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Department of Health and Human Services
Health Care Financing Administration
Operational Policy Letter #96
OPL99.096

You may download the main body of this OPL in either WordPerfect 6.1 or in PDF format viewable in Adobe Acrobat.

DATE: June 21, 1999

TO: All Medicare Managed Care Organizations

SUBJECT: Changes to the HCFA Managed Care Systems to Reflect the Risk Adjustment Payment Methodology

PURPOSE

The purpose of this OPL is to provide information regarding the changes that will be implemented in HCFA's managed care system to reflect the risk adjustment payment methodology mandated by the Balanced Budget Act of 1997 (BBA). Please note that the information regarding report and screen changes described in this document apply to all Managed Care Organizations (MCOs). Risk adjustment payment changes, however, apply only to members of Medicare+Choice (M+C) organizations. (See the section on Exclusions in this document for more specific information.)

Many of the changes described in the OPL have been shared with MCO representatives and the industry associations. As expected, the majority of the systems changes for CY2000 involve the Monthly Membership Report. There will also be minor revisions to the Plan Payment Report and to several online MCCOY rate and factor screens.

BACKGROUND

MCOs were notified regarding payment methodology changes resulting from the implementation of risk adjustment in the January 15, 1999 Advance Notice of Methodological Changes for the CY2000 M+C Payment Rates and in the March 1, 1999 Final Announcement of CY2000 M+C Payment Rates. The risk adjustment methodology described in these prior documents has not changed. This OPL focuses on how M+C payment information will appear beginning in CY2000 and presents the new version of the Monthly Membership Report.

For CY2000, risk adjustment is based on diagnostic data related to the inpatient hospital stays of M+C organization members. Additional data related to other medical services, e.g., outpatient, physician, etc., will be included as soon as collection methods are finalized and implemented. MCOs were required to submit inpatient hospital data (i.e., encounter data) beginning with July 1, 1997 discharges.

Risk adjustment factors will be calculated for each Medicare managed care and fee-for-service beneficiary. They will be used, along with the risk adjustment rate book and modified by applicable health statuses, to determine the risk adjustment capitated amount. A transition strategy will be utilized that involves blending the risk adjusted payment amounts with the risk demographic payment amounts. Based on the current schedule, this transition is expected to cover a 4-year period, after which full implementation of comprehensive risk adjustment will occur in CY2004.

SYSTEMS CHANGES

Overview

HCFA's managed care systems will be revised to compute monthly risk adjustment payments beginning with CY2000. These revisions are consistent with the method outlined in the January 15, 1999 Advance and in the March 1, 1999 Final Notices and include:

Exclusions

As stated previously, risk adjustment applies only to M+C organizations. For CY2000, some MCOs with Demonstration contracts are excluded from payment under risk adjustment. HCFA, however, may include some of these entities as soon as CY2001. MCOs with Cost or HCPP contracts will also be excluded from payment under risk adjustment, but risk adjustment rates will be reported to these organizations as "risk equivalent" rates. This will replace the current reporting of the "risk equivalent" demographic rates to the Cost and HCPP MCOs.

At the beneficiary-level, M+C organization members who are capitated at the Hospice or at the ESRD rate will be excluded from payment under risk adjustment. M+C organizations will receive the demographic payment applicable to these types of members.

Monthly Capitation Payments

CY2000 monthly payments to M+C organizations will consist of a blend of 90% demographic rate and 10% risk adjustment rate. The full demographic and risk adjusted rates will be computed at 100% for each member and then the appropriate blend percentage will be applied based on the transition schedule (see the Timeframes section for the 5-year schedule). It should be noted that monthly payments to M+C organizations will reflect ongoing, current-month and prospective-month membership. For example, the January 1, 2000 payment will reflect ongoing members and enrollments effective December 1, 1999 and January 1, 2000. Members enrolling December 1 will be capitated at 100% demographic rate for the month of December. Members enrolling January 1 and ongoing membership will be capitated at the blend of 90% demographic/10% risk adjustment beginning with the month of January.

