MCOs Begin Dual Demonstration Dialogue with Nursing Facilities

Earlier this week, we received word from a member facility in Northern Virginia that they were visited by representatives of a managed care organization (MCO) to discuss the facility’s participation in the MCO’s Dual Demonstration network should they be awarded a contract by the Centers for Medicare and Medicaid Services (CMS) and the Virginia Department of Medical Assistance Services (DMAS).  As previously reported, Virginia is one of 26 states seeking CMS approval to implement a three-year pilot which would combine Medicare and Medicaid funding for dual eligible beneficiaries.  All health care services provided to these individuals would be coordinated through, and payment made by, MCOs in each of four designated geographic areas comprising the Demonstration.  Under the proposal, 164 of 267 Virginia Medicaid-participating nursing facilities (61.4%) are located in one of the four pilot areas.  Beneficiaries would be automatically enrolled effective January 1, 2014.

Through ongoing discussions with DMAS leadership, VHCA was able to obtain two key assurances related to network participation under the Dual Demonstration.  First, DMAS agreed to a provision that guarantees that any Medicaid-participating nursing facility is eligible to participate in and contract with MCOs.  Second, DMAS will stipulate that MCOs can pay nursing facilities no less than rates in effect under the current fee for service methodology.

According to information provided this week by DMAS, MCOs should be starting to reach out to nursing facilities for introductions and will be working towards signing contracts.  Some MCOs may ask for letters of intent as an interim step before signing contracts.  DMAS received letters of intent from eight MCOs at the beginning of the Dual Demonstration discussions, and since that time one or two additional health plans have expressed an interest in the Virginia pilot program.  MCOs will be required to submit information about their networks to both DMAS and CMS in order to satisfy the network adequacy analysis as part of the MCO selection process.  The CMS timeline establishes February 21, 2013 as the deadline for MCOs to submit their networks to the Health Plan Management System (HPMS), but that may change.  DMAS is targeting for the end of this year getting the Requests for Applications (RFAs) out to MCOs and would require MCOs to submit networks information and composition to the Department sometime in the winter/early spring of 2013.  

The Dual Demonstration initiative being pursued by CMS and DMAS represents unchartered waters for Virginia’s nursing facilities.  We strongly encourage member facilities to read and listen carefully to information presented and available on the topic.  Given the overall lack of specific details from either CMS or DMAS, we see no compelling reason for facilities to commit at this time to a formal agreement with MCOs.  Facilities should keep in mind that MCOs are simply preparing to respond to a future RFA.  Currently, MCOs have no official standing with CMS or DMAS as it relates to the Dual Demonstration. VHCA will continue working with the Association’s Ad-hoc Medicaid Managed Care Committee and with DMAS to make certain that the requirements stipulated in the RFA recognize the need for MCOs to work collaboratively with nursing facilities to ensure that providers can continue to provide high-quality services to the dual eligible beneficiaries we now care for in an payment environment that promotes long term financial viability.