HCA Submits Comments on HHPPS Rule...little justification in terms of payment integrity or effective eligibility oversight, and needs to be revised. Congress’s decision and CMS’s

UPCOMINGPROGRAMS

Your Source for HOME CARE News Policy and Advocacy Vol 3 Issue 34 | September 4 2018

INSIDE

See FRAMES p 3

Senior FinancialManagers Retreat(Sept 6 amp 7)New Paltz

Mastering the LHCSASurvey ProcessUpstate amp NYCSessions

Sept 20 UticaOct 30 NYC

Ready and inCommand Hot Topicsand Best-Practices inEmergencyPreparedness(Sept 27)Troy

All-Sector SepsisSummit(Oct 3)Albany

Register at httpshca-nysorgevents-educationupcoming-events

See RULE p 2

HCA Submits Comments on HHPPS Rule

HCA last week submitted extensive comments on the US Centers for Medicare andMedicaid Servicesrsquo (CMS) proposed rule for the 2019 Home Health Prospective PaymentSystem (HHPPS) HCArsquos analysis of the new system suggests possible reimbursementimprovement for New York agencies Our comments recommend careful piloting to guide thesepotential positive results and we also address various components of the rule such as

Multiple concerns regarding CMSrsquos proposed Patient Driven Groupings Model (PDGM)payment methodology change for Calendar Year 2020 Some of those concernsinclude it being an untested model and our request for CMS to phase it in over time

HCA Frames Urgent Priority Issues with Legislature Executive

HCA has initiated meetings and messaging recommendations with the Legislature andExecutive to frame a priority slate of urgent and proactive provider and health plan issuesThese meetings are focusing on immediate and near-term issues in the field as well asproactive messaging and table-setting for the 2019 calendar of state budget legislative andpolicy development

HCA Submits Comments on HHPPS Rule1HCA Frames Urgent Priority Issues with Legislature Executive1HCA Comments on SED AHHA Regulatory Proposal42017 LHCSA Statistical Report and Resources Posted4DOH Releases Guidance on MLTC-LHCSA Limits5DOH Distributes FAQs on LHCSA Moratorium6Guildnet Files Request to Close7HCA Begins Active Steps on Pediatric Iteration of HCA Sepsis Tool7Member Hiring Announcement8HCA Offers Key Input to DOH on CFCO-MLTCPACE9HCA Submits Recommendations on Universal Billing Codes9CMS Releases 2016 Home Health Medicare Utilization ampPayment Data10CMS Announces Key Dates for Hospice Public Reporting10

DOH Releases 2019 Minimum Wage Survey for Hospices11Join HCA for Downstate LHCSA and HCC Forum12Upcoming DOH Preparedness Webinars Exercise Plus HCA Conference12Sexual Harassment Training and Guidance Released13LawTalk Intricate Requirements Govern OT for Salaried Employees14RWJF Grant Opportunity15Upcoming Deadlines16Update Provided on Changes in SPAs 1915 Waiver Reviews17CMS Releases Guidance on Medicaid 1115 Waiver Demos17NYSE-CON Changes Made18DOH Posts Regulatory Agenda18Providers Reminded About Medicaid Revalidation18HEPC Meetings Scheduled for Fall19Health Resources20

LAWTALK

The next installment of ourmonthly LawTalk column bylawyers at Jackson Lewisexplores overtime payrequirements for salariedemployees

PAGE 14PAGE 12

BILLING CODES

HCA submitscomments ondraft DOHrevisions to theuniform billingcodes policy

PAGE 9PAGE 4

LHCSA STAT REPORT

The 2017 LHCSA StatisticalReport is ready forcompleting by November16 including a newsubmission process andregistration requirement

LHCSA HCC FORUM

With so many changes affectingLHCSAs mdash from contract limits tothe moratorium and more mdash donrsquotmiss our Oct 4 Downstate LHCSAand HCC Forum delving into issuesdirectly affecting LHCSAs

2

The Situation Report is a weeklypublication of the Home CareAssociation of New York State(HCA) Unless otherwisenoted all articles appearingin The Situation Report are theproperty of the Home CareAssociation of New YorkState Reuse of any contentwithin this newsletterrequires permission fromHCA

Al CardilloActing President

acardillohcanysorg

Roger L NoyesDirector of CommunicationsEditor of The Situation Report

rnoyeshcanysorg

Patrick ConoleVice President

Finance amp Managementpconolehcanysorg

Andrew KoskiVice President

Program Policy amp Servicesakoskihcanysorg

Laura Constable Senior Director

Membership amp Operationslconstablehcanysorg

Celisia StreetDirector of Education

cstreethcanysorg

Mercedes Teague Finance Manager

mteaguehcanysorg

Jenny KerbeinDirector of Governance amp

Graphic Designjkerbeinhcanysorg

Billi Wilson Manager Meetings amp Events

bwilsonhcanysorg

Teresa BrownAdministrative Assistant

tbrownhcanysorg

Home Care Association of New York State (HCA)388 Broadway 4th Floor Albany NY 12207

Tele 518-426-8764 Fax 518-426-8788 Website wwwhcanysorg

The Situation Report the Home Care Association of New York State Volume 3 No 34 September 4 2018

RULE from p 1

underlying problems with the negative behavioral adjustmentthat CMS assumes the need for adequate time so thatproviders can implement such a massive payment changeand the fact that over 50 percent of home health patientswould fall into the Medication Management Teaching andAssessment (MMTA) clinical diagnosis

The current face-to-face (F2F) requirement remains an undueburden for home health agencies and physicians alike withlittle justification in terms of payment integrity or effectiveeligibility oversight and needs to be revised

Congressrsquos decision and CMSrsquos proposed phase-out of thehome health rural add-on between CY 2019 and 2022 Theadd-on should be restored and CMS should monitor theimpact of its tiered approach that treats different ruralcounties in a disparate manner

Enduring concerns with CMSrsquos proposed wage index and theneed for it to more accurately reflect local market conditions

The need for CMS to provide further analysis of the number ofagencies affected by the OASIS submission and pay-for-reporting thresholds and penalties

Ongoing concerns with CMSrsquos value-based purchasingdemonstration project the home infusion therapy proposal andthe lack of funding for Health Information TechnologyExchange

For each area of concern HCA offers specific comments orrecommendations HCArsquos comments are at httpshca-nysorgwp-contentuploads201809HCA_CY2019HHPPS_ProposedRuleComments_083018pdf

A final rule is anticipated by November 2018 with the 2019 HHPPSgoing into effect on January 1 2019