Unlike the demographic rates, risk adjustment rates utilize a beneficiary-specific factor which is effective for a calendar year. The risk adjustment factor includes age group, gender, PIPDCG category and, if applicable, Medicaid and Previously Disabled statuses. This factor will not apply to members with ESRD and Hospice health statuses; i.e, payment will not reflect risk adjustment. In addition, institutional corrections will not be applied to the risk adjustment portion of the blended payment amount (they will continue to be applied to the demographic portion). Working Aged, if applicable, will impact both the demographic and the risk adjustment portions of the payment amount at the appropriate percentages.

Adjustments

Demographic payment adjustments (i.e., those applicable to the demographic portion of the blended payment amount) will be processed as they occur, to reflect changes in:

Risk adjusted adjustments (i.e., those applicable to the risk adjustment portion of the blended payment amount) will be processed as they occur, to reflect changes in:

NOTE: Institutional status is not applicable to the risk adjustment rates.

Some adjustments to the risk adjustment portion of the blended payment amount will not occur during the payment year (as the demographic adjustments do). Changes that impact the computation of the risk adjustment factor will be resolved through a reconciliation process which will occur after the end of the payment year. This means that for changes in the date of birth, gender, Medicaid status, Previously Disabled status and/or late submittal of encounter data, a new risk adjustment factor will be computed.

Reconciliation Process

The reconciliation process will be utilized until HCFA systems are able to process changes that impact the factors as they occur during the payment year. In the interim, the process will work as follows. Information that could result in risk adjustment factor changes will be collected during the payment year. This includes updates to:

NOTE: Medicaid status is applied prospectively to the risk adjustment rates; i.e., if the beneficiary is in this status for only one month during the encounter data collection period, it is applied during the entire payment year. In contrast, Medicaid status is applied concurrently to the demographic rates; i.e., if the beneficiary is in this status for only one month during the payment year, it is applied for only that one month during the payment year.

During the second quarter of the calendar year following the payment year, the factors for members impacted by such changes will be recalculated. This revised factor will be utilized in adjusting the previous calendar year's payments; i.e, the risk adjustment portion of the blended payment. Adjustment processing would be completed during the third quarter of the calendar year following the payment year.

REPORT CHANGES

For CY2000, the following reports will be revised to reflect pertinent risk adjustment information (see attached examples). Please note that, for the reports described below, these will be the only versions created. HCFA systems will not maintain M+C and non M+C reports. MCOs with Demonstration, Cost or HCPP contracts (i.e., non M+C organizations) will receive the revised monthly membership report and must utilize it to access their payment information.

1. Transaction Reply/Monthly Activity Report
There will be no changes to this report for CY2000. Note that the "AAPCC Rates" column will continue to contain demographic rate data, as it does today.

2. HCFA Plan Payment Report
The only change to this report is the deletion of the word "Demo" from "Demo Factor" (line F in section 3 - Health Status Adjustments to Prior Months). The information on this line of the report will now reflect both Demonstration and Risk Adjustment Factor changes.

3. Monthly Membership Report- Summary
The only change to this report is the deletion of the word "Demo" from adjustment reason code #23. This code will now reflect adjustments relating to both Demonstration factors and Risk Adjustment factors.

4. Monthly Membership Report- Detail
The Monthly Membership Report- Detail (MMR) will be revised and it will continue to be generated as a data file and as a formatted report.

4a. MMR - Data File
The data file will contain all of the current information relating to the demographic portion of the payment as well as that associated with the risk adjustment portion of the payment. There will be a Risk Adjustment Components section with indicators for Previous Disabled and Medicaid along with the PIPDCG Category. There will also be a Default Factor Indicator which will be set to "Y" for members for which a default factor was utilized. Risk Adjustment Factors for Part A and B will also be included, although both factors will be the same.

