QIPP Update

On April 12, 2017, HHSC received approval from the Centers for Medicare & Medicaid Services to proceed with QIPP for FY 2017-2018.

The Quality Incentive Payment Program (QIPP) encourages nursing facilities to improve the quality and innovation of their services, using the Centers for Medicare & Medicaid (CMS) 5-star rating system as its measure of success for the following 4 quality measures:

  • High-risk long-stay residents with pressure ulcers
  • Percent of residents who received an antipsychotic medication (long-stay)
  • Residents experiencing one or more falls with major injury
  • Residents who were physically restrained

Background

During the 83rd Legislative Session, the Texas Legislature outlined its goals for adding managed care to nursing facilities. The Texas Health and Human Services Commission (HHSC) was directed to encourage transformative efforts in the delivery of nursing facility services, including "efforts to promote a resident-centered care culture through facility design and services provided."

In 2014, HHSC established the Minimum Payment Amount Program (MPAP), which became effective in 2015. MPAP establishes minimum payment amounts for qualified nursing facilities in STAR+PLUS. The STAR+PLUS managed care organizations pay the minimum payment amounts to qualified nursing facilities based on state direction. The program was intended to be a short-term program that would ultimately transition to a performance-based initiative.

HHSC Budget Rider 97 in the 2016-2017 budget (PDF) directs HHSC to transition the Minimum Payment Amount Program to the Quality Incentive Payment Program.

Eligibility

QIPP is open to 2 classes of facilities:

  • Non-state government owned nursing facilities
  • Private nursing facilities

Moving from private to public ownership as part of QIPP

A nursing facility interested in pursuing a change of ownership (CHOW) from private to public ownership, as a part of obtaining QIPP funds, must submit:

  • A CHOW application to DADS no later than March 2, 2017. 
  • All required documentation pertaining to the CHOW by March 31, 2017.

For information related to the CHOW requirements, visit the How to Become a Nursing Facility Provider page.

How the eligibility cut-off is determined

Private nursing facilities interested in participating in QIPP must have a percentage of Medicaid nursing facility days of service greater than or equal to the private nursing facility QIPP eligibility cut-off point. The private nursing facility QIPP eligibility period cut-off point is 77.89% for the first year, based on the 2014 cost report.
(The cut-off is equal to the mean percentage of historical Medicaid nursing facility days of service provided under fee-for-service and managed care by all private nursing facilities plus one standard deviation, as determined by HHSC.)
For each private nursing facility, the percentage of Medicaid nursing facility days is calculated by summing the nursing  Medicaid NF fee-for-service and MC days of service and dividing that sum by the NF's total days of service in all licensed beds. Medicaid hospice days of service are included in the denominator but excluded from the numerator.

Data sources

Data sources for the determination of each private NF's QIPP eligibility status are listed in priority order below:

  • The most recently available, audited Medicaid NF cost report for the private NF;
  • The most recently available, audited Medicaid Direct Care Staff Rate Staffing and Compensation Report for the private NF;
  • The most recently available, audited Medicaid NF cost report for the immediately prior owner of the private NF; and
  • The most recently available, audited Medicaid Direct Care Staff Rate Staffing and Compensation Report for the immediately prior owner of the private NF.

If none of these data sources are available, the private NF is not eligible for participation in QIPP.

Timeline for Implementation

  • Jan. 2017: Proposed rule (s) available in the Texas Register for Public Comment
  • Jan. 30, 2017: Stakeholder Meeting for QIPP
  • Feb. 2017: Public comment period ends
  • March 2, 2017: CHOWS due to the Texas Department of Aging and Disability Services
  • March 31, 2017: Last day to submit required CHOW documentation to DADS
  • April 2017
    • Adopted rule(s) published in the Texas Register
    • Rule(s) effective date
  • Spring 2017: Applications received from facilities wishing to participate in QIPP
  • Sept. 1, 2017: QIPP Implementation

Communications

Resources

Contact Information

If you have questions for HHSC, please use this email address: QIPP@hhsc.state.tx.us

Managed Care Organization Contacts
MCO Name Email Phone
Amerigroup Jessica McFarlin TXQIPP@amerigroup.com 817-456-6720
United Marianne Hanley, Director of Network Strategy and Business Development marianne.hanley@optum.com 972-372-5665
Superior Paula Swenson, VP, Provider Performance paula.swenson@superiorhealthplan.com 512-993-2492
Molina Bob Kalin, VP, Long Term Care Operations Robert.Kalin@Molinahealthcare.com 281-676-2269
Cigna-HealthSpring Maggie McDowell, Director of Quality maggie.mcdowell@healthspring.com 817-554-5552

QIPP Q&A

Can a facility participate in QIPP if they do not have a 2014 cost report?

