Update on the Medicaid Nursing Facility Upper Payment Limit (UPL) program

Posted on: 9/7/16


This week the Oklahoma Health Care Authority (OHCA) gave an update to and got feedback from representatives of the OHA, the Oklahoma Association of Health Care Providers (OAHCP), and LeadingAge Oklahoma.

OHCA has submitted to CMS the question about Oklahoma (Title 60) public trusts’ ability to make intergovernmental transfers (IGTs) to OHCA. This program can only be funded by IGTs, so it will be limited to non-state government owned nursing homes. No feedback on this question has yet been received from CMS.

OHCA has engaged Myers & Stauffer as their technical consultant for the nursing facility UPL program, and the agency held an all-day kick-off meeting with their consultant last week. Myers & Stauffer serves many state Medicaid agencies, and is OHCA’s auditor for their Disproportionate Share Hospital (DSH) program. The implementation work plan is drafted but not yet finalized. A Data Use Agreement allowing Myers & Stauffer access to the Minimum Data Set (MDS) of SoonerCare residents of participating facilities has been submitted to CMS for approval. Myers & Stauffer is creating a secure website/portal for participating facilities with information, forms, and the communication of amounts and calculations.

OHCA plans to submit the State Plan Amendment authorizing this program to CMS in October or November. Once approved, the program will be effective retroactively to Oct. 1, 2016. No funds will be exchanged until CMS has approved the program.

Agency rules for the program will be posted this week on OHCA’s Proposed Policy Changes page. The rules will be reviewed by OHCA’s Medical Advisory Committee on Sept. 15, and approved by their board on Oct. 13.

OHCA, OAHCP, and the Oklahoma State Department of Health have been working on improvements in the Certificate of Need process for nursing facilities, and have involved Novitas in improvements in the Change of Ownership approval process. OHCA is studying issues related to facilities’ starting date in this program following a change in ownership and new SoonerCare provider contract. Generally, the plan is for new participants in the program to enter quarterly, but OHCA has been asked to allow monthly entry during the startup period of this program.

OHCA is working on education and communication for eligible facilities.  (Rick Snyder)

OHA Partners with Healthcare Staffing Services 


Healthcare Staffing Services was developed as a collaborative effort among multiple state hospital associations to meet the temporary staffing needs of member hospitals and health systems.

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