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ACCS and ERC Rate Setting

Phase 1: Bring the ACCS and ERC reimbursement rates up to today’s operating cost.

As indicated in the State Provider Rate Study below, ACCS and ERC reimbursement rates are significantly lower than cost. Bringing reimbursement rates up to today’s operating cost is essential to the continued operation of the LTC facilities. Without adequate funding levels existing facilities may not be able to sustain operational loses as evidenced by the many closures since 2020. Additionally, investors could find it difficult to secure construction funding for new facilities from lending institutions if incomes do not cover dept and operating cost.


STATUTORY LANGUAGE:

Act 185 of 2022, Sec. E.334:

SPECIFIC HOME- AND COMMUNITY-BASED SERVICE PROVIDER RATE STUDY; REPORT

  • On or before February 15, 2023, the Department of Vermont Health Access shall report the results of its rate study to the House Committees on Human Services and on Appropriations and the Senate Committees on Health and Welfare and on Appropriations.
  • The Department of Vermont Health Access, in collaboration with the Department of Disabilities, Aging, and Independent Living, shall conduct a rate study of the Medicaid reimbursement rates paid for adult day, adult day rehabilitation, personal care, and homemaker services.

DVHA engaged a contractor, the Burns & Associates division of Health Management Associates (HMA-Burns), to conduct each rate study. DVHA and DAIL worked together with HMA-Burns.

The Tables below summarize the additional State funding needed to bring the current State reimbursement rates for the various services reviewed to a cost covering level.

Adult Day and Adult Day Rehabilitation Services

ServiceCurrent Rate Per HourRate Per Hour from StudyPercent IncreaseEstimated Total Required to Fund Increase
Adult Day Health$18.60$21.3315%$1,060,807

Using a moving average smooths large swings in the data (2020 and 2021) due to volatile events such as pandemics and effects of war while representing the latest data and direction.

Choices for Care Home Health Services

ServiceCurrent Rate Per HourRate Per Hour from StudyPercent IncreaseEstimated Total Required to Fund Increase
Personal Care Service alone$33.32$50.4051%$6,055,146
Homemaker Service alone$33.32$50.4051%$664,342
Respite/Companionship Service alone$26.72$50.4089%$1,403,158
Total:  Choices for Care $8,122,646

Assistive Community Care Services (ACCS) and Enhanced Residential Care Services (ERC)

ServiceCurrent Per Diem RatePer Diem Rate from StudyPercent IncreaseEstimated Total Required to Fund Increase
ACCS Only$47.25$84.6679%$13.0 million
ERC Level 1 (includes ACCS rate above)$114.81$129.9913%$8.7 million for all three ERC levels combined
ERC Level 2 (includes ACCS rate above)$123.24$168.4337%
ERC Level 3 (includes ACCS rate above)$131.71$210.8160%
Total for ACCS and ERC Services   $21.7 Million

Total Increase for all Services                                                                                                                    $30,883,453

The entire HMA-Burns report can be found here:

Specific-Home-And-Community-Based-Service-Provider-Rate-Study-Report-2023-02-06.pdf

Report was presented on 2/15/2023 to:

The VT House Committee on Human Services

The VT House and Senate Committee on Appropriations

The VT Senate Committee on Health and Welfare


Sustainable ACCS and ERC Annual Support

Phase 2: Bring financial stability to future reimbursement rates.

State Rate compensation stability is essential i.e., Annual sustainable State compensation rates covering ACCS and ERC Medicaid cost to ensure facility investors can secure construction financing and operators can continue to provide quality services.

Two possible methods to establish annual compensation rate levels.

  • Method 1: Use of the Consumer Price Index (CPI)

Use of the CPI can be used by State officials to establish a sustainable method of setting the ACCS and ERC yearly reimbursement rates.

The US Bureau of Labor Statistics provides CPI data on a regional basis for certain services. Below is a chart indicating the CPI history of All services and Medical Care Services for the Bureau’s Northeast Region States. Specific Bureau Medical services level data is not available at a VT State level.

Chart 32, Northeast CPI, All and Med Items

Chart 33, Northeast CPI, 3y moving average and VT State Increases

Using a moving average smooths large swings in the data due to volatile events such as pandemics and effects of war while representing the latest data and direction


Method 2; Use Annual average % Medicaid rate change used for VT Nursing Homes

Nursing Home compensation rates are set annually and are established thru State and Federal regulations.

Another method of establishing rates for Assisted Living and Residence Care Homes is to apply the average % change in the Nursing Home rates as the change for the other LTC facilities. It would not be prudent to apply the actual Nursing Home compensation rate as their cost are greater than the Assisted Living and Residence Care Homes, especially in administrative and Nursing Staff requirements.

Listed below are the Nursing Home Rates for 2022 and 2023, and on the bottom the existing and proposed ACCS and ERC rates, and a comparison of the NH and ACCS/ERC rates. The NH Rates difference between 2022 and 2023 averaged increase is 8.5%. This increase is more than twice the 3.6% CPI increase for Northeast Medical Care Services.

Medicaid Rates for VT Nursing Homes


“It was once said that the moral test of government is how that government treats those who are in the dawn of life, the children; those who are in the twilight of life, the elderly; and those who are in the shadows of life, the sick, the needy and the handicapped.” ~ Hubert H. Humphrey