DSRIP Meeting Agenda

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Date and Time 2/22/16, 8am-9am

Meeting Title NYP PPS Executive Committee

Location GoTo only

Facilitator David Alge, Betty Cheng

Go to Meeting https://global.gotomeeting.com/join/609884293

Conference Line Dial +1 (872) 240-3212 Access Code: 609-884-293

Invitees

Betty Cheng (CBWCHC) David Alge

Ashanti Chimurenga (NMPP) Emilio Carrillo (Clinical Operations)

Sharen Duke (ASCNYC) Brian Kurz (Finance)

Jay Gormley (MJHS) Steven Kaplan & Niloo Sobhani (Data/IT Governance)

Ellen Harnett (Isabella) Anne Sperling (PAC)

Meeting Objectives Time

1. Review Action Items from Last Meeting 2. Review NYS Updates 3. Review PPS Updates 4. Review of Compliance Educational Material 5. Update on Participation Agreements 6. Identify Action Items for Next Meeting

5 mins 5 mins 5 mins

10 mins 10 mins 5 mins

Action Items

Description Owner Start Date Due Date S Status

Make suggested changes to the NYP PPS Compliance Plan

D. Marsden 12/18/2015 12/31/2015 Completed

Share compliance slides and hotline information with Committee once final

D. Marsden 12/18/2015 1/2016 In progress

DSRIP Meeting Agenda

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Date and Time 2/22/16, 8am-9am

Meeting Title NYP PPS Executive Committee

Location GoTo only

Facilitator David Alge, Betty Cheng

Go to Meeting https://global.gotomeeting.com/join/609884293

Conference Line Dial +1 (872) 240-3212 Access Code: 609-884-293

Attendees

Betty Cheng (CBWCHC) David Alge

Ashanti Chimurenga (NMPP) Emilio Carrillo (Clinical Operations)

Sharen Duke (ASCNYC) Brian Kurz (Finance)

Jay Gormley (MJHS) Steven Kaplan & Niloo Sobhani (Data/IT Governance)

Lauren Alexander (NYP) Anne Sperling (PAC)

Isaac Kastenbaum (NYP)

Meeting Objectives Time

1. Review Action Items from Last Meeting 2. Review NYS Updates 3. Review PPS Updates 4. Review of Compliance Educational Material 5. Update on Participation Agreements 6. Identify Action Items for Next Meeting

5 mins 5 mins 5 mins

10 mins 10 mins 5 mins

Action Items

Description Owner Start Date Due Date S Status

Invite D. Marsden to the next meeting for a follow-up discussion related to compliance programming

L. Alexander 2/22/2016 4/21/2016 In progress

Consider broadening language of compliance hotline slide

D. Marsden 2/22/2016 4/21/2016 In progress

Look into recommended compliance trainings to suggest to collaborator organizations

D. Marsden 2/22/2016 4/21/2016 In progress

Develop “inactive” status and associated process for organizations who have not returned Participation Agreements

I. Kastenbaum, L. Alexander, K, Kurz, D.

Alge 2/22/2016 4/21/2016 In progress

MINUTES:

D. Alge opened the meeting.

I. Kastenbaum provided a NYS update. He covered the following: o DY1, Q3 reports were submitted January 31, 2016 and PPSs are currently undergoing a validation

process. Remediation will be the first two weeks of March. o There was a NYS All PPS meeting held on February 17

th.The meeting focused on:

Providing updates on provider-level reporting Cultural competency and health literacy Engaging CBOs

o There is a call taking place today (2/22/16) to discuss the Equity Infrastructure Program and the Equity Performance Program.

o There are no additional updates on capital funding. The requests are still with the Governor’s office. o J. Gormley inquired as to whether there is still an obligation that we meet milestones despite

the funding delay.

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L. Alexander provided an NYP PPS update. She covered the following: o General updates:

We have launched a new webinar series. Upcoming webinars will be focused on Healthix and funds flow.

We received the full AVS for DY1, Q2 reporting. The PPS IS strategy continues. HIE assessments are currently being conducted with

collaborators and initial conversations between Healthix, collaborators and project teams are underway. We are beginning to connect some collaborators to ACD and developing workflows related to that.

A revamp of the PPS website is underway. Contracting is still in progress. We are currently conducting follow-up with organizations

regarding outstanding Performance Agreements. Service Agreements have been finalized with 12 of the 15 organizations where we will be placing DSRIP-funded staff.

