Volume XXXI, Number 3
March 2016

QIPP Program Likely to be Postponed

We have reported in previous issues of THCA Notes that the “Minimum Payment Amount Program” (MPAP) system that was implemented when nursing facilities were carved into Medicaid Managed Care on March 1, 2015 was, by Legislative directive, going to transition to the Quality Incentive Payment Program (QIPP), a program containing performance-based initiatives. The targeted implementation date of this new system was September 1, 2016. THCA has worked closely with HHSC in the development of this new program, and as a result of that collaborative effort, a “concept paper” was developed by the agency and submitted to the Centers for Medicare & Medicaid Services (CMS) for its review and feedback.

On Wednesday, February 24th, HHSC executive leadership convened a conference call to update interested parties on recent developments regarding CMS’ concerns with the QIPP program. On that call, it was communicated that CMS’ main concerns with the program were:

  • While intergovernmental transfers (IGT) are an acceptable source of the state share of payments under QIPP, CMS has expressed concerns about the allowability of IGT Responsibility Agreements and about participation in QIPP being limited to nursing facilities (NFs) with a source of IGT.
  • Alignment of quality metrics and valuations; QIPP should not pay for activities NFs should already be doing (including covering the Medicaid shortfall).
  • IGT associated with failed metrics cannot be returned to the source IGT entity.

HHSC further communicated that if these CMS concerns are not resolved by March 11, 2016, it will not be possible to implement QIPP on the targeted date of September 1, 2016. If that occurs, HHSC stated that the following will happen:

  • The Minimum Payment Amounts Program (MPAP) will be extended for six months (e.g., through February 28, 2017) at 100 percent for existing MPAP participants only. Given the issues raised by CMS about QIPP, HHSC will not enroll new participants in the MPAP program.
  • HHSC will continue working with CMS with a goal of resolving their concerns in time to enable a March 1, 2017, rollout of QIPP.
  • MCOs will be advised to halt their work reviewing QIPP proposals and to submit existing proposals and supporting documentation to HHSC.
  • HHSC will store the submitted proposals pending resolution of CMS concerns.

The development of the QIPP has, by nature, been a fluid, ever-evolving process and all indications are that this will continue until the unresolved issues with CMS have been addressed. We will keep you apprised of further developments as they occur.

President’s Report


 Legislative Update


 Commitment to Care

If you have any questions about the THCA Commitment to Care Initiative or would like to share your facilities successes please contact Gloria Bean-Williams by email or call (512) 458-1257.


State / THCA News

  • QIPP Program Likely to be Postponed


National / AHCA News


Announcements & Recognition

2016 THCA Membership Directory and Resource Guide COMING SOON!

Hard copies scheduled to be mailed out later this month, with a digital copy to be posted on our website mid-April!

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