To learn more about the impact of the rule members should be sureto attend HCArsquos Senior and Financial Managerrsquos Retreat later thisweek on September 6 and 7 at the Mohonk Mountain House Resortin New Paltz Colin Roskey Partner at Scully Roskey amp Missmar willdevote much of his presentation to this topic along with otherfederal policy updates

For more information please contact Patrick Conole at (518) 810-0661 or pconolehcanysorg

3


In this past weekrsquos first high-level sessions HCA Acting President Al Cardillo and HCA counsel from HinmanStraub brought our advocacy to the leaderships of both houses of the Legislature and the executive team ofthe state Department of Health Office of Health Insurance Programs including the new State MedicaidDirector

Among the issues discussed were

The MLTC-Licensed Home Care Services Agencies (LHCSAs) contract limitations adopted in thebudget and the vast challenges in implementation dislocation and impacts on MLTCs agenciesworkers and patients created by the budget action and the state guidance put forward to date (seerelated p 5 story)

Moratorium on the processing of LHCSA applications and emerging areas of restriction (see relatedp 6 story)

Concerns over state rate changes reductions and cuts to MLTCs and their implications forreimbursement adequacy for plans and provider networks including care management andadministrative cuts coverage of minimum wage and other (new and existing) program mandatesMoreover these state rate actions are occurring while the state is simultaneously requiringtransition to value based payment phase 2 contracting incorporation of the Community First ChoiceOption and execution of other budget changes like contract limits the nursing home carve-out andother elements

Announced health plan withdrawals from the marketplace and reported fragility implications fortransition support as well as support needed by existing plans and providers including protectionsagainst defaulted payments by closure or withdrawing plans

The current status and support needs of certified home health agencies (CHHAs) especiallyconcerning workforce regulatoryprocedural relief and funding needs HCA emphasized theimplications to the entire delivery system if CHHAs are not supported in executing their rolesWorkforce needs were also discussed across all providers

Support for home care in new and evolving roles and models in the health system HCA emphasizedhome carersquos ability to contribute to the statersquos public health primary and preventive care goals inparticular in collaboration with physicians hospitals plans and other partners

HCA discussed and shared our legislative proposals on the above items and will be following up withadditional key officials in both the Legislature and Executive branches

Look for more details and discussion on these items at several upcoming programs like our LHCSA Forum(see related p 12 story) and more immediately this weekrsquos Senior Financial Managers Retreat (onSeptember 6 amp 7) at the Mohonk Mountain House in New Paltz HCA is building upon these and other stateand federal issues as we aggressively and comprehensively pursue solutions support and advancement ofopportunities for home care and our collaborative role in the health system

For further information contact Al Cardillo at acardillohcanysorg

FRAMES from p 1


4

Continued on next page

HCA Comments on SED AHHA Regulatory Proposal

HCA has submitted comments on the state Education Departmentrsquos proposed regulations implementingeducation law provisions of the new Advanced Home Health Aide (AHHA) program

The regulations are parallel to the state Department of Healthrsquos regulations proposed previously for AHHA

HCA urged streamlining of the regulations as well as essential clarifications related to allowable tasksrequired supervision training and other areas

Since well before statute was enacted HCA has urged that AHHA provisions be flexible for providers and plansand do not impose new excessive mandates and regulatory burdens We have also sought to ensure alignmentfor MLTCs and providers within that the statersquos AHHA implementation funding adequacy for MLTCs providersand workers and supportive recognition of nurses in their responsibilities under the program

HCA has long advocated for flexibility in the training and potential assignment of home health aides and weappreciate the extensive work underway by the Departments of Education and Health in implementation of thismajor new change affecting the home care workforce We will continue to seek ways of fine-tuning thisinitiative to maximize the benefits for home care hospice and MLTCs the patients health personnel and thesystem

For further information please contact a member of the HCA Policy Team

2017 LHCSA Statistical Report and Resources Posted As announced in an alert to members late last week the state Department of Health (DOH) has posted the2017 LHCSA Statistical Report and resources to assist LHCSAs in downloading and completing this newlyformatted and revised Report on the Health Commerce System (HCS) The resources include instructions on downloading a new platform the Universal Data Collection Systemwhich is used to complete the report instructions on how to complete each section of the report frequentlyasked questions and five videos on the new 2017 LHCSA Statistical Report The videos explain how todownload and install the new software download the report open the report enter data and validate finalizeand upload the report All of these resources are located on the HCS main page under ldquoNewsroom Highlightsrdquo In the future theseitems can also be accessed by clicking on ldquoMy Contentrdquo on the top tool bar going to ldquoDocuments by Grouprdquothen ldquoView all Document Groupsrdquo ldquoLong Term Carerdquo ldquoTrainingrdquo ldquoHome Carerdquo and lastly ldquoLHCSA StatisticalReportrdquo DOH notes that only those LHCSA staff in the Administrator role on the HCS as of the first week of Augusthave access to the Healthcare Financial Data Gateway which is needed to download the software and theReport HCA strongly recommends that all agencies review the videos and instruction documents so that you becomefamiliar with the 2017 revised Statistical Report and can complete it by the November 16 deadline


5

Continued from previous page

Reminder New Registration Requirement and Enforcement Penalties for Non-Compliance

HCA reminds LHCSAs that there is a new annual LHCSA registration process and the Statistical Report has beenamended to capture the necessary registration information Very importantly the Statistical Report is the onlymeans for fulfilling this new registration requirement by the November 16 deadline or else possibly face thefollowing potential penalties

A $500 fine for each month or part of a month that the organization is not registered

LHCSAs that are not registered will not be allowed to operate until they become registered

LHCSAs that fail to register timely for two years (not necessarily consecutive) may have their licensesrevoked

Also DOH has included compliance with DOH reporting requirements such as statistical reports as one of thecriteria that managed long term care (MLTC) plans are required to consider in implementing the recent limits onthe number of LHCSAs that MLTCs can contract with

Any questions concerns or comments regarding the 2017 LHCSA Statistical Report should be sent to DOHat HCStatRptshealthnygov (please copy Andrew Koski at akoskihcanysorg)

DOH Releases Guidance on MLTC-LHCSA Limits

As reported in an HCA alert the state Department of Health (DOH) on August 20 released guidance related to the2018-19 state budget provision that limits the number of Licensed Home Care Services Agencies (LHCSAs) withwhich Managed Long Term Care (MLTC) partial capitation plans may contract

The guidance is available at httpshca-nysorgwp-contentuploads201808MLTC-LHCSA-Limits-_082018pdf