67 out of 97 DSRIP-funded staff that will be placed at NYP have been hired. o Projects:

Adult Ambulatory ICU is piloting enhancements to the Interdisciplinary Teams and well as integrated visits for adults with complex care needs.

Palliative Care went live on Feb 15th, using the proposed tools, assessments and processes they have developed. They are also currently developing a PCMH-based training strategy for the project.

Pediatric Ambulatory ICU changed their name to SKATE – Special Kids Achieving Their Everything. They are also fully staffed.

Transitions of Care is developing a strategy to ensure successful warm handoffs between inpatient and outpatient care managers.

ED Care Triage is finalizing their workflows and is close to resolving union issues that will allow them to hire at Lower Manhattan.

Behavioral Health Crisis is starting to develop workflows in collaboration with ACN sites so they can set up their structure. They are also in the process of operationalizing their model now that their waiver has come through. Behavioral Health Primary Care is developing Allscripts Care Director to further engage community-based collaborators in care coordination activities.

HIV’s Steering Committee has a new name, REACH - Ready to End AIDS and Cure Hepatitis. The IDS has started workgroups to address various needs such as Healthix and Meaningful

Use and is working to streamline processes across the network.

L. Alexander reviewed the compliance educational materials, including the slides and advertisement for the compliance hotline.

o Dr. S. Kaplan asked how the educational material will be shared with the network. Both he and S. Duke suggested that they be shared through a webinar.

o Dr. E. Carrillo asked whether there is dedicated staffing to the PPS compliance program. o Dr. S. Kaplan, J. Gormley and S. Duke asked if organizations will need to provide an attestation to their

compliance programming and/or show evidence that their staff have been trained. S. Duke recommended that if not for all collaborators, do we want to consider this for the collaborators that will be receiving funding. She suggested that we might consider having these organizations submit a copy of their policy and an attestation that their staff have been trained.

D. Alge noted the balance between ensuring effective compliance programs are in place across the PPS with assuming responsibility for other organization’s compliance programming. D. Marsden will be invited to the next meeting for a follow-up discussion.

o S. Duke asked whether we will be providing a recommended training to collaborator organizations. o S. Duke asked about the audience of the compliance hotline and whether it was both consumer and

provider-oriented. If so, we may want to consider broadening the language as the slide currently reads more provider-oriented.

o Dr. S. Kaplan asked if the compliance hotline was dedicated to DSRIP or if it was the general NYP compliance hotline.

L. Alexander provided an update on Participation Agreements. Out of about 90 collaborators organizations, we still have approximately 25 outstanding agreements. There have been numerous attempts to reach out to the remaining organizations, including individual e-mail and phone outreach. I. Kastenbaum noted that the reasons for not returning the agreement vary across organizations. D. Alge led a discussion with the group about how we want to address organizations that have not return their Participation Agreements. He noted that we cannot

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flow funds to an organization that does not have an agreement on file. He also noted that there is a formal and quite involved process to remove an organization from the PPS. He asked the group whether we want to manage the non-responders more formally so that we can provide evidence to the State that notice was provided regarding their status within the PPS.

o Dr. E. Carrillo asked if the non-responders are organizations that are integral to the care coordination work happening in the projects.

o S. Duke suggested that perhaps we consider defining collaborator more narrowly (i.e. reimbursable role within a project).

o B. Kurz recommended that we consider a “suspended” or “inactive” status. Based on failure to reply within 30 days, this status would go into effect. Both D. Alge and E. Carrillo agreed. The group decided to formalize this into writing with specific terms and then send to the Executive Committee for feedback.

o Dr. E. Carrillo suggested reaching out to organizations for a meeting to address their lack of participation as opposed to an automatic suspension.

o I. Kastenbaum will work with L. Alexander, D. Alge and B. Kurz to outline the process, what is means to be in an inactive status and the steps to be taken prior to putting an organization in this status.

D. Alge closed the meeting.

Delivery System Reform Incentive Payment Program (“DSRIP”) NewYork-Presbyterian Performing Provider System

Overview of DSRIP Program

What is the Delivery System Reform Incentive Payment Program (“DSRIP”)?

What is DSRIP’s Primary Goal? DSRIP’s primary goal is to reduce potentially preventable hospital admissions and emergency room visits by 25% over 5 years by coordinating care across patient care settings to promote health and better outcomes, particularly for at-risk populations.

