Chapter 257 of the Acts of 2008 Provider Engagement Session: DYS Capacity Building January 3, 2013 www.mass.gov/hhs/chapter257 email@example.com
Chapter 257 of the Acts of 2008 Regulates Pricing for the POS System • Chapter 257 places authority for determination of Purchase of Service reimbursement rates with the Secretary Of Health and Human Services under MGL 118G. The Division of Health Care Finance and Policy provides staffing and support for the development of Chapter 257 pricing. • Chapter 257 requires that the following criteria be considered when setting and reviewing human service reimbursement rates: • Reasonable costs incurred by efficiently and economically operated providers • Reasonable costs to providers of any existing or new governmental mandate • Changes in costs associated with the delivery of services (e.g. inflation) • Substantial geographical differences in the costs of service delivery • Many current rates within the POS system may not reflect consideration of these factors. • Chapter 9 of the Acts of 2011 establishes new deadlines for implementing POS rate regulation as well as requires that related procurements not go forward until after the rate setting process is completed.
The Cost Analysis and Rate Setting Effort has Several Objectives and Challenges Objectives and Benefits Development of uniform analysis for standard pricing of common services Rate setting under Chapter 257 will enable: Predictable, reimbursement models that reduce unexplainable variation in rates among comparable, economically operated providers Incorporation of inflation adjusted prospective pricing methodologies Standard and regulated approach to assessing the impact of new service requirements into reimbursement rates Transition from “cost reimbursement” to “unit rate” Challenges Ambitious implementation timeline Data availability and integrity (complete/correct) Unexplained historical variation in reimbursement rates resulting from long-term contracts and individual negotiations between purchasers and providers Constrained financial resources for implementation, especially where pricing analysis warrants overall increases in reimbursement rates Cross system collaboration and communication Coordination of procurement with rate development activities Pricing Analysis, Rate Development, Approval, and Hearing Process Data Sources Identified or Developed Provider Consultation Cost Analysis & Rate Methods Development Provider Consultation Review/ Approval: Departments, Secretariat, and Admin & Finance Public Comment and Hearing Possible Revision / Promulgation
Agenda • Service Class Overview • Services • Procurement Plan • Similarities among Short- and Intermediate- Term Residential Programs • Proposed titles and definitions • Implementation • Next Steps & Logistics
DYS Capacity Building Services & Procurement Plan • Service Class Definition:Programs that support providers or agencies in order to facilitate or enhance services delivered to individuals or families. This may include, but is not limited to, staff augmentation, staff education and training, infrastructure and administrative support, technical assistance, and material goods. • These supportive positions provide services within DYS residential facilities for youth in the Department’s care. These staff members supplement staff in state programs. • Staff positions range from clinicians to direct care and varying levels of support staff. • Procurement Plan: • Once rates are approved, DYS will issue a procurement and new contracts will be issued. • Contracts will be multi year rate agreements.
DYS Capacity Building: Data Sources The rate development for DYS Capacity Building services considers: Benchmarks used in the development of short and intermediate services FY11 contracts for DYS capacity building services Benchmarks from market sources: Bureau of Labor Statistics Each proposed rate includes: Data-informed salary levels Tax and fringe Relief where applicable Cost adjustment factor (CAF) Overhead
DYS Capacity Building: Similarities with Short- and Intermediate- Term Residential Programs • The Department of Youth Services utilizes these capacity building positions to supplement their Short- and Intermediate- Term Residential Programs • DYS, CHIA and EOHHS engaged in extensive rate setting processes to determine the salary levels and position titles essential to provide services to youth in the care and custody of the Department. • Positions for this capacity building service class are in many ways the same positions as are included in the provider-run programs. Examples include: • Clinical Director & Clinician • Direct Care • Support Staffing (cook, maintenance, and clerical) • Staffing positions that were not considered in the previous rate setting projects but are up for consideration within this capacity building rate development include: • Transporter • Skilled maintenance • Security
Proposed Titles and Definitions • Clinician: An individual who provides social work services. License requirements are under review. • Clinical Director: An individual who is hired to manage clinical staff and who provides social work services. The Clinical Director is also a member of the program Administration Team and provides clinical supervision, training and manages a case load for individual treatment. License requirements are under review. • Direct Care: Staff who are responsible for the general daily care of program clients/service recipients or for primary program service delivery.
Proposed Titles and Definitions (Cont’d) • Program Support: Program housekeeping, maintenance and janitorial staff, ground keepers, drivers or cooks and staff who carry out direct program activities for client health and safety. • Cook: entry level position performing general food service tasks. Does not generally work independently. • Maintenance: Staff who provide general maintenance and repair services, and skilled workers who are licensed. General staff do not work independently, but skilled staff must be able to work independently. • Transporter: Skilled worker who transports youth to and from courts and appointments. Must be able to manage responsibilities and work independently. • Secretarial/Clerical: provides a variety of clerical and organizational takes that are necessary to run an organization efficiently. Does not generally work independently. • Security: Skilled worker who performs maintains security in a facility. Must be able to manage responsibilities and work independently. • Office Coordinator: Highly skilled office workers, preferably with a college degree. Must be able to work independently
Implementation of Capacity Building Rates • DYS, along with CHIA and EOHHS, are working to expedite the rate setting process to have final rates approved by early Spring 2013- contingent upon completion of rate setting and approval process. • All Chapter 257 rates are subject to the public hearing process. • Provider and stakeholder feedback is welcome and encouraged throughout the rate setting process, as well as, the public hearing period. • The proposed Capacity Building rates will be on a unit basis; cost reimbursement contracts will no longer be utilized to finance these services. • Proposed unit rates under development are per diems for each Capacity Building staff position • DYS plans to work alongside providers to develop the most efficient and appropriate billing process.
Next Steps & Logistics • DYS, CHIA and EOHHS will continue to refine these capacity building rates. • A public hearing will be scheduled upon rate proposal. • DYS will release an RFR upon final adoption of rates. • Further comments and questions can be sent to: EOHHSPOSPolicyOffice@ehs.state.ma.us