Waiver FAQ

 Waiver FAQ

Date posted:

Requestor:

 Region 10

Question:

What guidance, if any, can be provided for a provider with a “needs assessment” or “gap analysis” milestone provide in terms of information or documentation for proof of milestone completion for reporting purposes?

Response:

 For the needs assessment, we leave it up to the providers to create a documented needs assessment which addresses what the needs are, how they will be addressed through the project, and impact to Medicaid/low income uninsured, generally answering why the project is needed.

 Waiver FAQ

Date posted:

Requestor:

THR 

Question:

A provider has asked for clarification if “billing should occur as normal” for patients who encounter a DSRIP project.  They stated that a comment was made about this on the webinar last week, however that recording is not yet available on the HHSC website. 

Response:

Yes, the provider can still bill for patients that are in a DSRIP project (e.g. Medicaid or insurance)

 Waiver FAQ

Date posted:

Requestor:

 UNTHSC

Question:

Can any non-urgent care clinic be a Continuity Clinic or is there a classification or list of Continuity Clinics by RHP? 

Response:

Yes, any non-urgent care clinic can be counted.

 Waiver FAQ

Date posted:

Requestor:

 UNTHSC

Question:

Can a primary care physician qualify as a “primary care trainee” or do we only count residents?

Response:

A primary care physician can qualify as a trainee if they have received training as a part of your project.

 Waiver FAQ

Date posted:

June 24, 2013

Requestor:

THR

Question:

Response:

The state is working to refine the anticipated cost of the monitoring to be performed for the 1115 Waiver.  The proposed rule states it will be no more than 1% of the IGT, but it may be less.  If the state determines that the non-federal cost of the monitoring contract(s) will only cost .5% of the DSRIP projects’ IGT amounts, then the state only will collect .5%.  To the extent possible, the state will attempt not to collect more from the IGT entities than is required for the monitoring.  If too much is collected, unused IGT funds will be returned

Waiver FAQ

Date posted:

June 15, 2013

Requestor:

THR

Question:

Response:

Providers can determine an annual date range for pulling baselines that does not correspond with the federal fiscal year (e.g., calendar year, state fiscal year, or other). The provider just needs to stay consistent and use the same date range used to establish the baseline. We will be working on the process to notify regions when projects have been formally submitted to CMS.

Waiver FAQ

Date posted:

June 15, 2013

Requestor:

Baylor

Question:

Response:

Use origional numbers

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

Region 10

Question:

Response:

No, the new outcome should not be valued at $0. The provider needs to split Category 3 value between patient satisfaction and the new outcome. HHSC recommends that the provider keep patient satisfaction value below 50% of the total Category 3 value.

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

Region 10

Question:

Response:

July.

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

Region 10

Question:

Response:

Yes, they should continue highlighting and striking through information to identify changes.

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

UNTHSC

Question:

Response:

Yes, they should continue highlighting and striking through information to identify changes.

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

Region 10

Question:

Response:

This is an indicator if any of the DY2-5 milestones didn’t add up but we only included DY2 for Phase 3. In most cases, for DY2, HHSC updated the milestone values to the correct equal amount in this Excel file but you can check if we may have missed some.

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

Region 10

Question:

Response:

The provider can leave Cat2 project value unchanged and split Cat 3 value between old and new outcomes. If for some reason this approach does not work and the provider needs to move some funds from Cat 2 – please provide additional information explaining the reason and we can discuss this further.
 

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

MHMR Tarrant County

Question:

If a provider is accepting the lower alternate value for a project (Phase 1 decision) should they change the dollar value per milestone/ metric in the Phase 3 Provider Correction template?

Response:

No, they do not need to this. HHSC will update this once we receive all cover sheets by Friday, June 7^th. You can note in the “Provider Change Comment” that the provider will or will not be accepting the lower value.

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

Region 10

Question:

If Metric Provider Manual Desc (if needed) is blank – does this need to be filled in by the provider?

Response:

“Provider Manual Desc (if needed)” refers to when a provider didn’t use the same language from the RHP Planning Protocol in their milestones and metrics table. If they used the language from the menu, it would be in the column immediately preceding it “Metric Description”. The provider would only need to enter something if they used different language from the menu and it’s not showing up in the “Provider Manual Desc” column.

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

Region 10

Question:

If a Metric #__ Data Source (DY2) is blank or says ‘0’ does the provider need to fill this in?