DSRIP is a New York State program whose primary purpose is to fundamentally restructure the health care delivery system by reinvesting in the Medicaid program.

Additional information on the DSRIP program can be found at the New York Department of Health website: http://www.health.ny.gov/health_care/medicaid/redesign/dsrip/

Performing Provider Systems Collaboration is essential to the mission and goal of the DSRIP program.

DSRIP requires that local networks be established between various provider types. These networks must create new and innovative projects that focus on:

(i) system transformation;

(ii) clinical improvements; and

(iii) population health improvements.

The collective network is called the Performing Provider Systems (“PPS”).

Each provider in the network is referred to as a Participating Provider.

New York Presbyterian PPS NewYork-Presbyterian Hospital (“NYP”) has been designated “Lead” for the NYP Performing Provider System network (“NYP PPS”).

NYP PPS consists of a wide variety of provider/organizational types and services including, but not limited to:

Hospitals

Clinics

Primary Care and other Specialty Providers

Mental Health and Substance Abuse Providers

Home Care Services

Laboratory, Radiology and Rehabilitation Service Providers

Pharmacies

Community-Based Organizations

DSRIP – Incentive Payment Program:

DSRIP is an incentive payment program. Payment and financial rewards are dependent upon project implementation and meeting specific quality and performance measures. Payment for DSRIP project-related activities are based on performance linked to:

achievement of project milestones (Pay-for-Performance); and

timely reporting (Pay-for-Reporting).

DSRIP Funds Distribution Plan The NYP PPS Lead is responsible for the distribution of DSRIP funds, in accordance with State criteria and the NYP PPS’s Budget and Funds Flow Distribution Plan (“Plan”).

The Plan supports achievement of DSRIP goals and successful implementation of NYP PPS projects. All funds will be distributed in accordance with the Plan.

NYP PPS Participating Providers must understand their responsibility regarding accurate and timely reporting of milestones measures; and for achieving the goals of each project, as well as the overall DSRIP initiative.

NYP PPS Compliance Program

DSRIP PPS Lead Compliance Program Requirements

DSRIP requires that the PPS Lead have an effective compliance program, in accordance with New York State Social Services Law and New York Code, Rules and Regulations.

The Office of Medicaid Inspector General (“OMIG”) released guidance for PPS Leads regarding DSRIP-related compliance.

Accordingly, NYP PPS Lead has established a PPS Compliance Policy, outlining the DSRIP Compliance obligations of the PPS Lead and its Participating Providers.

See Resources slide, at the end of this presentation, for information on NYS compliance program requirements and OMIG DSRIP compliance program guidance

NYP PPS Lead Compliance Program

As part of its DSRIP Compliance Program obligations, the NYP PPS Lead will:

provide guidance and resources, as appropriate, to Participating Providers on compliance matters related to DSRIP funds

report to the NYP PPS Executive Committee on DSRIP-related matters regarding compliance

inform Participating Providers of their responsibility to provide DSRIP-related compliance training to their staff

NYP PPS Lead Compliance Program – cont’d

establish systems for routine identification of compliance risks concerning DSRIP project performance and allocated payments

establish communication methods for reporting DSRIP funds- related concerns

establish systems for responding to compliance issues related to DSRIP funds

Participating Providers’ Compliance Program Obligations

OMIG guidance provides that the PPS Lead is not responsible for Participating Providers’ compliance programs; as may be required under NYS Law and Regulations, based on their Medicaid provider status.

As such, all Participating Providers involved in the NYP PPS, subject to NYS mandatory compliance program obligations, must have an effective program in place.

Participating Providers not mandated under NYS to establish a compliance program should consider implementing a program appropriate for their size, complexity, resources and culture.

Participating Providers’ Compliance Program Obligations – cont’d

All NYP PPS Participating Providers, irrespective of an existing compliance program, must have or establish:

systems to ensure DSRIP funds are appropriately obtained and are used in accordance with the approved project plan

systems to identify and prevent fraud and abuse, specific to discrepancies of DSRIP payments or misuse of DSRIP funds

staff training on: Participating Provider’s role in DSRIP project(s); DSRIP compliance expectations of staff; and how to report any fraud or abuse of DSRIP funds to their

Compliance Liaison.