HCA had submitted comments on a draft version Some of these comments were included in the final versionUnfortunately many industry edits and recommendations were still not incorporated and HCA will continue toadvocate for flexibility and accommodations for plans and LHCSAs in implementing these changes The guidancecovers

How the limit on the number of MLTC-LHCSA contracts is computed for 2018 and 2019 and later withexamples including when a LHCSA has multiple site contracts with the same MLTC plan and treatment ofIndependent Practice Associations (IPAs)

Factors that MLTC plans need to consider in establishing limits

Enrollee notification

Network adequacy

Exceptions to the limits and how exceptions are processed by DOH and Continued on next page


6

Compliance by plans

HCA advises members to read the entire guidance and submit any questions toLHCSAExceptionshealthnygov (and copy Andrew Koski at akoskihcanysorg)

DOH Distributes FAQs on LHCSA Moratorium On August 20 the state Department of Health (DOH) released a Frequently Asked Questions (FAQs) documenton the recent state budget provision that placed a two-year moratorium on the ldquoprocessing and approval ofapplications seeking licensurerdquo of a Licensed Home Care Services Agency (LHCSA) under Public Health Lawsection 3605

The FAQs are at httpwwwhealthnygovfacilitiesconsdocslhcsa_moratorium_faqpdf The FAQs cover

Changes in business entity type (these are subject to the moratorium)

Documentation required under the ldquoserious concernsrdquo exception

Applications submitted prior to April 1 2018 but which have not received Public Health and HealthPlanning Council approval or contingent approval (these are subject to the moratorium)

Management agreements (these are not subject to the moratorium)

Home care licenses that are not active In such cases (meaning there are no clients and no employees)the licenses cannot be sold or transferred and the LHCSA is required to surrender its license to DOH

Refund of LHCSA application fee

Application process for adding sitesservicescounties (these are not affected by the moratorium)

Many issues related to the Assisted Living Program (ALP)LHCSA exception and

The LHCSA application process after the moratorium expires (applications will be accepted pursuant tothe statutes and regulation in effect at that time)

The FAQs should be reviewed in tandem with other guidance issued by DOH at httpswwwhealthnygovfacilitiescons

Additional questions regarding the application moratorium can be sent to homecareliccerthealthnygov

Any members who submit questions to DOH are invited to copy HCA on the e-mail message (copy AndrewKoski at akoskihanysorg) or alert us to your questions so that we can track DOHrsquos response or otherwisesupport you in gaining clarification




7

HCA has been in steady contact with DOH about areas of overreach in the application of the moratorium thatappear counter to the budgetrsquos intent Thus far DOH has been severely constrained in its remedies bydetailed specifics of the adopted change in law

The 2018-19 state budget authorized additional changes that impact LHCSAs including a limit on MLTC-LHCSA contracts (see related p 5 story) a new LHCSA registration process (see related p 4 story) newLHCSA and Fiscal Intermediary (FI) cost reports a new LHCSA public need methodology and a ban on FIldquofalse or misleadingrdquo advertising HCA will provide further information on these changes as more guidance isissued

Guildnet Files Request to Close

Guildnet had filed a request with the state to stop offering its managed long term care (MLTC) plan

The state Department of Health (DOH) confirmed to HCA that the nonprofit has stopped enrolling newmembers As reported in the press Guildnet desires to cease operations on December 1 2018 DOH hasindicated that they have not approved this timeline As of August 2018 Guildnet has 7316 members in its MLTC plan 478 in its Medicaid Advantage Plus planand 417 in its Fully Integrated Duals Advantage (FIDA) plan ndash all in New York City In September 2017 DOH released guidance (httpswwwhealthnygovhealth_caremedicaidredesignmrt90mltc_policy17-02htm) that covers plan closures service area reductions and mergers acquisitionsand other arrangements

HCA has been meeting with state legislative and administrative offices emphasizing our concerns for allparties over implications of the closure as well as related concerns about payment adequacy to plans andrecalibrated rates the steady flow of new mandates and other challenges to the MLTC and provider networkin the state We continue to emphasize to the state the necessity of providing plans with payments that areadequate to cover their services and any new mandates like the increased minimum wage Community FirstChoice Option and more

HCA Begins Active Steps on Pediatric Iteration of HCA Sepsis Tool

HCA has begun active efforts to develop a pediatric iteration of its unique Home Care Sepsis Tool

The current HCA tool which has been adopted by home agencies throughout the state as well as in otherstates incorporates adult measures in assessment areas related to sepsis criteria Measures differ forchildren and in fact have variation across age groups

HCA with the assistance of Sepsis Alliance has been working to engage pediatricians with expertise insepsis care for groundwork on a pediatric version of the HCA sepsis tool This past week HCA IPRO HCAsepsis clinical leader Amy Bowerman of Senior Network HealthVNA of Utica and Sepsis Alliance conferencedwith sepsis pediatric experts and outlined a plan of action




8

Dr Elizabeth Alpern a pediatric emergency physician at Northwestern University provided technicalsupport and has now networked HCA with the national Childrenrsquos Hospital Associationrsquos ImprovingPediatric Sepsis Outcome Collaborative (IPSO) for next levels of input

Children especially the very young and those with compromised immune systems are among thehighest at risk for sepsis and of course public education and awareness are critical for all families andchildren as too many cases exist where healthy children fall victim to this preventable and treatablecondition (especially when identified early) Indeed 12-year-old Rory Stauntonrsquos tragic loss to sepsisfollowing a cut playing basketball is what changed (and continues to change) the New York Statelandscape of sepsis screening and intervention in this state and in other states due to the advocacy ofhis parents Ciaran and Orlaith The Stauntons will also be part of our work in this pediatric initiative

HCA will keep members apprised of the developments meanwhile stay informed through HCArsquos sepsiswebsite at httpstopsepsisathomenyorg


HIRING

Staff Development Education Supervisor ndash Home HealthFull Time 9am-5pm

NYU Winthrop Hospitalrsquos Home Health Agency ranks as a top-performing US Home Health Agency Come join ourstellar team of nurses therapy professionals and social workers who provide home health care to our maternalchild and adult population

We have an exceptional opportunity for a Staff Development Education Supervisor to be responsible for homehealth staff education development and professional growth including our orientation program (didactic amppractical components) With collaboration of the Director of Quality ManagementStaff Development and thedepartmentrsquos management team you will identify develop and plan appropriate staff development programs tosupport agency needs to provide optimum patient outcomes Working with the Administrator and the Director ofPatient Services you will research coordinate amp establish new programs for the agency