Response:

As long as the provider has something in the “Metric #X Data Source (DY2)” column or the “Data Source Provider Manual Desc (if needed)” column which is similar to what’s mentioned above (i.e. provider used something other than the data source listed in the menu), then they don’t need to fill it in. If both are blank, then the provider should fill in one of the fields.

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

Region 10

Question:

Specifically – for JPS Health Network I have been reviewing projects column by column for Categories 1 &2.  Although no Cat 1 or 2 projects had HHSC comments I have found at least 5 areas where I have seen an XX%, a TBD, or a data source blank à are these items that may have been over looked and need to be corrected on this template per HHSC Phase 3 guidance: Note: Please update any milestone/metric goals that are TBD or non-quantifiable that HHSC may have missed or metrics with missing data sources. August DY 2 DSRIP payments may be impacted if any TBD or non-quantifiable goals were not identified and revised

Response:

Yes, please update any missing/TBD data sources and any TBD or XX% goals that HHSC missed – this will mainly be changing the columns referring to “Metric #X Baseline/Goal (DY2)”, “Metric #X Type”, “Numeric Goal”, “Metric #X Data Source (DY2)” and “Data Source Provider Manual Desc (if needed)”. For Cat 3, it’s ok to have the “Starting Point/Baseline” column be TBD.

Waiver FAQ

Date posted:

June 7, 2013

Requestor:

Region 10

Question:

I have a provider who is concerned with the QPI milestone requirement.  He has a few projects he is reviewing for phase 1 and has put QPI in milestones, but spread over 2-3 milestones in DY4-5 that touch the entire population, he has not included one milestone that references the entire population all together.  He is worried that HHSC/ CMS is looking for one milestone to reflect the entire population, otherwise he will lose value both in this round and phase 2.  Can you please clarify that you are looking for one milestone to reflect the entire project population? Or can the entire population be spread out amongst 2-3 milestones?

Response:

It is preferable if QPI is reflected in one milestone, however this is not necessary. Providers can show their populations in different metrics as long as these are distinct populations. Providers will soon receive the Phase 2 spreadsheets to reflect QPI, and this spreadsheet will give the provider the opportunity to identify the specific QPI target amounts for each project and note if this QPI information comes from more than one milestone.

Waiver FAQ

Date posted:

April 9, 2013

Requestor:

Niki Shah

Question:

How many/much of the DY2 metrics are expected to be attained by the July/August timeframe to receive DY2 funds?

Response:

There is no expectation on how many/ much of the DY2 metrics will be achieved by August 2013.  Payment will only be paid for milestones fully met as described in the “Disbursement of DSRIP funds” in the PFM.

Waiver FAQ

Date posted:

May 24, 2013

Requestor:

Region 10

Question:

What is the process to remove a project that has been approved? Does the process also remove related Category 3 outcomes?   How will providers know what amount of DY1 DSRIP will be recouped if a project is withdrawn?   When projects that have been approved are withdrawn, and not replaced, what is done with the funds for those dollars associated with the projects?

Response:

Please use the HHSC form available on this site. Yes, all related Cat 3 outcomes will also be removed. There is a formula included in the form that the provider can refer to but HHSC will be making the calculation. No, the funds will be available for DY3 plan modifications.

Waiver FAQ

Date posted:

May 24, 2013

Requestor:

Region 10

Question:

In cover sheets, when it says $X over the life of the waiver – does that include DY4-5?  How does that affect the ongoing valuation approval for DY4-5?

Response:

The amount $X over the life of the waiver includes DY4-5, however, HHSC specifies what the amounts are for DY2-3 separately. The provider does not need to accept HHSC suggested valuation for DY4-5, since CMS is going to do this summer all projects’ valuation analysis for DY4-5.

Waiver FAQ

Date posted:

May 24, 2013

Requestor:

Region 10

Question:

If a hospital provider currently has a patient satisfaction outcome, and plans to keep that outcome but also add additional clinical outcomes – they need to complete a brand new Cat 3 narrative and table for these new outcomes, correct? How then should these new outcomes be valued? Should they be a zero dollar value?  Are remaining dollars from a Cat 2 project that may have been lowered to be spread among the new additional two or three Category 3 outcomes instead of the 1 original patient satisfaction proposed?

Response:

No, the new outcome should not be valued at $0. The provider needs to split Category 3 value between patient satisfaction and the new outcome. HHSC recommends that the provider keep patient satisfaction value below 50% of the total Category 3 value

Waiver FAQ

Date posted:

April 9, 2013

Requestor:

Niki Shah

Question:

Are providers beginning to spend money without firm confirmation of project approval? Is this advisable?