Participating Providers’ Compliance Program Obligations – cont’d Participating Provider’s compliance program must have or establish:

appropriate training or educational resources on Healthcare Fraud and Abuse Laws and Regulations, as required by the Deficit Reduction Act

policies regarding good faith reporting of compliance issues and non-retaliation

In addition to staff obligation to comply with all laws and regulation applicable to the Participating Provider, staff involved in DSRIP projects must be made aware of their obligation to comply with DSRIP regulations and the NYP PPS Lead Compliance Policy provisions.

Compliance concerns related to DSRIP funds may be reported to the PPS Lead via the PPS Help Line at (888)308-4435.

See Resources slide, at the end of this presentation, for information on provider obligations regarding Fraud and Abuse, under the Federal Deficit Reduction Act

Resources

New York Social Service Law 363-d Provider Compliance Program

18 N.Y.C.R.R PART 521.3 - Provider Compliance Programs

Office of Medicaid Inspector General DSRIP Compliance Guidance

Federal Deficit Reduction Act - Fraud, Waste and Abuse

The links below provide additional guidance on Provider Compliance Program requirements.

DSRIP Performing Providers System Helpline 1-888-308-4435 Confidential helpline for reporting DSRIP related compliance issues to the Performing Provider System Lead Compliance Officer. The helpline is available 24/7, and calls may be anonymous and will be kept confidential to the extent possible.

New York-Presbyterian (“NYP”) - Delivery Systems Reform Incentive Payment Program (“DSRIP”) Page 1 of 4 ___________________________________________________________ TITLE: PERFORMING PROVIDER SYSTEM COMPLIANCE POLICY BACKGROUND

New York State (“NYS”) Department of Health (“DOH”) has established the Delivery System Reform Incentive Payment Program (“DSRIP”) to promote community-level collaborations that focus on Medicaid system reform, and to reduce avoidable hospital use over the next five years. Through the establishment of Performing Provider Systems (“PPS”), safety net providers and community providers collaborate to implement innovative projects focusing on system transformation, clinical improvement and population health improvement. PURPOSE:

As part of New York Presbyterian’s (“NYP”) commitment as a PPS Lead, NYP PPS has developed a PPS Compliance Policy (“PPS Policy”), in accordance with DSRIP regulations and NYS Office of Inspector General (“OMIG”) September 1, 2015 DSRIP Compliance Guidance (2015-01 – Revised). The PPS Policy is dedicated to maintaining excellence and integrity in support of DSRIP’s mission and the implementation of the DSRIP Program. The PPS Policy is designed to support a culture that promotes prevention, detection, and resolution of instances that do not conform to laws, regulations, and DSRIP requirements.

POLICY:

The PPS Policy was established in accordance with relevant federal and state laws and regulations, including but not limited to New York State Social Services Law (“SSL”) 363-d; Title 18 of the New York Code of Rules and Regulations (“NYCRR”), part 521; the Deficit Reduction Act of 2005; DSRIP requirements; and applicable NYP policies and procedures.

Pursuant to New York State law, NYP has an established provider compliance program, which among other things include systems for (i) the detection and prevention of fraud and abuse; (ii) identification of risk areas; and (iii) reporting of compliance issues. It is important to note, as the DSRIP program progresses, the PPS Compliance Policy may have to evolve to ensure compliance with DSRIP program developments and additional OMIG considerations.

This Policy sets forth the PPS Lead and Participating Providers’ compliance program obligations under DSRIP.

APPLICABILITY:

NYP PPS Lead and Network Participating Providers

RESPONSIBILITY:

PPS LEAD:

The PPS Lead establishes processes that can assist in preventing and detecting Medicaid payment discrepancies related to the DSRIP program, specifically when Participating Providers obtain DSRIP distributions in a way that is inconsistent with approved DSRIP project plans. The PPS will consider the distribution of DSRIP funds in accordance with DOH’s requirements, as provided in the DSRIP - Measure Specification and Reporting Manual.