NOTE: Although the Part A and B factors are identical, the risk adjustment rates will differ. A Part B risk adjustment rate is computed to allow capitation of Part B-only members. HCFA's Office of the Actuary computes combined A/B/Aged/Disabled rates for each county. For CY2000, these rates are split by .4367 to derive the Part B rate and by .5633 to derive the Part A rate.

The MMR data file will contain the following payment information:

The MMR data file will only be provided in this format, even for non M+C organizations. For MCOs with Cost and HCPP contracts, all of the information presented above will be included in the file as "risk-equivalent" data. For MCOs with Demonstration contracts, no risk adjustment information will be provided. The applicable Demonstration payment rate data will be populated in the Blended Payment Rate fields.

4b. MMR - Formatted Report
The formatted report will include all of the information contained on the MMR- Data File. Due to space considerations, however, each member's prospective payment information will be displayed on three detail lines. Line one will include the member's identifying information along with the risk adjustment indicator and the 100% Part A and Part B demographic payment rates. Line two will contain the PIPDCG category, Part A and B risk adjustment factors and the 100% Part A and Part B risk adjustment rates. Line three will contain the Part A, Part B and Total blended payment amounts. Each member's adjustment payment information will be netted out and will be displayed on one line as blended payment amounts with the applicable reason code.

The MMR formatted report will only be provided in this version, even for non M+C organizations. For MCOs with Cost and HCPP contracts, the information will be presented as described above and will be "risk-equivalent" data. For MCOs with Demonstration contracts, no risk adjustment information will be included. The applicable Demonstration payment rate data will be populated in Line three.

5. Demographic Report
This report will continue to be produced in it's current format. The dollar amounts, however, will reflect the risk adjustment/demographic payment amounts.

SCREEN CHANGES

The following MCCOY online screens will be revised to reflect risk adjustment information (see attached examples).

1. View Rates by State and County Code (SCC)
This screen will be expanded to display risk adjustment rates for Part A and Part B by specified date, state and county code. Note that these rates will only be available for dates beginning 1/1/2000.

2.View Age-Sex Underwriting Factors
The contents of this screen will not change; only the title. It was formerly identified as "View AAPCC Demographic Cost Factors", which is incorrect.

3. View Risk Adjustment Default Factors
A new screen will be added to display the information from the Factors for New Enrollees table that was presented in the March 1, 1999 Final Announcement of CY2000 M+C Payment Rates. These are the rates that will be utilized when no risk adjustment factor information is available for a member. The screen will display the Base and Medicaid Add-on rates by gender, age group and date. Note that this screen will be unavailable for dates prior to 1/1/2000.

4. View Payment Calculation
This screen, which displays rates calculated based on input criteria, will be expanded. It will include risk adjustment "Part A factor" and "Part B factor" as input parameters and the Medicaid Flag item will be renamed "Demographic Medicaid Flag". Based on the items selected, the screen will display:

Note that for specified process months prior to 1/2000, the calculation will not include risk adjustment information.

5. View Factors
This screen will be revised to display factor information based on the user. The plan-level demonstration factor will be displayed if the member is enrolled in an associated demonstration organization. The beneficiary-level risk adjustment factor will be displayed if the member is enrolled in an M+C MCO. Security will prevent viewing of factor data other then that for a particular MCO's membership.

TIMEFRAMES

The following are important dates relating to the systems implementation of risk adjustment.

- CY2001 blend is 70%/30%,

- CY2002 blend is 45%/55%,

- CY2003 blend is 20%/80% and

- CY2004 is 100% comprehensive risk adjustment.

This OPL describes systems changes to be made in 1999 to implement risk adjustment for CY2000 payments. HCFA expects to refine this process during the transition period as the managed care systems are redesigned and the risk adjustment factor computation interface is solidified. Most of the current reports and screens will need to be updated to reflect comprehensive risk adjustment and to provide additional information as needs are identified.

