VHCA-VCAL submitted comments to the Department of Medical Assistance Services (DMAS) as the agency requested comments in advance of potential revisions to the CCC Plus contract.  VHCA-VCAL offered detailed recommendations on issues ranging from the use of the Uniform Assessment Instrument (UAI)/screening requirements, continuity of care, guaranteed payment for non-networked CCRC nursing facility level care, and other payment issues.

The current CCC Plus contract period runs from January 1 – December 31 and is renewed annually. DMAS solicits stakeholder comments on potential contract revisions at each contract renewal. This year the agency elected to execute a mid-year contract amendment of the 2018 contract. DMAS expects to complete the revision process and post the revised contract to its website by mid-June for a July 1 effective date. 

VHCA-VCAL’s comments included the following points:

• Section 4.7.1 Screening Requirements: VHCA-VCAL offered detailed comments on the use of UAIs and efforts to verify that hospital screening teams are completing UAIs in a timely way for all relevant discharges to nursing care prior to or concurrent with discharge. We also requested that DMAS articulate a date certain (no earlier than 10/1/18, and potentially with the next contract revision on 1/1/19) that the UAI nursing center payment requirement will be re-invoked. VHCA-VCAL requested that DMAS convene the stakeholders (hospitals, nursing centers, and managed care organizations (MCOs)) to work through any remaining issues so that a consistent understanding of responsibilities and timelines can be reached.

• Section 5.14.1 General Provisions: We reiterated previously voiced concerns about how the continuity of care provisions may affect a resident’s access to ancillary providers.

• Section 5.14.3 Members in Nursing Facilities: VHCA-VCAL expressed concern that the language in the contract regarding guaranteed payment for non-networked CCRC nursing facility level care could be clearer to require the MCO to pay the appropriate fee-for-service rate in the event of continued non-par status.

• Section 12.4.2 Exceptional…Payment Rules for Nursing Facility…: VHCA-VCAL suggested language to make the contract more explicit on minimum payment and alternative arrangements for specialized care facilities.

Click here to read VHCA-VCAL’s comment in their entirety.