Waiver services provided through the Consolidated and P/FDS waivers are also known as Community Waiver Programs. These services exclude ICF/ID (formerly ICF/MR) services (even though ICFs/ID are also located in the community).
Fiscally, the Community Waiver program in Pennsylvania has been going through many changes over the last several years. The transition is not yet over. Community Waiver programs previously received funding from the county MH/MR offices throughout the State, who in turn, received allocations from the State level, who in turn, received federal participation dollars from the federal government. Funding was provided to provider agencies from the county MH/MR offices based on an annual contract. While there were similarities throughout the state, there were also differences, making no two county/provider relationships the same.
In the effort to meet federal requirements of standardizing a payment system throughout the state, DPW first started with "ratesetting forms" a few years ago. This quickly became obsolete, and DPW went forward with "cost reporting." Beginning with FY 2007-2008, provider agencies first filed cost reports in the fall of 2008 for the preceding fiscal year. These cost reports not only were to serve as a formal filing of an agency's expenses but also were to become the basis for a future year's "ratesetting," hence PPS, or Prospective Payment System. FY 2008-2009 cost reports were prepared and submitted by providers to the state in the fall of 2009, FY 2009-2010 cost reports were due by October 17, 2010, and FY 2010-11 cost reports--known as Year 4--were due November 3, 2011, but the deadline was extended to November 7, 2011. Year 5 cost reports--to report expenses for FY 2011-12-- were due November 1, 2012, but the deadline was extended due to Hurricane Sandy. Year 6 cost reports were due October 31, 2013. "Year 7" cost reports are due October 30, 2014.
As of this date, the actual ratesetting process is still not fully understood and we are uncertain of forthcoming changes. In simplest form, however, your reported costs and available units are used to calculate a unit cost which is then the basis for the calculation of your rate two years later. Revenue adjustment factors (RAFs) have been applied in some years, and cost of living adjustments have been absent. The rates are also restricted in other ways. For FY 2012-13, all nonresidential services and residential ineligible services have been moved to the fee-for-service Department-established rates. For residential eligible services, the outlier methodology is still in play and the parameters are being tightened more each year. Additionally, a 97% vacancy factor is applied to the cost-based rates, but providers, in turn, may no longer bill for medical or therapeutic leave days.
Many providers have been unable to figure out how their rates were calculated, because the "rate letters" do not provide the calculation. If you need assistance with a rate analysis, contact AZTAC and we can help you with that. We are able to calculate most of the rates.
The Chapter 51 regulations were published on June 9, 2012 (without going through the Independent Regulatory Review Commission). These regulations are retroactive to July 1, 2011, except where noted, and contain many provisions for the Department to publish additional changes in the Pennsylvania Bulletin. The Chapter 51 regulations are quite controversial, and it is questionale whether or not the regulations are indeed valid.
The revenue reconciliation process was implemented, rather haphazardly for many, for two years (FY 09-10 and FY 10-11) and does not continue any longer.
AZTAC assists providers throughout the year as ODP issues and requests more and more information. AZTAC is experienced with revenue reconciliation, rate setting, cost reporting and appeals.