We require NYS RN License BSN with 2 yearsrsquo experience in education in a Certified home care agency 2-3 years clinical nursing practice 2 years community health nursing Good communicationcomputer skills

NYU Winthrop Hospital is located on Long Island in Western Nassau County just 25 miles from Manhattan Email

HRHomeCarenyuwinthroporg



9

HCA Offers Key Input to DOH on CFCO-MLTCPACE

HCA continues to press for procedural efficiency clarity and overall workability as the state Department ofHealth (DOH) develops guidelines and requirements for implementation of the Community First ChoiceOption in Managed Long Term Care (MLTC) plans and Programs of All-Inclusive Care for the Elderly (PACE)

This past week DOH held a CFCO advisory group meeting to discuss its latest plans and proposedprocedures for implementation While the procedures are very much in a ldquowork-in-progressrdquo stage DOH islooking to move at a steady pace toward implementation HCA and member MLTCs have been concernedabout the many CFCO requirements and the nature parameters and financing of CFCO-covered servicesversus traditional services covered under MLTCPACE

At this past weekrsquos meeting HCA recommended technical and policy efficiencies and clarifications as wellas ways to promote adaptability to plan operations clarification of payment rules seamlessness withexisting MLTCPACE procedures wherever possible and mitigation of fair-hearing risks HCA has alsopreviously and again this past week made broader model recommendations for alternative ways ofimplementing CFCO that would provide options to largely avoid the myriad issues in the current DOHapproach

DOH is inviting input over the next several weeks The DOH materials outlining the presentation andwebsites for input can be viewed at httpshca-nysorgwp-contentuploads201809CFCO-Overview-8-29-18-Read-Onlypdf

HCA Submits Recommendations on Universal Billing Codes

Last week HCA sent recommendations to the state Department of Health (DOH) on its recentlyimplemented universal billing codes for Medicaid home and community-based long term care servicesprovided to managed care plans

Some of HCArsquos recommendations based on feedback from members included the need for

Separate codesmodifiers to allow for billing for RN and LPN services by visit

Separate codesmodifiers for physical therapy assistants (PTAs) and occupational therapy assistants(OTAs)

A separate code for telehealth monitoring per day

A new code for telehealth originating site fee (DOH has agreed to do this) and

An additional code andor modifier in cases where more than two consumers are being providedhome health aide services in the same household (DOH has agreed to do this)

HCA will keep members informed of DOHrsquos response and any resulting changes in the codesmodifiers Formore information contact Andrew Koski at (518) 810-0662 or akoskihcanysorg


10

CMS Releases 2016 Home Health Agency Medicare Utilization and Payment Data The US Centers for Medicare and Medicaid Services (CMS) has posted the fourth annual Medicare HomeHealth Agency (HHA) Utilization and Payment Public Use File (PUF) with data for 2016 The PUF summarizes information on services provided to Medicare beneficiaries by home health agencies Itcontains information on utilization payment submitted charges and demographic and chronic conditionindicators organized by CMS Certification Number (6-digit provider identification number) Home HealthResource Group (HHRG) and state of service The 2016 PUF has information for 10139 home health agencies almost 6 million claims and $18 billion inMedicare payments for 2015 CMS protects beneficiariesrsquo personal information in all public data releases The updated 2016 data and supplemental information can be accessed at httpswwwcmsgovResearch-Statistics-Data-and-SystemsStatistics-Trends-and-ReportsMedicare-Provider-Charge-DataHHAhtml HCA has compiled the 2016 Medicare Utilization and Payment data for all of the HHAs in New York and hasposted this to our HCA Data Page at httpshca-nysorghca-data See the section labelled ldquoHome Health andHospice Medicare Resourcesrdquo HCA Data is a members-only page that provides data reports to assist home care and hospice providers andmanaged care plans in their benchmarking efforts understanding of system-wide trends and access toreimbursement and premium rates The page is not visible on our site unless you are logged in with an HCAmember website account Our log-in page is here httphca-nysorglogin Upon login the HCA Data link will appear in the site menu atthe top right (though you may have to refresh your browser first) Simply e-mail HCArsquos Communications DirectorRoger Noyes at rnoyeshcanysorg if you do not yet have an HCA website account or would like furtherinformation

CMS Announces Key Dates for Hospice Public Reporting The US Centers for Medicare and Medicaid Services (CMS) is reminding hospice providers to make sure thattheir Hospice Item Set (HIS) records are complete and accurate prior to submission CMS wants hospice providers to submit all HIS modification or inactivation records prior to the ldquofreeze daterdquoprior to public reporting Hospices should check CMSrsquos Key Dates webpage (httpswwwcmsgovMedicareQuality-Initiatives-Patient-Assessment-InstrumentsHospice-Quality-ReportingPublic-Reporting-Key-Dates-for-Providershtml) fordeadlines to meet when modifying data so that those modifications are reflected in your corresponding HISProvider Preview Reports and on Hospice Compare Additional information can be found at httpswwwcmsgovMedicareQuality-Initiatives-Patient-Assessment-InstrumentsHospice-Quality-ReportingHQRP-Requirements-and-Best-Practiceshtml

11


DOH Releases 2019 Minimum Wage Survey for HospicesALP Survey Also Posted

The state Department of Health (DOH) recently issued a Dear Administrator Letter (DAL) to Hospiceproviders requesting information via a survey to assess the impact of the statersquos minimum wage increasefrom January 1 2019 through January 1 2021 The DAL can be downloaded at httpshca-nysorgwp-contentuploads2018092019-Hospice-survey-MW-DALpdf The survey is at httpswwwsurveygizmocoms34543360Minimum-Wage-Survey-Hospice-2019 The Minimum Wage Act (Article 19 of New York State Labor Law) sets benchmarks for minimum wagethrough 2021 DOH is surveying health care providers to determine the financial impact of scheduledminimum wage increases over the coming years In completing the survey hospices should use employee wage data from April 1 2018 through June 302018 for your facility If your facility has locations in more than one minimum wage region you will berequired to provide the minimum wage data for each region within the survey The three minimum wageregions are New York City Northern Metropolitan (includes Nassau Suffolk and Westchester counties)and the remainder of the state All direct care worker hours for which your facility can produce a payrollrecord including direct contracted staff should be included in your counts Hospices must electronically submit their survey by close of business on Wednesday September 19 2018and DOH says it will not be granting extensions If your facility is not impacted by the minimum wageincrease for calendar years 2019 through 2021 or you choose to opt-out of the survey you are stillrequired to complete questions 1-3 and 5-6 of the survey The CEO or CFO of your facility will berequired to attest to the validity of the information provided HCA strongly encourages hospice members to complete this important survey The Department will onlyincrease providersrsquo Medicaid rates based on the data submitted in this survey Specific questions regarding DOHrsquos minimum wage survey can be sent to hospice-rateshealthnygov ALP Survey DOH has also released a survey for Assisted Living Programs (ALPs) to obtain information regarding thestatersquos minimum wage increase from January 1 2019 to January 1 2021 The survey is at httpswwwsurveygizmocoms34543570Minimum-Wage-Survey-ALP-2019 and also must be submitted bySeptember 19 2018 Questions regarding the ALP minimum wage survey can be sent to ALP-rateshealthnygov For further information contact the HCA Policy staff