Response:

Implementation of projects prior to full approval is at the discretion of each provider.  Providers must decide individually how to balance the risk of implementation prior to approval with the timeline allotted for achieving DY2 milestones. We understand that some providers in the Region have begun to incur DSRIP project expenses.

Waiver FAQ

Date posted:

April 9, 2013

Requestor:

Niki Shah

Question:

Will the DY’s be changed at all to accommodate attaining metrics/milestones in a timely manner?

Response:

Currently there are no plans to change the DYs to attain metrics and milestones.  There is a possibility of reporting dates changing on a rolling timeline based on each region’s full approval of their RHP plan but this decision has not been made.  Reporting dates should be understood as is in the PFM until new information is published by HHSC.

Waiver FAQ

Date posted:

April 8, 2013

Requestor:

Jeanie Foster

Question:

Is it possible for a project to be “initially approved” for DY2 and DY3 funding and never reach full approval for DY4 and DY5 funding?  If so, will DY2 and DY3 funds already distributed for meeting milestones in DY2 and DY3 need to be returned?

Response:

At this time, HHSC has advised DY2 dollars associated with milestone payment will not be recouped.

Waiver FAQ

Date posted:

April 8, 2013

Requestor:

Jeanie Foster

Question:

Originally, providers had until Oct. 1, 2013 to remove a project, if needed.  I do not see that date in the new PFMP.  Section VII, b. on page 35 says that an RHP may request to delete or terminate a project from its RHP plan and forego replacing it but it does not give a deadline.  Does this mean that we could get into DY3 and then drop a project if we realize that we cannot meet the new targets based on CMS’s/HHSC’s methodology for setting standard targets for DY4 and DY5?

Response:

There is no date in the new PFM approved 4/4/13.  HHSC will work with CMS to provide rules and processes regarding the removal of projects and new project planning for DY3.

Waiver FAQ

Date posted:

April 8, 2013

Requestor:

Jeanie Foster

Question:

If a provider removes a project, does the provider refund the funds previously distributed for meeting milestones associated with that project or does the provider just forego future payments?  I know DY1 payments must be refunded if CMS does not approve a project.  But if a project is removed due to the circumstance mentioned in question 2, would a provider refund DY2 or DY3 payments if the milestones were met before the project was removed?

Response:

At this time, HHSC has advised DY2 dollars associated with milestone payment will not be recouped.

Waiver FAQ

Date posted:

April 8, 2013

Requestor:

Jeanie Foster

Question:

It appears that CMS will approve valuations during the DY4 and DY5 approval which is towards the end of DY2.  If there are questions or valuations to be worked out, the approval could be as late as March 31, 2014 (mid- DY3).  Is this correct?  If so, how will CMS know what to pay for DY2 and DY3 milestones?

Response:

If a project receives initial approval with no need for priority technical corrections the project is eligible for DY2 and DY3 payments as is.

If a project requires priority technical corrections, the project will be eligible to earn DY2 payments but technical corrections must be submitted by 9/30/13  with approval no later than 3/31/14 to be eligible to receive DY3 payments.

Waiver FAQ

Date posted:

April 8, 2013

Requestor:

Jeanie Foster

Question:

Along the same lines, since the valuations were based on population and actual numbers set for the chosen targets, changing the targets significantly should change the valuations.  If CMS and HHSC are not going to send standard methodology for setting targets until Oct. 1 in DY3, how do we estimate DY2-DY3 payments?

Response:

The objective methodology being developed by CMS and HHSC is to determine the impact of the project sufficiently justifies each projects value for DYs 4 and 5 only.  With initial approval of a project, pending any priority technical corrections, a project will be eligible for DY2 and 3 funding based on valuation of DY2 and 3 milestones.

Waiver FAQ

Date posted:

April 8, 2013

Requestor:

Jeanie Foster

Question:

Unrelated to the latest changes, I remember hearing in a meeting that 1115 funds cannot be used for new construction or for recruiting costs.  I cannot find that information in the PFMP.  If I am remembering correctly that we cannot use the funds for recruiting costs, what qualifies as “recruitment costs?”

Response:

The issue of “new construction” is related to project valuation and not the use of DSRIP dollars.  “New construction” costs cannot be used as a basis for valuing DSRIP projects.

Waiver FAQ

Date posted:

March 19, 2013

Requestor:

Dan Fernandez

Question:

Who is actually responsible for the report? Was it developed by JPS Staff members or authored by an unnamed 3rd party consulting firm?

