Commonwealth Coordinated Care Update

VHCA has been informed by the Department of Medical Assistance Services (DMAS) that all three managed care organization (MCO) contract templates for the Commonwealth Coordinated Care program (CCC or the dual demonstration) have been approved.   As described by DMAS, each of the three MCOs (Virginia Premier, Humana, and Anthem HealthKeepers) may now begin talking with individual nursing facilities regarding participation in the CCC program.

Concurrent with DMAS's review of the proposed MCO contract templates, VHCA submitted to DMAS a list of issues we felt needed to be addressed in the contracts so that first, Virginia nursing facilities would have sufficient information to evaluate whether they want to participate with an individual health plan in the dual demonstration; and second, to clarify and standardize the terms within each of the three contracts.

Based upon our review, coupled with an analysis of each of the three contract templates by our legal counsel, it appears that many of these issues have been addressed in the approved templates.   However, not all of the issues that we raised with DMAS have been addressed.  We encourage our members to review COMMONWEALTH COORDINATED CARE: Considerations for Nursing Facilities as an educational resource in connection with your evaluation and decision to contract with an individual health plan.  If there are issues not clearly resolved to your satisfaction, then you should ask the appropriate MCO to address and clarify the issue to your satisfaction.  Within the next week, we plan to augment the linked resource document with a side-by-side comparison of key provisions and observations related to each of the three approved MCO contract templates.

The decision to execute a CCC program contract, as presented, is yours.  We continue to encourage our members to consider delaying the execution of contracts with MCOs especially in light of the fact that the “three-way contract”, the core agreement between the Centers for Medicare and Medicaid Services (CMS), DMAS and each of the MCOs, has not been finalized and the blended payments to MCOs have not been formally established.  One additional key element that we understand will be addressed in the three-way contracts is the provision for prompt payment as it relates to MCO payments to providers.  While there are no guarantees, we anticipate that the three-way contracts may be finalized over the next two to four weeks.  

We hope the linked educational resource document will help your understanding of some of the key issues for nursing facilities in the contracts for services provided under the CCC program.