UPDATE: Commonwealth Coordinated Care

On July 31st, representatives from the Department of Medical Assistance Services (DMAS) presented an update to members of the Commonwealth Coordinated Care Advisory Committee.  DMAS and the Centers for Medicare and Medicaid Services (CMS) are moving forward with the development and implementation of Virginia’s demonstration for a blended Medicare-Medicaid program for dual eligibles – now known as Commonwealth Coordinated Care (CCC).

While DMAS has not disclosed specific information following their initial announcement in June that it intended to award contracts to three health plans for each of the five demonstration regions, speculation persists that MCOs who were not selected to participate may be pursuing appeal and possible legal action against the Department.  The initial notice of intent to award has been removed from the Department’s website.  DMAS would only offer a brief letter from Director Cindi Jones that is reproduced below:

July 30, 2013

Dear Stakeholders,

At this time, the Department of Medical Assistance Services (DMAS) is conducting negotiations with selected firms regarding the Request for Proposal (RFP 2013-05) for the Medicare-Medicaid Alignment Demonstration.  Throughout this procurement phase, DMAS and the Centers for Medicare and Medicaid Services (CMS) representatives will work with Humana Health Plan, Inc., VA Premier Health Plan, Inc., and HealthKeepers, Inc. through the negotiation process. This process includes CMS readiness reviews, rate setting, education and training, and subsequent negotiation of a contract with Offerors who meet all federal requirements.

Once an agreement has been reached and a decision to award a contract has been made, DMAS will post the notice of intent to award.

Cynthia B. Jones

We learned during the advisory committee meeting that DMAS has informed the three health plans that they must submit proposed provider participation agreements to the Department for review and approval prior to requests for execution with individual providers – including skilled nursing facilities.  This news reinforces earlier VHCA communications to member facilities that it is premature to execute MCO provider agreements at this point in time.  During a July 18th meeting between representatives of VHCA’s Managed Care Committee and DMAS, Karen Kimsey who serves as Deputy Director, Complex Care and Services and who has overall responsibility for the roll-out of the CCC program, indicated that she anticipated that MCOs and nursing facilities would most likely be evaluating and executing provider agreements between mid-September and October.  VHCA’s Managed Care Committee is working aggressively with DMAS to ensure that provider agreements between health plans and SNFs contain provisions to ensure the continued ability of providers to deliver high-quality post-acute and long term care services and to be adequately and fairly compensated for those services.

For nursing facilities, the Commonwealth Coordinated Care program represents much more than a demonstration.  Beginning in 2014, 71.4% of Virginia SNFs will begin to provide services to Medicare-Medicaid (duals) beneficiaries under the managed care program as it is now being developed.  The table below reports the number of SNFs in each of the five CCC demonstration regions.

CCC Region Number of Facilities
Central Virginia 58
Northern Virginia 34
Southwest Virginia 26
Tidewater 48
Western Virginia 21
CCC Demonstratration Subtotal 187
Not in CCC Demonstration 75
State Total 262

The two major efforts ahead for DMAS and CMS are the completion of readiness reviews for each of the participating MCOs and the development and signing of three-way (CMS/DMAS/MCO) contracts.  As of now, DMAS intends to work toward the completion and execution of the three-way contracts by November of this year.  While no formal start date for the CCC program has been announced, DMAS indicates that dual beneficiaries within the Central and Tidewater regions will be passively enrolled beginning in May of 2014.  

The financial goals of the program are to begin to “bend the cost curve” of expenditure growth associated with Medicare and Medicaid funding for services provided to dual eligible beneficiaries.  DMAS indicates that actuarially determined blended rates to be paid to MCOs now being calculated will be adjusted to reflect required savings of 1.0% in calendar years 2014 and 2015, 2.0% in calendar year 2016 and 4.0% in calendar year 2017.  

Members with questions about the Commonwealth Coordinated Care program are encouraged to contact VHCA.  In September, VHCA members attending the Annual Convention in Roanoke will have an opportunity to hear from Jade Gong, a nationally recognized expert in the financing and operations of managed long term care programs, about strategies that providers must consider in determining where and how they will survive in this new environment.