The State of Connecticut Department of Social Services (DSS) released a new draft notice to identify how the Medicaid Nursing Home Wage and Benefit Program (NHWABP) will be implemented. Based upon the new draft released by the Department on September 22, 2015, this program will consist of three parts, all of which will require nursing home facilities to complete forms to be filed with DSS. The details for these three Parts are as follows:
Part 1 of the program is primarily focused on salary and wage increases to the direct and indirect employees (i.e. Dietary, Housekeeping, Laundry, DON, ADON, RN, LPN & Aides). There is a total of $26,000,000 that will be allocated to all skilled nursing facilities whom meet the following eligibility requirements:
- Wage increases were given and/or increased staffing levels for direct and indirect employees made between October 1, 2014 and July 30, 2015
- Wage increases will be given and/or staffing levels will be increased for direct and indirect employees from July 1, 2015 through June 30, 2016
In order to apply for additional funding under Part 1 of the NHWABP, each facility must provide information regarding increases made within the specified periods listed above (the amount of the increase(s) and date(s) given). The form to be filed with the Department will compare direct and indirect wages as reported in the 2014 Annual Cost Report with increases already made from October 1, 2014 through June 20, 2015 (annualized); or increases that were or will be given from July 1, 2015 through June 30, 2016. Consistent will all payments made from the Medicaid program, the State with only pay for the Medicaid portion of these increases (calculated using Medicaid to total days reported on the 2014 Annual Cost Report). Also, if total Medicaid payments to facilities is in excess of the $26,000,000 available for this part of the program, each facility will be awarded a percent of the $26,000,000 based upon their individual increase compared to all increases given.
Each rate increase related to the NHWABP will be effective on the first day that the increase was actually implemented by the nursing facility. Additionally, all increases will be subject to desk review and field audit. Upon completion of these reviews, if it is determined that the additional funding provided was now utilized for the specific wage enhancements identified above, the per diem rates will be adjusted downward to reflect actual costs spent within the NHWABP guidelines.
Part 2 of the program is focused on employee benefits, contact services, and maintenance wages. The State has between $6,640,000 and $9,600,000 that will be allocated to facilities, with the total amount to be allocated pending on how much is awarded in Part 3. For Part 2, the State is looking for increases in the following areas:
- Increase in existing pension plan benefits
- Health care insurance
- Increases for health care services contract workers
- Wage increases for maintenance workers
- Training activities
Costs eligible for Part 2 of the program must be incurred on or after July 1, 2015, and facilities will need to apply for the funding. Consistent with Part 1 of the program, a form must be filled out stating the date(s) and amount(s) of increases; only the Medicaid portion will be reimbursed; the increase is effective the date when the wage enhancements and or benefits enhancements were implemented by the facility; all rate increases provided are subject to Department review and any amounts not deemed to be for the specific items listed above will result in negative adjustment to the Medicaid rate. The one caveat for Part 2 is that the base amount that can be allocated to facilities is $6,640,000; however, any remaining funding not used for Part 3 of the program may also be used to fund these increases.
The final part of the WEP is Part 3, which focuses on the implementation of a new pension plan. Any facility that implements a new pension plan for their workers is available to apply for some of the $2,960,000 funding available. Each applicant must submit a schedule of additional costs incurred by implementing a new pension plan and the effective date of the increase. These new costs will be annualized for review purposes and must be incurred on or after July 1, 2015. Consistent with Part 1 and Part 2, the rate increase will be effective the day the nursing facility implements the new benefits with all additional increases provided subject to audit and review with any corresponding adjustments to the rates.
All information and necessary forms applicable to the Nursing Home Wage and Benefit Program can be found on the State of Connecticut Department of Social Services’ website which is linked below:
Should you have any further questions, you can reach Stephen Bernier or Matthew Bavolack directly at (860) 760-0677 or (203) 781-9680 respectively.