Public Hearing on CCN Notice of Intent March 30
The Department of Health will hold a public hearing Wednesday, March 30, on the Notice of Intent to implement Coordinated Care Networks for Louisiana Medicaid recipients. The hearing will take place at 9:30 a.m. in Room 118 of the Bienville Building (DHH headquarters), 628 N. 4th St. in downtown Baton Rouge.
The Notice of Intent was published in the Louisiana Register on Feb. 20, which served as the official start of the rulemaking process and enacted a period of public comment. To see a copy of the Notice of Intent, click here. To see all resources related to the Notice of Intent, please click here.
Because this is a public hearing, the state will accept oral testimony or written comments. There will be no question-and-answer period at this meeting. People who are unable to attend the public hearing are also welcome to submit their comments in writing per the instructions listed in the Notice of Intent.
Updates for Providers
CCN Provider Recruitment
Potential CCNs are now reaching out to Louisiana health care providers to solicit their participation in CCN provider networks. This step is necessary for potential CCNs to show LDH they can provide an adequate network of providers, should they be successful in securing a contract with LDH to establish a CCN.
LDH has created a model Letter of Intent for potential CCNs to use in their recruiting efforts. For the purposes of a CCN proposal, LDH is only requiring the potential CCNs to provide Letters of Intent as their evidence that they can form an adequate network. Contracts with providers are not required at this time. However, CCNs and providers are free to enter into contracts at this time if they prefer. For Phase 1 (New Orleans and the Northshore Regions), there will be a very short period of time between the August award of contracts and the late September deadline for inclusion of a provider in the CCN's initial Provider Listing, which potential members will use to choose a CCN and PCP.
The frequently asked questions listed below and the provider participation guidelines, located here, were created to assist providers during this recruitment period.
Frequently Asked Questions - Provider Recruitment
Q: Do I have to sign a Letter of Intent?
A: No. Providers are under no obligation to sign a Letter of Intent. However, LDH encourages providers to sign the non-binding Letter of Intent if they are open to good faith negotiations to contract with the CCN, post-contract award.
Q: Does signing the Letter of Intent commit me to contracting with a CCN?
A: No. The Letter of Intent is non-binding and does not obligate you to contract with a CCN. The Letter of Intent is used to help LDH determine whether a potential CCN has providers who have agreed to enter into good faith discussions about becoming a member of the CCN's network.
Q: A potential CCN has contacted me and is insisting I contract with them at this time - they are not interested in the Letter of Intent. What are my options?
A: Providers are under no obligation to sign a contract (or a Letter of Intent) at this time. If you wish to contract with the network at this time, you are welcome to do so. Reimbursement terms cannot be less than the Medicaid rate for the provider type in effect on the date of service.
Q: If I contract with a CCN at this time, but decide after they are successful in their bid to be a CCN that I don't want to be part of their CCN, what recourse do I have?
A: LDH does not know all of the terms and conditions included in the potential CCN contracts. We are only aware of the terms and conditions that LDH requires (see the contract checklist, located here). If your contract has not yet been signed, you could require an out clause.
Q: A potential CCN has contacted me and asked me to sign a Letter of Intent. They have informed me that, if I do not sign the Letter of Intent at this time, they will make additional efforts to contact and contract with me and, if I refuse all three times, they can later pay me 90% of the state rates as an out-of-network provider. Is this true?
A:. The CCN Notice of Intent includes language that a CCN must make three documented attempts to contract with a provider before they can reimburse out-of network providers for non-emergency services at 90% of the Medicaid rate. However, these three documented attempts cannot begin until after the date the CCN is awarded a contract and the contract is signed by the CCN. LDH does not anticipate any contracts to be awarded and signed before August.
Q: My clinic has a number of providers of different types, but not everyone in the clinic wants to be enrolled with a CCN. Does the signed Letter of Intent commit the whole clinic and all of our providers?
A: No. The Letter of Intent should clearly indicate which of the clinic's providers are covered by the Letter of Intent.
Q: A doctor in our clinic sees dual eligible Medicaid/Medicare in her office, but does treat Medicaid primary patients at a local hospital. Does she need to sign a Letter of Intent for either scenario? Would this obligate her to be a primary care provider with assigned patients to her in-office practice?
A: The Letter of Intent is non-binding. Your provider can indicate whether he or she will act as a primary care provider with assigned patients (and the number of patients he/she can accept) or he/she can elect to serve in a specialist capacity. Please note, out of network providers may receive lower reimbursement rates for non-emergent services.
Q: Our provider group includes several hospital-based providers. Do they need to sign or be included on the Letter of Intent?
A: This decision is at the discretion of the provider. Emergency services must be reimbursed by CCNs at 100% of the Medicaid rate, regardless of whether a provider is a network provider. For non-emergency services (those that do not meet the prudent layperson definition of an emergency), the CCN is permitted to reimburse out-of-network providers 90% of the Medicaid rate IF they have made three documented offers to contract with the provider at the 100% Medicaid rate and the provider chooses not to be a member of the network. Those three official attempts cannot begin until after the date the CCN is awarded a contract and the contract is signed. LDH does not anticipate any contracts to be signed before August.
Q: Our hospital-based providers see patients in both a nursing home and rehab hospital setting. Do they need to sign or be included in Letter of Intent?
A: Rehab hospital services are among the CCN core benefits and services and would be considered non-emergent. As non-emergent services, any out-of-network provider could be paid at 90% of the Medicaid rate (see above question).
Residents of nursing homes are excluded from enrollment in a CCN, and room and board payments to nursing facilities are not included in the CCN core benefits and services. Reimbursement will continue to be made by DHH. If a member of a CCN is admitted to a nursing facility, they will revert to fee-for-service Medicaid the first day of the following month. It is possible that the CCN could be responsible for the physician visit in the nursing home setting in that month of admission.
Provider Conference Calls - Follow Up
Following the publication of the Notice of Intent, LDH Medicaid Medical Director Dr. Rodney Wise and staff working on the state's CCN proposal held a series of conference calls with Medicaid doctors, nurse practitioners and other health care providers to discuss the plans for CCN implementation and answer questions. Click here to see the questions and answers from the calls. These are also posted on the "For Providers" page at www.MakingMedicaidBetter.com. Providers can submit additional questions or comments to firstname.lastname@example.org, or can submit these using the electronic form at www.MakingMedicaidBetter.com.
Louisiana Medicaid EHR Incentive Program
The Louisiana Medicaid EHR Incentive Program, which opened registration in January 2011, is offering payments to eligible providers and hospitals that treat Medicaid patients and wish to adopt this technology so they can better coordinate care. Program registration is open, and providers can learn more or sign up for the program at www.MakingMedicaidBetter.com. For more information, please call 225.342.4810 or email email@example.com.
The federal Center for Medicare and Medicaid Services' Electronic Health Record (EHR) Incentive Programs are holding conference calls for eligible professionals and eligible hospitals about important registration information.
A call for eligible providers will take place Friday, April 1, from 1:30-3 p.m. ET, and a call for eligible hospitals will take place Wednesday, April 6, from 1:30-3 p.m. ET. To register for either of these calls, participants must log on to the eligible providers site for the April 1 call, or the eligible hospitals site for the April 6 call. Registration closes at 1:30 p.m. ET on the day before each of the calls is scheduled or when all available space has been filled.
For the latest news and updates on the EHR Incentive Programs, please visit the CMS website.
Your feedback is important to us as we move forward in transforming Louisiana's Medicaid program. For the latest information or to share your comments, please visit www.MakingMedicaidBetter.com, e-mail firstname.lastname@example.org, or call toll-free 1-888-342-6207.