12

Join HCA for Downstate LHCSA and HCC Forum on Oct 4

Please join your LHCSA and HCC colleagues HCA staff and Board Members on October 4 in New York City foran exchange of valuable information advocacy concerns and recommendations for action in support of LHCSAsand HCC members Some of the vital issues to be covered at our upcoming Downstate LHCSA Forum include

LHCSA-MLTC contract limits LHCSA moratorium and need methodology LHCSA Statistical Report and registration process 24-hourlive-in cases CDPAP Fiscal Intermediary authorization process Regulatory changes Uniform billing codes Additional issues or concerns Value Based Payments phase 2

This forum is for HCA members only but you must register and RSVP at httpshca-nysorgwp-contentuploads201808October-4-2018-Downstate-LHCSA-and-HCC-Forum-Registration-Formpdf

Join Upcoming DOH-Led Emergency Preparedness Webinars Exercise and HCAPreparedness Conference Home care and hospice providers throughout New York State are urged to participate in upcoming webinars anda training exercise offered by the state Department of Health Office of Health Emergency Preparedness (OHEP)in September and October

These programs complement an HCA conference on Emergency Preparedness hot-topics and best-practicesalso offered in September during Preparedness Month Details are below

OHEP Webinar Exercises 101 (September 7 from 1 to 2 pm) acquaints providers with the various typesof preparedness exercises stressing why they are an integral component of agenciesrsquo ongoingpreparedness activities (Register at httpsnylearnsphcomPublicCatalogDescriptionaspxu=kM6WW0gCRpkcHvKm5KI41OYokNI7litY4EKe2fwzjrVbfTW89SJ0dRm6k7rMi5gShAURjR2fdXWRE3d)

OHEP Webinar Writing an After-Action Report (September 21 from 1 to 2 pm) will help providerscorrectly execute After-Action Reports which are required as part of any exercise These reportsinclude what was supposed to happen what actually occurred what went well (strengths) areas forimprovement identified during an exercise and the timeline for incorporating necessary improvements(Register at httpsnylearnsphcomPublicCatalogDescriptionaspxu=kM6WW0gCRplE1yOOIY2AMQMayrnuXTME82ZlEqgh7ow84ZUvQlG2boU8xc2O75k4RHuqrNAJVnew3d)

Exercise Interoperable Communications Drill (October 9) will begin with an Integrated Health AlertNotification System (IHANS) notice at 9 am through the Health Commerce System (HCS) Agencieswill have until late morning to complete the drill and demonstrate their ability to receiveinformation by testing whether the agency has appropriate roles assigned and current contact


13

information in the HCS The following roles should be assigned and up-to-date in the HCSCommunications Directory Administrator Director Home Care Patient Services or Patient Services forhospices Emergency Response Coordinator and HPN Coordinator

These programs align with HCArsquos September 27 conference on Emergency Preparedness hot-topics that willoffer many other additional topics distinct from the DOH webinars including cybersecurity resources forassisting in the development of required home care and hospice emergency preparedness plans a session onkey considerations for developing a truly all-hazards approach to emergency preparedness planning and atable-top exercise that qualifies as one of the elements for meeting the federal Conditions of Participationrequirement to test your emergency preparedness plan Please register at httpshca-nysorgwp-contentuploads201808HCA-Emergency-Preparedness-Conference-9-27-18-Brochurepdf

Sexual Harassment Training and Guidance Released

The state has released a draft sexual harassment policy training and related guidance for public comment

The materials are located at httpswwwnygovprogramscombating-sexual-harassment-workplace andinclude

Minimum standards for employer sexual harassment prevention policies and trainings Model sexual harassment prevention policy Model sexual harassment complaint form Model training (script book and PowerPoint presentation) Frequently Asked Questions (FAQs)

Starting October 9 2018 employers are required to adopt the statersquos model sexual harassment preventionpolicy or revise their own policies to meet the statersquos minimum standards and provide annual sexualharassment prevention training to all employees

The draft FAQs clarify that by January 1 2019 employers must provide all employees with sexual harassmentprevention training either using the model created by the state or a comparable version that meets the statersquosminimum standards Furthermore new employees or employees who start after January 1 must complete therequisite annual sexual harassment training within 30 calendar days of hire

The sexual harassment materials are due to recent state budget provisions that require all employers to adopta sexual harassment prevention policy and provide related training extend sexual harassment protections tononemployees in the workplace ban enforcement of arbitration clauses for sexual harassment claims setforth a mandatory waiting period and revocation period for non-disclosure agreements related to sexualharassment claims and require entities that bid for state contracts to affirm compliance with sexualharassment training laws

The state law along with a related New York City (NYC) law is discussed in an HCA memo at httpshca-nysorgwp-contentuploads201804042318SexualHarrassmentMemoJacksonLewispdf

Earlier in August the New York City Commission on Human Rights posted a workplace poster on sexualharassment that must be displayed by all NYC employers starting September 6 and a fact sheet that


14

employers are required to provide to new employees upon hire (see the August 20 edition of The SituationReport for more information and links to materials)

The Stop Sexual Harassment in NYC Act mandates employer training on sexual harassment prevention (foremployers of 15 or more employees) expands NYC Human Rights Law coverage for gender-basedharassment claims to all employers extends the statute of limitations for gender-based harassment claimsunder the Human Rights Law from one to three years and extends protections to non-employees in theworkplace

LawTalk Intricate Requirements Govern OT Pay for Salaried EmployeesBy Christopher Stephens Attorney at Jackson Lewis PC

Many employers think that paying an employee on a salary basis automatically means that you do not haveto pay them overtime Employers frequently make this incorrect assumption across all industries includinghealth care Readers of this article however will not make this common mistake

