HHSC held a meeting to inform providers and interested parties to the changes brought about by the implementation of the QIPP for nursing facilities.
QIPP Overview
- Similar to NAIP (Network Access Improvement Program)
- Four parts of QIPP philosophy
- Culture change within facilities
- Small housing model implementation
- Improvements in staffing
- Improvements in quality of care
- Facilities must secure source of IGT and submit proposals by deadline to be considered
- Facilities must not be a special focus facility and must not have a history of denial of payment over certain periods of time
- QIPP proposals should be submitted to HHSC and outline projects money will be used for, proposals must include:
- Overview of projects
- Forecasted and itemized costs
- Valuation of projects, pro-rated
- Performance metrics, including annual goals and quarterly benchmarks
- HHSC evaluates largely based upon the following criteria:
- How proposal relates to QIPP philosophy
- How progress is measured for the project, including appropriateness of the selected metrics
- Comparison of valuation to forecasted costs
- Reasonableness of forecasted costs
- After implementation, HHSC will ask for quarterly status reports
- No defined dollar amount cap for projects yet, HHSC is investigating
QIPP Similarities to NAIP
- Available to public hospitals currently
- Hospitals negotiate plan with MCO and then submit to HHSC for approval, however primary contractual relationship is between hospital and MCO
- Similarly, nursing facilities would contract with MCO under QIPP and submit those proposals to HHSC for approval
- Valuation is built in to capitation rate
- No risk to MCOs under NAIP, not dependent on days of service etc., projects have fixed negotiated dollar amount
QIPP and Federal Regulations/IGT
- Non-federal share in increase to capitation must be supported by IGT, QIPP is to be opened to publicly and privately owned nursing facilities, private facilities must secure “allowable” IGT as program is not to be funded through GR
- Funds will be directed to whoever owns the nursing facilities
- Private facilities must find IGT partner, aka a publicly owned entity
- IGTs must be compliant with federal regulations, process is complicated
- If federal government decides IGT is not allowable funds will be recouped from HHSC, who will then recoup from provider
- Emphasis on the hospital owning the nursing facility, if CMS is told relationship is different could be “serious problems”
- Primary work will be between entity that owns the nursing facility and MCO, agreement is only reviewed by HHSC
Discussion
Jamie Dudensing, TAHP
- There are not many NAIP projects and they are not necessarily hard to secure. IS it the intent of HHSC to have every QIPP project secure separate approval
- Very good question, will talk with TAHP, providers, and MCOs to work the problem out, expect many more nursing facilities will be interested in QIPP than hospitals were in NAIP
- Could there be a way to consolidate the workload, but leave it procedurally similar to NAIP
- Yes, but HHSC wants the process to be as easy as possible
- Can multiple parties on both sides of the QIPP project be involved
- Should have a conversation about this
- If you are a nursing home that contracts with multiple MCOs, does QIPP program need to work with all of those MCOs
- Understanding is no, can work with individual MCOs on projects
- Regional restrictions apply to UPL and others, does QIPP have a regional restrictions regarding IGT partners
- IGT and facility must be within the same regional healthcare partnership or within 150 miles of each other, will not change for QIPP program
- Is remodeling included with regard to prior credit
- HHSC is not looking at prior credit
- Dudensing suggests having a handful of statewide projects to ease the burden of nursing facilities creating their own projects from scratch
Closing
- HHSC is intending to submit concept plan to CMS for approval of QIPP, will not require state plan amendment as MCOs are not under state plan
- Emphasis on discussing IGT with legal, process is not easy
- Valuation includes the following:
- Reasonableness
- Does the project improve quality of life
- Does the project help with cost avoidance
- Weighed against cost, however does not include cost as part of valuation
- HHSC is looking to have a back and forth conversation about rejected QIPP proposals, will help facilitate approval
- Not likely that all currently supported nursing facilities will be able to find MCO partner to meet QIPP criteria
- Overall, HHSC expects number of projects to decrease due to changes
- Federal partner unhappy with current program implementation, HHSC must look towards facility improvement, part of the goal of the rider and QIPP is to ensure funding is used to improve resident life
- HHSC is open to suggestions on criteria for quality measurements
- Legislature intends to fully transition program by September of 2016
- HHSC hopes to have proposals in by January for decisions by March
- IGT needs to fund administrative costs and the increased premium costs
- HHSC intends to distribute material by mid-September for feedback from facilities and MCOs