Texas Health Transformation Program Overview
The Texas Health Transformation and Quality Improvement Program (THTQIP), initiated through the 1115 waiver, consists of two pools - Uncompensated Care (UC) Pool and Delivery System Reform Incentive Payment (DSRIP) Pool. This program aims to support providers in enhancing access to care, improving quality, and reforming the healthcare delivery system. The waiver extension addresses the current public health emergency, enabling Texas to respond to the pandemic while transitioning through DSRIP. The extension provides a 10-year demonstration period starting from October 1, 2021. Additionally, the PHP-CCP under the waiver extension offers reimbursement for healthcare services to uninsured patients, benefitting various local health entities in the state.
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Presentation Transcript
1115 Waiver & Public Health Providers Charity Care Program (PHP-CCP) June 9, 2021
Initial 1115(a) demonstration, entitled Texas Healthcare Transformation and Quality Improvement Program (THTQIP): Effective Date: December 12, 2011 Expiration Date: September 30, 2022 THTQIP included two pools: Uncompensated Care (UC) Pool Delivery System Reform Incentive Payment (DSRIP) Pool Help defray the actual uncompensated care costs incurred by hospitals and other eligible providers for serving uninsured individuals in the state Provides incentive payments to providers to support their efforts to enhance access to care, improve quality, and reform the health care delivery system 3
1115 Waiver Extension Rationale: The extension will address the current public health emergency. The extension adequately enables Texas to respond to the pandemic while also working with providers through the DSRIP transition. Approval and Duration: CMS s January 2021 approval of HHSC s request to extend the waiver provides Texas a 10-year demonstration extension beginning October 1, 2021 and ending September 30, 2030. CMS granted the State s request to exempt the extension application from public notice and comment requirements. 4
1115 Waiver Extension: New Pool Public Health Provider Charity Care Program (PHP-CCP) PHP-CCP is designed to allow qualified providers to receive reimbursement for the cost of delivering healthcare services, including behavioral health services, vaccine services , and other preventative services when those costs are to an uninsured patient and there is no expectation of reimbursement. The program is in the best interest of Local Health Departments and other local health entities because they will have a source to continue receiving reimbursement for the uncompensated costs for delivering services to people outside of the Medicaid program. 5
PHP-CCP Eligibility Established under the Texas Health and Safety Code Chapters 533 and 534 : Community Mental Health Clinics (CMHCs), Community Centers, Local Behavioral Health Authorities (LBHAs), and Local Mental Health Authorities (LMHAs), Local Health Departments (LHDs) and Public Health Districts (PHDs) established under the Texas Health and Safety Code Chapter 121. 6
Waiver Extension Timeline Year 1 (FY 2022) PHP-CCP (where the patient is unable to pay), and Bad Debt (where payment was expected but not received).* Year 2 (FY 2023) Pool will transition to charity care only (i.e., PHP-CCP).* Year 3 (FY 2024) Program will be resized based upon actual charity care cost data from Year 2. *The first 2 years will be capped at $500 million 7
Waiver Rescission In April of 2021, CMS rescinded the extension. CMS contends that Texas did not hold the normal public notice process regarding their plans to renew the uncompensated care funding and did not provide sufficient reasoning for skipping that step. Furthermore, CMS maintains that Texas s request did not adequately explain: What the extension request had to do with the pandemic, Why the circumstances constituted an emergency, or Why a delay would compromise the demonstration or beneficiary interests. 8
Response to Waiver Rescission On May 14, 2021: Texas Attorney General Ken Paxton filed suit against the Biden Administration for the loss of the Medicaid waiver. On May 28, 2021, HHSC posted the Extension Application for the waiver. The extension request reflects the same terms and conditions agreed to and approved by CMS on January 15, 2021. The extension request is for approximately 10 years, which will allow the 1115 waiver authority to run through 2030. 9