Response:

The assembling of the Region 10 plan is a joint effort of many individuals and organizations.  Those providing significant content include JPS as the anchor organization, participating performing providers, and subject matter experts (waiver subject matter experts and legal) as needs were determined by each performing provider

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

How much did it cost to prepare this report?

Response:

The cost for all performing providers in the region is unknown.  JPS’s external cost to complete the plan was approximately $2.5 million.  These costs are funded through DSRIP funds.

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

Starting on page 16, there are 20 pages of Category 1-2 projects. What were the criteria used to select these projects versus (other than an apparent healthcare institution’s wish list)?

Response:

The criteria for project selection were driven from a menu of projects spelled out by the Center for Medicare and Medicaid Services (CMS) and Texas Health and Human Services Commission (HHSC).  The requirements can be found in the RHP Planning Protocol and Program and Funding Mechanics Protocol documents located on HHSC’s website.  These requirements can be found at:  http://www.hhsc.state.tx.us/1115-Waiver-Guideline.shtml.  Performing providers were then allowed to select projects within the parameters of these guidelines where the provider could demonstrate a need through a community needs analysis. 

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

There are enormous technology requirements underlying these 20 pages of projects. These include:

a. IT infrastructure (in-house, host, cloud)

b. Networks / communications (telephony, mobility, BYOD)

c. Applications (clinical, patient billing, electronic health records, analytics, etc.); and,

d. Systems integration underlies these 20 pages of projects.

e. What is RHS overall strategic IT plan for all these requirements to ensure the projects’ successful outcomes and timely implementation, and minimize redundancy and cost overruns, etc.?

Response:

HHSC and the performing providers are currently assessing IT needs and requirements.  Final determination of those requirements cannot occur until after final plan approval by CMS which is targeted for May 1, 2013.

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

Who is responsible for the preparation for this strategic IT plan?

Response:

Strategic planning is a joint function of the Board of Managers and Senior Leadership.

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

Are these technologies costs included in the budget numbers on the right side of the page? If so, what amount of these budgets is allocated to address the technology requirements?

Response:

The waiver does not permit a cost passthrough approach.  All project valuations are based on the estimated economic impact that a particular project has on a defined population of patients through an associated intervention.  Final valuation amounts will be determined by CMS in the final approved plan.

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

If they are not included in these budgets, then what are the technology budget numbers?

Response:

The preforming providers are currently developing long term business plans and projections of cost needed to fully implement the plans.  Final determinations will be made once CMS provides full plan approval.

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

What is the difference between the anticipated revenue and costs of these projects, the difference which will have to be made up by the Counties (and specifically Tarrant County as the largest county in the RPS)?

Response:

As per question #7, the net differential of project revenue and costs is currently being assessed and final determinations will occur after CMS provides final plan approval.  If a project cost more than the available funds, a performing provider will have to choose from multiple options including:  discontinuing the project, subsidizing the project from gains on other projects, or subsidizing the project from other operating funds, reserves, or efficiency gains.   

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

What are the Counties plan to address these revenue gaps?

Response:

Not fully known at this time.  All performing providers are developing implementation and business plans as the Region 10 plan is being reviewed by CMS. 

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

What is being done to integrate the RHS technology strategy with the Counties planned technology strategies to minimize redundancies and duplicate costs? How can these technology strategies combine to save money and improve service?

Response:

We understand that HHSC has an RFP underway to develop an information database system to support the reporting requirements of the DSRIP projects beginning in DY3 of the Waiver (October 1, 2013).  The anchors have been advised that they will be notified of these requirements by HHSC once the RFP selection has been completed.  

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

What is the best, most effective strategy(ies) to procure these technologies, especially concerning the short timeline to comply to the Texas HHS requirements?

Response:

JPS has been evaluating how to best provide the reporting of milestones and metrics with newly installed EPIC system and with other internal systems infrastructure.  The SVP for Quality and IT leadership (CIO) are currently assessing alternative project management programs to support DSRIP project owners in the implementation of DSRIP projects.  IT Infrastructure needs by non-JPS entities are unknown at this time by JPS.

Waiver FAQ

Date Posted: 

March 19, 2013

Requestor:

Dan Fernandez

Question:

How will the structural infrastructure be procured (e.g. additions to JPS and other medical institutions)?

Response:

IT infrastructure for JPS will be procured through the standard JPS procurement processes.  Non-JPS infrastructure will be secured directly by the performing providers.