The Oceana County Medical Care Facility (OCMCF) board and administrative staff faced several difficult decisions to align with upcoming state and federal mandates, which were discussed extensively at the most recent board meeting on Aug. 24.
Room rates will increase for residents staying under private pay, going from $485 to $520 a day, roughly estimated to cost residents and their families $1,000 extra per month. After reviewing the resolution, board member Larry VanSickle asked, “What has transpired to make us think that the Medicaid rate is going to climb that high?”
The answer was given by OCMCF Financial Controller Cindy Leone, who explained the changes coming to the payment of direct care wages (DCW), which will soon only be paid into healthcare staff treating Medicaid patients. The direct reimbursement would put about $23 extra into the Medicaid rate, putting the per-person price at $500.39, for which financial advice is to charge private pay patients $20 above the Medicaid rate.
As it stands, only seven current residents are on private pay, though the facility has had up to nine at a time. Of those seven, only two came into the facility with the intention to continue private pay throughout their time, with most either on private hospice or hoping to transition to Medicaid. Leone assured that this would be "very low impact for the total population that we currently have charging $520,” but acknowledged that "it would be a humongous impact if we didn’t get [the private pay rate] above that Medicaid rate, because it affects 84% of our current population.”
Leone also reminded the board that this would put OCMCF in line with other medical care facilities in Michigan. “We’re not an outlier by any means.”
The decision to approve the private pay increase was not one the administrators and staff made lightly. Said VanSickle, “I’m disappointed that we find ourselves in this spot… the idea that [the state of Michigan] look at it like ‘just charge more money. You can get it. The people who need to be in there, they’ll pay it.’ You know, I don’t like that scenario when they can back you into a corner, and we don’t have a choice.”
Impacted residents and families are expected to be apprised of the increase, which will be effective Nov. 1.
The board was also alerted to major HIPAA compliance changes, which focus on more robust cybersecurity regulations and measures. Administrator Sally Choponis described this change as the “most significant HIPAA change in security rules in over 20 years.” Some highlights of this ruling include mandatory cybersecurity safeguards such as encryption and multi-factor authentication, greater oversight of business associates and vendors, and greater accountability on board and leadership’s part to comply with these new measures and managing risk assessments.
As there was forewarning of this imminent ruling, OCMCF already has many of these modifications in place or are working towards them. Common Angle - OCMCF’s IT services provider - likewise, already has several of the required safeguards in place, such as proactive measures against phishing scams. Choponis also assured that, when she took on the position, her intention was to increase focus “on documentation, on risk assessments, on vulnerability testing and incident response planning,” where it concerns the facility and residents’ safety.
Said Choponis of the direction the facility is taking and the importance of implementing these safeguards, “It’s actually a scary world we live in. As an administrator, I’m looking at top cybersecurity risks, I’m looking at assessments, like I had mentioned, and this tight oversight of it. Because at the end of the day, we’re trying to protect all our residents’ information, but simultaneously protecting ourselves as well as a business.”
Choponis also informed the board of a decision made to apply to decertify extra beds at the facility in the interest of avoiding losing a greater number of beds altogether. As it stands currently, OCMCF has 12 off-line beds that are not in service, which had previously been registered to double rooms. The facility has removed still-certified beds to transition to private rooms for resident privacy and marketability, putting these beds out of commission for an indeterminate time. Previous discussions with the board regarding the beds have revealed that returning them to full use would pose challenges for the facility to maintain staffing, privacy and space.
The imminent problem these off-line beds cause, however, is that - should they remain off-line - by Oct. 1, regulations would require the beds [to] be counted in the census regardless of use, or the rooms they are associated with be taken off-line fully.
The risks associated with either scenario were determined detrimental to the facility. Should the beds remain off-line, the 12 other beds associated with the previous double rooms would suffer the same fate, for a total of 24 off-line beds. As Choponis explained, “The proposal states that if you take one bed off[-line] and it's a dual room, you must take both. You can’t isolate a room.”
Should the beds be put on-line, the facility would have 115 beds to ensure 85% occupancy, and while they have been able to maintain 85% occupancy for 103 beds, the administration is unsure the same could be done with 115. Also considerable is that, with a greater occupancy of Medicaid patients, the facility would also have to hire additional staff to maintain compliance with Medicaid standards.
Choponis explained that the decision was made considering the previous board discussions, ongoing staffing constraints, and the Medicaid-heavy payer mix of residents, “I submitted the application to protect the facility from a larger financial loss and give the board the best path forward under the new ruling.”
Facing the impending application deadline, however, there was no time to bring the decision forward to a vote. Assured Choponis, “I felt that fiduciary responsibility and, therefore, my action was done in good faith leadership, rather than trying to circumvent the board.”
That being said, there is no ruling on whether or not the decertification will be approved. VanSickle asked if the decertified beds could be regained in the future. Board Chair Linda East responded by discussing her own research, concluding that the future reapplication of decertified beds was uncertain. East also questioned the facility’s ability to maintain an 85% census of 115 beds and the requisite staff to service the greater population. She also made it clear that, considering the cuts coming to Medicaid state funding in January, it is not worthwhile to risk any further Medicaid reimbursements with low staffing or bed census.
As summarized by VanSickle, “The only option is to preserve the 12 or lose 24. And I think we owe it to the community to keep as many beds open for people that we can.”
VanSickle also proposed that the board vote to support Choponis’ move, saying, “I think you made the right decision to keep the beds… we could support the move you made, because I think that was the right move for the community.”
Following which, the board unanimously supported the decertification of the 12 off-line beds to preserve the attached rooms.
Several third-party surveys were conducted at the end of July and beginning of August, which reported happy staff, residents and their families. There were a handful of low-level health and safety concerns, such as sticky fire doors, flagged by surveys. Administration assured the board that these concerns are being addressed, if they weren’t already prior to the survey. One positive survey result highlighted by OCMCF was the quality of food served at the facility. As such, Choponis focused the facility’s “Spotlight of Excellence” on Caitlin Salliotte, a dietary aide at the facility, for “[demonstrating] exceptional leadership in professionalism, and remained calm, confident and organized as she assisted throughout the survey process.”
Choponis also complimented Salliotte’s “ability to maintain composure under pressure, which helped ensure that the dietary department was well prepared and presented with excellence.”
Decision papers for kitchen drain, grease trap repairs and the replacement of the kitchen’s HVAC system were presented and approved by the board. The drain and grease trap repairs will be done by Andy Egan Company for $34,369. The direction to go with Andy Egan for the project was reassuring to Choponis, as the company has done similar repairs in hospitals and is “going to be cognizant of infection control and other concerns that we have as a healthcare facility.”
The board approved the decision, with the added requirement that Buildings Management Consultant Clark Kelly monitor time and material management, as well as approvals for any change orders.
The kitchen HVAC replacement will come from Premier Heating and Cooling for $34,850. This quote is inclusive for the entire project save for wiring the unit to the building’s automation controls, which will be completed by Enertemp. The quote does, however, include the cost of the crane, which will help install the unit.