The federal Fair Labor Standards Act (FLSA) generally requires that employers pay employees overtime at arate of one and half times their regular rate for every hour worked over 40 in a given work week The FLSAalso creates several exemptions from this requirement All of the so-called ldquowhite collarrdquo exemptions(administrative executive and professional) have one thing in common the ldquosalary-basis testrdquo In order toproperly classify an employee as exempt under one of those exemptions an employer must pay thatemployee a salarymdashmeaning that the employee generally receives the same amount of pay regardless ofthe number of hours workedmdashof at least $455 per week (or $23660 per year) Under federal law t isimportant to note that New York imposes a higher salary threshold than federal law

The applicable state threshold varies depending on the location and size of the employer For largeemployers (defined as those with 11 or more employees) the threshold is currently $975 per week ($50700per year) in New York City $825 per week ($42900 per year) in Nassau Suffolk and Westchester Countiesand $780 per week ($40560 per year) in all other areas of the state

Clearing this threshold requirement is not the end of the story however All exemptions also have a secondprong known as the ldquoprimary duties testrdquo This test varies depending upon the particular exemption that anemployer is looking to apply The most common exemptions include the executive administrative andprofessional exemptions

The professional exemption is often particularly relevant in the home care context Employees may qualifyfor the professional exemption if in addition to being paid a salary as described above their primary duty isthe performance of work requiring advanced knowledge that involves the exercise of discretion andjudgment The advanced knowledge must be in a field of science or learning and must be customarilyacquired by a prolonged course of specialized intellectual instruction

Physicians typically qualify for this exemption So do some Registered Nurses (RNs) Licensed PracticalNurses (LPNs) Certified Nurse Assistant (CNAs) and other similar employees on the other hand typicallydo not qualify

Some other exemptions relevant to the home care industry do not have a ldquosalary basisrdquo test Take thecompanionship exemption for example which applies to individuals who provide companionship services to

15


a person who requires assistance caring for themselves This exemption upon which many employers rely hasbeen narrowed considerably in recent years

Specifically the type of work that qualifies as ldquocompanionship servicesrdquo has been refined to expressly excludeldquohousehold workrdquo that benefits any other members of the household aside from the person who needsassistance caring for themselves In addition third-party employers are no longer permitted to claim thisexemption as HCA has extensively reported

It is important to note however that exemptions are analyzed on a case-by-case basis depending on the uniquefacts of each employeersquos particular situation Employers should be wary of making assumptions or applyinggeneral rules in lieu of conducting a thorough individualized analysis

There is more to classifying employees as exempt than simply paying them a qualifying salary In additionemployers must ensure that the employeersquos primary duties satisfy one of the specifically defined exemptionsavailable under the law Each employeersquos situation is unique and onersquos duties should be closely scrutinizedbefore making a decision to classify the employee as exempt

LawTalk is a monthly series of articles prepared by attorneys at the firm for HCArsquos counsel Please note that HCALawTalk articles are for general informational purposes are not legal ldquoadvicerdquo and do not create an attorney-client relationship Because each case is unique the information provided should be considered to be general innature and should never be considered a substitution for legal counsel Readers should not take or refrain fromtaking any action based on information in this article without first seeking legal advice from competentcounsel

RWJF Grant Opportunity

The Robert Wood Johnson Foundation (RWJF) has issued a Request for Proposals for research that supports newscientific evidence on ways to optimize delivery and financing systems in order to improve health and reduceinequities

Under its Systems for Action (S4A) RWJF aims to apply new evidence about ways of aligning the delivery andfinancing systems for medical social and public health services that support a Culture of Health

In 2018 the program will award up to six grants of up to $250000 over four years

To be eligible applicants must either be a public entity or a nonprofit organization in the US that is tax-exemptunder Section 501(c)(3) of the Internal Revenue Code Multi-organization consortia are encouraged to apply aslong as a single eligible organization is designated as the primary applicant

Letters of Intent must be received no later than September 12 2018 Upon review selected applicants will beinvited to submit a full proposal by October 10 2018

More information and the complete RFP are at httpswwwrwjforgenlibraryfunding-opportunities2018systems-for-actionmdashsystems-and-services-research-to-build-a-culhtml

16


Upcoming Deadlines

RequirementChange EffectiveDue Date More Information

Transition Period for using Health Insurance

Claim Number (HICN) or new Medicare

Beneficiary Identifier (MBI)

April 1 2018 to

December 31 2019

httpswwwcmsgovMedicareNew

Medicare Cardindexhtml

Wage Parity Certification Forms due for

LHCSAs and Fiscal Intermediaries in NYC

Long Island and Westchester

September 1 2018httpswwwhealthnygovhealth_careme

dicaidredesignmrt_61htm

Deadline for NYC employers to post sexual

harassment poster and give new employers

related fact sheet

September 6 2018

httpswww1nycgovassetscchrdownloa

dspdfmaterialsSexHarass_Notice

85x11pdf


dspdfmaterialsSexHarass_Factsheetpdf

2019 hospice minimum wage survey due September 19 2018httpswwwsurveygizmocoms34543360

Minimum Wage Survey Hospice 2019

2019 Assisted Living Program minimum

wage survey dueSeptember 19 2018

httpswwwsurveygizmocoms34543570

Minimum Wage Survey ALP 2019

MLTCLHCSA contract limits go into effect October 1 2018

Emergency Preparedness Interoperable

Communications DrillOctober 9 2018 See article in this weekrsquos newsletter

All NY employers are required to adopt

sexual harassment prevention policies and

provide annual training

Effective October 9

2018

wwwlabornygov

httpswww1nycgovsitecchrindexpage

LHCSA proposed public need methodologyComments due

October 12 2018

httpshca nysorgwp

contentuploads2018079594a968 7de4

4c67 b52d 62fa0234c9cbpdf

2017 LHCSA Statistical Report due November 16 2018httpscommercehealthstatenyuspublic

hcs_loginhtml

MLTC enrollment lock in starts December 1 2018

httpswwwhealthnygovhealth_careme

dicaidprogramupdate20182018

06htmmltc

17


Update Provided on Changes in SPAs and Section 1915 Waiver Review Process

On August 16 the US Centers for Medicare and Medicaid Services (CMS) provided an update on recentchanges to the State Plan Amendment (SPA) and Section 1915 Waiver review processes