The PPS Policy is intended to provide reasonable assurance that the PPS Lead; in connection with the implementation of the DSRIP Program;

complies in all material respects with laws and regulations applicable to its operations; satisfies the conditions of the Delivery System Reform Incentive Payment Program; complies with OMIG’s Special Considerations for Performing Provider System Leads’

Compliance Programs; provides guidance of compliance program expectation, as outlined in the PPS policy; conducts reviews of DSRIP distribution of funds to ensure they are in accord with

approved project plan; conducts risk assessments specifically associated with payments to Participating

Providers, and performance progress towards DSRIP milestones; establishes a system for anonymous and confidential reporting of fraud, waste and abuse

of DSRIP funds, investigation, and responding to compliance issues (including a method for prompt corrective action and refund of overpayments);

provides, as appropriate, training and educational resources; and confirms Participating Provider delivery of compliance training to staff

PPS Lead Compliance Officer and Governing Body Implementation of the PPS Compliance Policy by the PPS Compliance Officer will be overseen by the DSRIP Executive Committee, the governing body of the DSRIP Program. The Compliance Officer will attend the Executive Committee and provide quarterly reports on DSRIP compliance.

Participating Provider:

The PPS Lead is not responsible for Participating Providers’ compliance programs, as may be required by their status as a Medicaid service provider. Participating Providers who meet the mandatory requirements, pursuant to SSL 363-d and 18 NYCRR 521.3, are required to have an effective compliance program. Participating Providers who do not meet the mandatory compliance program requirements should consider implementation of a compliance program appropriate for their size, complexity, resources, and culture.

The following expectations and provisions apply to the operation and activities of all NYP PPS Participating Providers, irrespective of a compliance program. The obligations for compliance include, but are not limited to:

compliance with all laws and regulations, applicable to their provider type; compliance with relevant NYP policies, as established in service/provider agreement; understanding of the purpose and applicable requirements of the DSRIP program; proper implementation of the PPS Project; maintaining complete and accurate records of all services provided to Patients covered by

the PPS’ project; submission of accurate and timely reports on measurable milestones; appropriate use of DSRIP funds for intended purpose, per project plan; providing reporting mechanism for known or suspected DSRIP compliance issues to

Compliance liaisons or Compliance Hotline; PPS Lead Compliance Officer must be notified of concerns regarding DSRIP funds; and providing compliance training on DSRIP related topics

Education, Training and Implementation All Participating Providers are obligated to provide compliance training and education regarding the DSRIP program to their respective employees. This training should include (i) compliance expectations related to DSRIP; (ii) Participating Providers’ role in the DSRIP projects; and (iii) how to report any fraud, waste or abuse of DSRIP funds. Participating Providers will confirm to the PPS Lead that all staff received such training.

Fraud and Abuse Compliance In carrying out DSRIP activities and operations, Participating Providers shall not engage in the following, as set forth by the applicable statutes and regulations:

fraud, abuse or misuse of federal healthcare program funds

False Claims Act violations

Anti-kickback violations

Medicaid beneficiary inducement to avoid seeking medically necessary care;

Stark Law violations

Criminal Health Care Fraud violations

Participating Providers will provide their employees with appropriate training or materials containing details about these regulations.

Whistleblowers/Non-Retaliation Federal and state laws provide whistleblower provisions that protect an individual who has reported an incident of fraud, in good faith. Under the law, a private citizen may bring a civil action for violations of the False Claims Act or equivalent state requirements on behalf of the government. Persons bringing whistleblower claims are granted protections under the law. Anyone who is fired, demoted, suspended, threatened, harassed, or in any other manner discriminated against by his or her employer because of certain legal reporting violations may be entitled to reinstatement with seniority, double back pay, interest, special damages, and attorney’s fees and costs sustained as a result of discriminatory treatment. Similarly, the PPS Policy strictly prohibits Participating Providers from retaliating against any person (s) who reports a compliance issue or concern, in good faith. Participating Providers, as

part of their respective compliance programs should have established policies regarding good faith reporting and non-retaliation.

Lines of Communication and Complaint Process The PPS Compliance Program recognizes that open lines of communication between the PPS Lead Compliance Officer and Participating Providers are critical to the success of DSRIP project objectives.

Reports may be communicated through the PPS’s website at www.nyp.org/pps,telephone hotline 1-888-308-4435, directly to the Participating Provider, or the PPS Lead Office of Corporate Compliance [insert #]. All DSRIP compliance issues reported directly to the Participating Provider must be immediately reported to the PPS Lead Compliance Officer.

Corrective Actions The PPS Lead has the authority and responsibility to review all reported DSRIP related compliance issues directly. The PPS Lead, through the PPS Lead Compliance Office, will review all reported DSRIP compliance issues, and where appropriate, recommend remediation and/or corrective action.

Responsibility: NYP PPS Executive Committee

Policy Date: Reviewed December 2015