Medicaid VBP Update:
Upcoming Implementation and RN Measure
In three weeks the per resident per day Medicaid add-ons will be replaced by the new Medicaid Nursing Facility Value-Based Purchasing (VBP) Program. The General Assembly has boosted the funding for this program in the budget pending Gov. Glenn Youngkin’s approval.
DMAS has also clarified the data it will be using around the RN 8-hour minimum staffing metric. If you attended a recent District Meeting where Steve Ford and I discussed this issue, make note of the updates we have for you.
RN 8-hour Minimum Staffing Metric
As some members reviewed their baseline data for the 8-Hour RN minimum staffing metric, they noticed discrepancies in their data. VHCA-VCAL met with DMAS to discuss the issue and has received clarification from the agency on what data will be used going forward.
VHCA-VCAL learned that DMAS used only one of the three RN job codes included in the Payroll Based Journal (PBJ) reporting. This resulted in incorrect baseline data for all facilities. The intent of the Medicaid VBP Program has always been to use existing CMS metrics and PBJ data to avoid new reporting requirements in the program.
VHCA-VCAL provided detailed information to DMAS on the three RN job codes (RN Director of Nursing- job code 5, RN with administrative duties-job code 6, and RN performing clinical services-job code 7) used in the PBJ RN data. DMAS initially decided to count only the hours for job code 7. VHCA-VCAL pointed out that CMS allows for the required eight hours of RN coverage to be fulfilled by RN time that is reported via job codes 5, 6, and 7. The CMS PBJ policy manual explains that total hours of an employee are reported based on their primary role although it is understood that most roles have a variety of non-primary duties conducted throughout the day. Moreover, the time reported for job codes 5 and 6 directly affects the quality of care residents received.
With this clarification, DMAS announced it will modify the RN metric to include all three job codes in alignment with CMS to set the baseline for the 8-hour RN minimum metric. DMAS will be recalculating the base period data for the RN metric in the coming weeks.
VBP Funding
As a reminder, the VBP Program funding is intended to replace the value of the Medicaid add-ons provided during the pandemic. The state budget includes $25.1 million in funding for the VBP program for the first year (FY 2023) and $50.7 million for the second year (FY 2024). This is in addition to $93.5 million authorized when the program was created last year.
Budget language specifies that the non-metric-based portion of the funding will be accomplished as a rate add-on instead of as a lump sum as proposed by DMAS. This means that instead of waiting until December for payment, payment will occur with claims for dates of service beginning July 1, easing the transition from the full $15 add-on currently included in the rate.
It appears that the additional VBP Program funds will be included in the split between metric and non-metric-based payments. As such, what was projected to be approximately $7.50 per resident per day as of July 1, 2022, should be closer to $9.50; the projected $3.75 per resident per day for July 1, 2023, should be closer to $5.80. (DMAS will determine the actual amounts; the above should only be considered estimates). Additionally, all the per diems associated with the actual metric performance will be increasing as well. We will provide final updates once we receive them from DMAS.
