Wage Parity and Certified Home Health Agencies
During the week of Sept. 22, the Department of Health (DOH) posted a federal document approving an increase in the Medicaid Fee-For-Service (FFS) rates for New York City Certified Home Health Agencies (CHHAs) to assist with the State Home Care Worker Wage Parity Law. This is in response to DOH’s request in March 2014, “For periods on and after March 1, 2014, the Commissioner of Health will adjust Medicaid rates of payment for services provided by certified home health agencies to address cost increases stemming from the wage increases required by implementation of the provisions of section 3614-c of the Public Health Law. Such rate adjustments will be based on a comparison, as determined by the Commissioner, of the hourly compensation levels for home health aides and personal care aides as reflected in the existing Medicaid rates for certified home health agencies to the hourly compensation levels incurred as a result of complying with the provisions of section 3614-c of the Public Health Law."
As we previously reported, the final state budget included $50 million for CHHAs and Long Term Home Health Care Programs (LTHHCPs) in New York City to support wage parity costs. The LTHHCP wage parity rate increases were already posted in July. Those rates did not require CMS approval.
The $50 million is separate from the wage parity Quality Incentive/Vital Access Provider Pool (QIVAPP). The QIVAPP monies will go into the Managed Long Term Care (MLTC) premiums and then adjustments must be passed on to certain eligible home care providers to help meet wage parity. According to the May 8, Dear Administrator Letter (DAL):"The determined NYC wage parity adjustment is to establish a minimum rate for both Home Health Aide (HHA) and Personal Care Aide (PCA) services of $20.95 per hour, retroactive to March 1, 2014. The DAL also clarifies, "Adjustment for NYC CHHA episodic rates will be based on a comparison of the minimum $20.95 rate to the weighted average HHA rate reflected in the 2009 expenditure episodic rate. That result will be further adjusted for accurate application to the episodic payment structure; this includes adjustments for such factors as the bundled payment that also includes professional nursing and therapy services and the low utilization and outlier components of the rate structure. DOH has determined a preliminary estimate that the results of this calculation will produce a uniform increase to the NYC episodic prices of approximately 11 percent."