At the end of 2017 CMS issued a bulletin (see httpswwwmedicaidgovfederal-policy-guidancedownloadscib110617-2pdf) announcing an initiative to revamp these processes highlighting four specificimprovements 1) a call with states within 15 days of receipt of each submission to review the statersquos requestand any critical timelines to help expedite the review process 2) launch of new tools available to states tofacilitate the development of complete submissions 3) implementation of a strategy to reduce a significantbacklog of state requests and 4) expanding the use of MACPro a web-based system for processingrequests

On August 16 CMS issued a new bulletin with updates and additional changes under consideration for thisprocess (see httpswwwmedicaidgovfederal-policy-guidancedownloadscib081618pdf)

In June CMS established a new triaging protocol that will determine the path that SPAs and 1915 waivers willfollow from submission to adjudication The protocol includes three potential paths that a SPA or 1915 waivercan follow ndash expedited escalation and standard review paths

CMS is also implementing new procedures to prevent a future backlog of amendments on Requests forAdditional Information (RAIs)

CMS Releases Guidance on Medicaid Section 1115 Waiver Demonstrations

The US Centers for Medicare and Medicaid Services (CMS) released a letter to State Medicaid Directors thatdescribes CMSrsquos current approach to calculating budget neutrality expenditure limits for Medicaid section1115(a) demonstration projects

The letter is at httpswwwmedicaidgovFederal-Policy-GuidancedownloadsSMD18009pdf

The letter also outlines recent changes that CMS made in its approach to budget neutrality for demonstrationproject extensions in order to ldquostrengthen fiscal accountability and prevent the federal governmentrsquosexposure to excessive expenditures under section 1115(a) demonstrationsrdquo

Lastly the letter also announces a new monitoring tool to support a more streamlined and standardizedapproach to expenditure reporting for Medicaid demonstrations

These waivers are important for providers because they are the means that many states take to providingenhanced long-term services and supports New Yorkrsquos managed long term care program is authorized underan 1115 waiver

18



NYSE-CON Changes Made

The state Department of Health (DOH) has announced upgrades to the New York State Electronic Certificateof Need (NYSE-CON) application system

These changes include a redesign of the application submission for streamlined navigation improvedlayouts and on-screen instructions A new Sites Tab automatically populates currently certified beds andservices while more clearly indicating which sites are part of the application submission

Training Guides for the Application Submission process and Sites Tab will be at httpswwwhealthnygovfacilitiesconsnysecontraining

DOH Posts Regulatory Agenda

The state Department of Health (DOH) has posted regulatory actions that are under consideration forproposals this year Not all of these listed items will actually materialize into formal regulatory proposals thisyear but are listed as on DOHrsquos radar Should formal regulation follow HCA will be engaged in the reviewand advocacy process

The information is at httpsdocsdosnygovinforegister2018august29regulatorypdf

Some areas of interest include

Amend the regulation to update the need methodology used to estimate the need for Certified HomeHealth Agencies (CHHAs)

Amend the regulation to allow for minimum wage costs for CHHAs

Amend the regulation to update the need methodology used to estimate the need for hospice careand services

Amend the regulation to allow for added costs due to the increases in minimum wage for personalcare services

Add or amend regulations to set forth the requirements for the Community First Choice Option (CFCO)

Providers Reminded About Medicaid Revalidation

All Medicaid providers are required to revalidate their enrollment in the program every five years

The state Department of Health (DOH) Bureau of Provider Enrollment has sent providers initial and finalrevalidation letters to their correspondence address informing them of the revalidation requirementHowever some providers who were sent revalidation letters have not responded To promote providercompliance the Bureau has sent out a final revalidation letter

Providers who do not revalidate will receive a termination letter and will be terminated



19


Terminated providers will not be able to participate in Medicaid Managed Care (MMC) networks andChildrenrsquos Health Insurance Program (CHIP) in addition to being unable to bill for fee-for-service (FFS)Medicaid

Additionally future revalidation notification letters will be automatically sent to providers An initial letter willbe sent out and if after 90 days the provider has not responded a second and final letter will be sent outProviders who do not revalidate within 45 days of the final letter will receive a termination letter

DOH encourages providers to maintain their correspondence address to ensure the letters are sent to thecorrect address More information on revalidation is at httpswwwemednyorginfoProviderEnrollmentrevalidationindexaspx

If you have any questions about the revalidation process or maintaining your provider file please visitwwweMedNYorg contact the eMedNY Call Center at 1-800-343-9000 or e-mail providerenrollmenthealthnygov

HEPC Meetings Scheduled for FallNote date changes

HCA encourages members and non-member home care and hospice providers and managed care plans to getinvolved with their local Health Emergency Preparedness Coalitions (HEPCs)

HEPCs are coalitions of health care providers local and state emergency management and local public healthpreparedness officials that develop and coordinate emergency preparedness across the continuum includingreadiness among individual health sectors holding exercises and lsquohotwashesrsquo conducting hazard andvulnerability assessments and other important activities

The following are upcoming HEPC meetings note that some dates have changed since last reported in theAugust 20 Situation Report

Those interested in participating should contact Andrew Koski at akoskihcanysorg

HEPC Meetings

Western New York ndash September 12 2018Finger Lakes ndash September 17 2018Central New York (first quarter meeting) ndash September 20 2018Long Island ndash September 25 2018 (NEW DATE)Capital District ndash September 25 2018Lower Hudson Valley ndash September 26 2018 (NEW DATE)North Country ndash September 27 2018Bronx ndash October 2 2018Western Region ndash October 15 2018North Country ndash November 26 2018Capital District ndash December 4 2018 (NEW DATE)Finger Lakes ndash December 17 2018

20



HCA and the New York State Association of Health Care Providers (HCP) work with all home care and hospiceproviders to support their roles in emergency preparedness under a grant from the state Department ofHealth Office of Emergency Preparedness This includes participating in HEPC meetings across the state

Providers and plans are also advised to review the Aware Prepare Update an excellent resource of upcomingpreparedness trainings It is at httpswwwurmcrochestereduemergency-preparednesstrainingaspx

