Reimbursement Unit

% of annual fee schedule updates that are posted for public comment 30 days prior to the effective date of the rate change

33.3%SFY 2020

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  • Burns and Associates Inc. (consultants)
  • Medicaid Providers
  • Trade associations such as Vermont Association of Hospitals and Health Systems (VAHHS), VNA’s of Vermont and Bi-State, etc.
  • DXC 
  • DVHA Policy Unit
  • DVHA Business Office
  • DVHA Program Integrity Unit
  • Legislature
  • DVHA/AHS Management
  • Medicare – Release of fee schedules and guidelines


Story Behind the Curve

During the 2016 legislative session the Reimbursement Unit received a lot of push back from hospitals related to its proposed policy to eliminate Provider Based Billing (PBB), with specific complaints on the length of the public comment period. In this case, public comment was posted to the Global Commitment Register on February 13, 2016 and slated to run until February 29th (Leap Year), a total of 17 days. The new policy was to have been implemented on March 1, 2016.

While Vermont Medicaid does not have a specific policy related to the length of a public comment period, it has followed Medicare guidelines which states public comment should be posted for a "reasonable" length of time. As a result, the Reimbursement Unit has established the goal that 100% of annual fee schedule/policy change updates will be posted for public comment 30 days prior to the effective date of the rate or policy change. 

It is important to stakeholders to be able to analyze and review proposed changes prior to their implementation so that they can familiarize themselves with the changes and analyze how it effects their operations. It also gives stakeholders the opportunity to be engaged in the process and provide feedback to the State. Medicaid Reimbursement appreciates the benefits of being able to work collaboratively with partners and stakeholders so that we can all work together effectively to provide the best health care possible at a reasonable cost to Vermont residents. 

For 2020, the target of 30 day public notice prior to rate updates was not met for the following reasons 1) waiting for State Budget to be signed and 2) rate modeling not completed in a timely manner allowing for PBR completion and posting of public comment to meet our 30 day goal.  We will continue with our efforts to meet this goal in the future.

Last updated:  07/15/2020

Author:  Reimbursement Unit


There are many challenges to the Reimbursement Unit meeting the goal of posting public comment 30 days prior to the effective date for a fee schedule/policy/PPS change update. Some of those barriers are as follows:

  • Obtaining timely feedback and consensus from stakeholders on proposed changes
  • Due to competing projects, the availability of contractor to pull data, model new rates and provide fiscal impact for PBR completion
  • Having clear and concise language in legislative directives
  • Having enough time to review and model rate/policy changes prior to legislatively directed implementation dates
  • Extended legislative sessions
  • Length of time needed to make system changes to MMIS
  • Complexity of proposed changes

One of the strategies being used by Medicaid Reimbursement to meet our goal is to engage with stakeholders earlier in the update process. As an example, starting in August 2017 we engaged with stakeholders on the update to the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) fee schedule for a proposed January 1, 2018 implementation date. Parties engaged in the conversations included the Home Medical Equipment and Services Association of New England (HOMES), representatives from the provider community, state employees representing various DVHA units and consultants engaged by the State. During the August meeting DVHA informed stakeholders of their intent to update the VT Medicaid DMEPOS fee schedule to more align with Medicare policies and rates and invited their input in the process including feedback on proposals.

Since the fee schedule had not been updated in about 10 years and includes numerous distinct classes of items, DVHA/Consultants laid out and shared a plan to update in a phased approach. Phase 1 of the update was scheduled for January 1, 2018 with additional classes of items to follow in a subsequent Phase 2 update. Over the ensuing months data was gathered and analyzed and preliminary models created and shared. Since DVHA’s new methodology is to benchmark to Medicare rates, the model could not be finalized and shared with stakeholders until late December because Medicare issued guidelines to States using their DMEPOS fee schedule around the second week of December. 

Other strategies being used are:

  1. Gathering all units/individuals involved in the PBR process to attend an informational session with the intent of explaining the changes (e.g. policy, methodology) included in the update including fiscal impact.  Fiscal impact and other appropriate information is shared prior to meeting so that individuals can come prepared with any questions they may have.  The intent is to have all PBR signers well informed on the details of the update by the time their signature is required.
  2. Informing our DXC partners as soon as MMIS system changes are identified and working with them to make sure that any system changes needed can be completed by the effective date of the change.
  3. For updates to payment methodologies that are complex in nature such as those that include major policy and/or system changes completing the update in different phases over a pre-determined period instead of a one-time update.
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