CONTACT:

If you have questions regarding this OPL, please contact Kim Miegel (410-786-3311, KMIEGEL@HCFA.GOV) or Bob Fortenbaugh (410-786-6359, RFORTENBAUGH@HCFA.GOV).

This OPL was prepared by the Center for Health Plans and Providers.

Most of the attachments to this OPL are not yet available in softcopy. The item most critical to the MCOs is the data file format and the formatted report format of the Monthly Membership Report. These items are included as attachments with this OPL.

Attachments


Monthly Membership Report Format (19990329)

Field Name             Length       Location    Description

LINE #1 Prospective Payments

Filler                       3              1-3        Spaces

HIC                         12             4-15        Beneficiary's Health Insurance       
                                                       Claim Number

Surname                      7            16-22        Beneficiary's Surname

First Initial                1               23        Beneficiary's First Initial

Filler                       1               24        Space

Sex                          1               25        M = Male
                                                       F = Female

Filler                       1               26        Space

Date of Birth                8            27-34        Format of YYYYMMDD

Filler                       1               35        Space

Age Group                    4            36-39        Demographic Age Grouping

Filler                       1               40        Space

State & County Code          5            41-45        Beneficiary's State & County Code

Filler                       2            46-47        Spaces

Out of Area Indicator        1               48        Y = Out of Service Area

Filler                       2            49-50        Spaces

Part A Entitlement           1              51         Y = Entitled to Part A

Filler                       1              52         Space

Part B Entitlement           1              53         Y = Entitled to Part B

Filler                       1              54         Space

Health Status Indicators

Hospice                      1              55         Y = Hospice

Filler                       1              56         Space

ESRD                         1              57         Y = ESRD   

Filler                       1              58         Space

Working Aged                 1              59         Y = Working Aged

Filler                       1              60         Space

Institutional                1              61         Y = Institutional 

Filler                       1              62         Space

Nursing Home Certifiable     1              63         Y = Nursing Home Certifiable

Filler                       1              64         Space

Medicaid                     1              65         Y = Medicaid

Filler                       3           66-68         Spaces

Risk Adjusters Components

Previous Disabled            1              69         Y = Previous Disabled

Filler                       1              70         Space

Medicaid Add-on              1              71         Y = Medicaid Status during last               
                                                       Risk Adjuster encounter period

Filler                       1              72         Space

Default Factor Indicator     1              73         Y = Default Factor Used

Number of Part A Payment     2           74-75         Number of Payment Months         
     Months                                            Used in Calculation (Part A)
Number of Part BPayment      2           76-77         Number of Payment Months         
     Months                                            Used in Calculation (Part B)

Filler                       5           78-82         Spaces

Payment Start Date           6           83-88         YYYYMM of Payment Start Date

Filler                       1              89         Space

Payment End Date             6           90-95         YYYYMM of Payment End Date

Filler                       2           96-97         Spaces
 
Demographic Part A Dollars  10          98-107         Value up to $99,999.99                
      At 100 Percent                                   of Part A Payment        

Filler                       2         108-109         Spaces

Demographic Part B Dollars  10         110-119         Value up to $99,999.99
     At 100 Percent                                    of Part B Payment 
 
Filler                      13         120-132         Spaces

Monthly Membership Report Format (19990329)

Field Name               Length    Location  Description

LINE #2 Prospective Payments

Filler                       75           1-75         Spaces

PIP-DCG Category              2          76-77         Value of PID-DCG Category

Filler                        4          78-81         Spaces

Part A Risk Adjustment Factor 7          82-88         Value of Part A Risk Adjuster Factor  
                                                       used in Payment calculation

Filler                        1             89         Space 

Part B Risk Adjustment Factor 7          90-96         Value of Part B Risk Adjuster Factor  
                                                       used in Payment calculation