The draft rules propose that new NFs, not NFs that have recently changed ownership, with no cost report data cannot participate in QIPP. The NF would have to wait until HHS has good cost report data.

Where do we get an application to enroll in QIPP?

The application period for QIPP is not currently open. Once it is, information will be placed on the QIPP website.

How is the baseline determined?

The baseline will be an NF-specific average of the previous 4 quarters of published CMS data, before the start of the QIPP program. This number will remain the same for the entire year; however, each NFs baseline may change before the start of each new QIPP year.

What is the benchmark for each QM that my NF will be measured against?

The benchmark for each QM that all NFs will be measure against is the most recent CMS-published national percentage.

When is the effective date for changes of ownership for nursing facilities that want to participate in QIPP?

April 1, 2017, or earlier.

Does the percentage payout occur monthly or quarterly?

Quarterly

Will NFs participating in QIPP need to contract with 1 MCO or several MCOs?

NFs should contract with all of the MCOs in their service delivery area.

What is the percentage payout for improvements that are made to the quality measures?

Component 2 - Minimum Improvement

  • The maximum amount of funds available is recalculated every 6 months.
    • Allocation of funds across qualifying non-state government-owned and private nursing facilities will be based upon historical Medicaid days of nursing facility service.
    • A quarterly target for improvement for each measure is met (see table below) starting with 1.7 percent in the first quarter and increasing quarterly to 7 percent by the fourth quarter.
    • The total value of Component 2 will be equal to 35 percent of remaining QIPP funds after accounting for the funding of Component 1.
    • Quarterly payments to nursing facilities will be triggered by improvement on specific indicators.
Component 2 quarterly target for improvement
Quarter Total Improvement from Baseline
1 1.7%
2 3.4%
3 5.1%
4 7%

Component 3 - Strong Improvement

  • The maximum amount of funds available is recalculated every 6 months.
    • The total value of Component 3 will be equal to 65 percent of remaining QIPP funds after accounting for the funding of Component 1.
    • Allocation of funds across qualifying non-state government-owned and private nursing facilities will be based upon historical Medicaid days of nursing facility service.
    • A quarterly target for improvement for each measure is met (see table below) starting with 5 percent in the first quarter and increasing quarterly to 20 percent by the fourth quarter.
    • Quarterly payments to nursing facilities will be triggered by meeting these goals.
Component 3 quarterly target for improvement
Quarter Total Improvement from Baseline
1 5%
2 10%
3 15%
4 20%

In the calculation for a facility’s Medicaid days, why are Medicaid hospice days not included in the numerator?

Because Medicaid hospice services are not covered under Medicaid managed care, HHSC has determined it would be inappropriate to include them in the calculation of the private nursing facility qualification percentages. Medicaid hospice is not included in the numerator for the calculation of the Medicaid percentage achievement for the individual private provider or in the numerator for the calculation of the Medicaid percentage achievement cut-off point for private providers as whole. If it were to be included in both of these calculations, the cut-off point would increase and achievement levels would increase for NFs providing Medicaid hospice services.

Will your MCO work with NFs to coordinate MCO and CHOW contract effective dates?

Amerigroup Cigna Molina Superior United
Yes Yes, but Cigna HealthSpring encourages NFs or SNFs undergoing a CHOW to notify CHS immediately following DADS approval of the CHOW. Yes

Superior will collaborate with the NF for contract effective dates following notification of DADS receipt of a CHOW application and subsequent confirmation of new ownership licensure.

Yes

Will your MCO reimburse claims submitted by new NF owners at the in-network rate, while new contracts are being established? 

All MCOs have agreed to retroactively pay NF providers undergoing a CHOW at the network rate back to the CHOW effective date.

News

February 10, 2017

For all private nursing facilities, the eligibility list is now available on the QIPP Website. If you are interested in participating in the QIPP, please review this list to determine your eligibility.