Health Resources

ldquoExploring the Growth of Medicaid Managed Carerdquo by the Congressional Budget Officehttpswwwcbogovsystemfilesfile=2018-0854235-MMC_chartbookpdf

ldquoRecent and Upcoming Improvements In Hospice Billing and Claims Processingrdquo by the US Centersfor Medicare and Medicaid ServiceshttpswwwcmsgovOutreach-and-EducationMedicare-earning-Network-MLNMLNMattersArticlesdownloadsSE18007pdf

ldquoFunctional Need and Frailty in the New York State Managed Long-Term Care Populationrdquo by thestate Department of Healthhttpswwwhealthnygovhealth_caremanaged_caremltcdocsstatistical_brief_2pdf

ldquoImproving Care and Lowering Costs for Chronic Care Beneficiaries Implementing theBipartisan Budget Actrdquo by the Bipartisan Policy Centerhttpsbipartisanpolicyorgwp-contentuploads201808Improving-Care-and-Lowering-Costs-for-Chronic-Care-Beneficiaries-Implementing-the-Bipartisan-Budget-Actpdfpage=8

ldquoWhere to Apply for Medicaid and Medicaid Home Care in New York Cityrdquo by the New York LegalAssistance Grouphttpwwwwnylccomhealthprint79

ldquoMedicaid Eligibility Verification System (MEVS) and Dispensing Validation System (DVS) ProviderManualrdquo (August 2018 update) by eMedNYhttpswwwemednyorgProviderManualsAllProviderssupplementalaspx

ldquoInfluenza Vaccine Payment Allowances mdash Annual Update for 2018-2019 Seasonrdquo by the US Centersfor Medicare and Medicaid ServiceshttpswwwcmsgovRegulations-and-GuidanceGuidanceTransmittals2018DownloadsR4124CPpdf

ldquoPrevalence of Disabilities and Health Care Access by Disability Status and Type Among Adults mdashUnited States 2016rdquo by the Centers for Disease Control and Preventionhttpswwwcdcgovmmwrvolumes67wrmm6732a3htms_cid=mm6732a3_w

For more information contact Andrew Koski at akoskihcanysorg or (518) 810-0662

2

The Situation Report is a weeklypublication of the Home CareAssociation of New York State(HCA) Unless otherwisenoted all articles appearingin The Situation Report are theproperty of the Home CareAssociation of New YorkState Reuse of any contentwithin this newsletterrequires permission fromHCA

Al CardilloActing President

acardillohcanysorg

Roger L NoyesDirector of CommunicationsEditor of The Situation Report

rnoyeshcanysorg

Patrick ConoleVice President

Finance amp Managementpconolehcanysorg

Andrew KoskiVice President

Program Policy amp Servicesakoskihcanysorg

Laura Constable Senior Director

Membership amp Operationslconstablehcanysorg

Celisia StreetDirector of Education

cstreethcanysorg

Mercedes Teague Finance Manager

mteaguehcanysorg

Jenny KerbeinDirector of Governance amp

Graphic Designjkerbeinhcanysorg

Billi Wilson Manager Meetings amp Events

bwilsonhcanysorg

Teresa BrownAdministrative Assistant

tbrownhcanysorg

Home Care Association of New York State (HCA)388 Broadway 4th Floor Albany NY 12207

Tele 518-426-8764 Fax 518-426-8788 Website wwwhcanysorg


RULE from p 1

underlying problems with the negative behavioral adjustmentthat CMS assumes the need for adequate time so thatproviders can implement such a massive payment changeand the fact that over 50 percent of home health patientswould fall into the Medication Management Teaching andAssessment (MMTA) clinical diagnosis

The current face-to-face (F2F) requirement remains an undueburden for home health agencies and physicians alike withlittle justification in terms of payment integrity or effectiveeligibility oversight and needs to be revised

Congressrsquos decision and CMSrsquos proposed phase-out of thehome health rural add-on between CY 2019 and 2022 Theadd-on should be restored and CMS should monitor theimpact of its tiered approach that treats different ruralcounties in a disparate manner

Enduring concerns with CMSrsquos proposed wage index and theneed for it to more accurately reflect local market conditions

The need for CMS to provide further analysis of the number ofagencies affected by the OASIS submission and pay-for-reporting thresholds and penalties

Ongoing concerns with CMSrsquos value-based purchasingdemonstration project the home infusion therapy proposal andthe lack of funding for Health Information TechnologyExchange

For each area of concern HCA offers specific comments orrecommendations HCArsquos comments are at httpshca-nysorgwp-contentuploads201809HCA_CY2019HHPPS_ProposedRuleComments_083018pdf

A final rule is anticipated by November 2018 with the 2019 HHPPSgoing into effect on January 1 2019

To learn more about the impact of the rule members should be sureto attend HCArsquos Senior and Financial Managerrsquos Retreat later thisweek on September 6 and 7 at the Mohonk Mountain House Resortin New Paltz Colin Roskey Partner at Scully Roskey amp Missmar willdevote much of his presentation to this topic along with otherfederal policy updates

For more information please contact Patrick Conole at (518) 810-0661 or pconolehcanysorg

3













FRAMES from p 1


4











5
















Network adequacy



6

Compliance by plans



















7














8





HIRING









9
















10



11





12











13













14











15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














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19











HEPC Meetings


20





Health Resources










3













FRAMES from p 1


4











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6

Compliance by plans



















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8





HIRING









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13













14











15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














18






















19











HEPC Meetings


20





Health Resources











4











5
















Network adequacy



6

Compliance by plans



















7














8





HIRING









9
















10



11





12











13













14











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16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














18






















19











HEPC Meetings


20





Health Resources











5
















Network adequacy



6

Compliance by plans



















7














8





HIRING









9
















10



11





12











13













14











15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














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19











HEPC Meetings


20





Health Resources











6

Compliance by plans



















7














8





HIRING









9
















10



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12











13













14











15














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Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














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HEPC Meetings


20





Health Resources











7














8





HIRING









9
















10



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12











13













14











15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














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HEPC Meetings


20





Health Resources











8





HIRING









9
















10



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12











13













14











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16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














18






















19











HEPC Meetings


20





Health Resources











9
















10



11





12











13













14











15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














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HEPC Meetings


20





Health Resources











10



11





12











13













14











15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














18






















19











HEPC Meetings


20





Health Resources










11





12











13













14











15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














18






















19











HEPC Meetings


20





Health Resources











12











13













14











15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














18






















19











HEPC Meetings


20





Health Resources











13













14











15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














18






















19











HEPC Meetings


20





Health Resources











14











15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














18






















19











HEPC Meetings


20





Health Resources










15














16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














18






















19











HEPC Meetings


20





Health Resources










16


Upcoming Deadlines





April 1 2018 to

December 31 2019










related fact sheet

September 6 2018



85x11pdf















Effective October 9

2018

wwwlabornygov



October 12 2018

httpshca nysorgwp




hcs_loginhtml




06htmmltc

17














18






















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HEPC Meetings


20





Health Resources










17














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HEPC Meetings


20





Health Resources










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HEPC Meetings


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Health Resources












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Health Resources










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Health Resources