Filler                        1             97         Space

Risk Adjuster Part A Dollars 10         98-107         Value up to $99,999.99
       At 100 Percent                                  of Part A Payment

Filler                        1           108          Space

Risk Adjuster Part B Dollars 10       109-118          Value up to $99,999.99
       At 100 Percent                                  of Part B Payment

Filler                       14       119-132          Spaces


Monthly Membership Report Format (19990329)

Field Name              Length      Location       Description

LINE #3 Prospective Payments

Filler                     97          1-97         Spaces

Part A Blended Amount      10        98-107         Value up to $99,999.99
                                                     of Part A Payment

Filler                     2            109         Space

Part B Blended Amount     10        110-119         Value up to $99,999.99
                                                    of Part B Payment

Filler                     2        120-121         Spaces

Blended TOTAL Payment     10        122-131         Value up to $99,999.99
                                                                                             
Filler                     1            132         Space

Monthly Membership Data File
# Field Name Len Pos Description
1 Plan Number 5 1-5 Plan Number
2 Run Date 8 6-13 YYYYMMDD
3 Payment Date 6 14-19 YYYYMM
1 HIC 12 20-31  
2 Surname 7 32-38  
3 First Initial 1 39-39  
4 Sex 1 40-40 M = Male, F = Female
5 Date of Birth 8 41-48 YYYYMMDD
6 Age Group 4 49-52  
7 State & County Code 5 53-57  
8 Out of Area Indicator 1 58-58 Y = Out of Area
Always Spaces on Adjustment
9 Part A Entitlement 1 59-59 Y = Entitled to Part A
10 Part B Entitlement 1 60-60 Y = Entitled to Part B
Health Status Indicators:
11 Hospice 1 61-61 Y = Hospice
Always Spaces on Adjustment
12 ESRD 1 62-62 Y = ESRD
Always Spaces on Adjustment
13 Working Aged 1 63-63 Y = Working Aged
14 Institutional 1 64-64

Y = Institutional
Always Spaces on Adjustment

15 NHC 1 65-65 Y = Nursing Home
Certifiable
Always Spaces on Adjustment
16 Medicaid 1 66-66 Y = Medicaid Status
Always Spaces on Adjustment
Risk Adjuster Components:
17 Previous Disable 1 67-67 Y = Original Reason of Entitlement
Always Spaces on Adjustment
18 Medicaid Add-on 1 68-68 Y = Entitled to Medicaid
Add-on
Always Spaces on Adjustment
19 PIP-DCG Category 2 69-70 PIP-DCG Category
Always Spaces on Adjustment
20 Default Factor Indicator 1 71-71 Y = Default Factor Used
Always Spaces on Adjustment
21 Risk Adjuster Factor A 7 72-78 NN.DDDD
22 Risk Adjuster Factor B 7 79-85 NN.DDDD
23 Number of Paymt/Adjustmt Months Part A 2 86-87 99
24 Number of Paymt/Adjustmt Months Part B 2 88-89 99
25 Adjustment Reason Code 2 90-91 99
Always Spaces on Payment
26 Paymt/Adjustmt Start Date 8 92-99 YYYYMMDD
27 Paymt/Adjustmt End Date 8 100-107 YYYYMMDD
28 Demographic Paymt/Adjustmt Rate A 9 108-116 -$$$$$.¢¢
29 Demographic Paymt/Adjustmt Rate B 9 117-125 -$$$$$.¢¢
30 Risk Adjuster Paymt/Adjustmt Rate A 9 126-134 -$$$$$.¢¢
31 Risk Adjuster Paymt/Adjustmt Rate B 9 135-143 -$$$$$.¢¢
32 Blended Paymt/Adjustmt Rate A 9 144-152 -$$$$$.¢¢
33 Blended Paymt/Adjustmt Rate B 9 153-161 -$$$$$.¢¢
34 Total Paymt/Adjustmt 9 162-170 -$$$$$.¢¢

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Last Updated June 23, 1999

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