HomeMy WebLinkAboutRESOLUTION 2002-71Suggested by: Administration
City of Kenai
RESOLUTION NO. 2002-71
A RESOLUTION OF THE COUNCIL OF THE CITY OF KENAI, ALASKA SUPPORTING THE
DEVELOPMENT OF A DENTAL CLINIC IN KENAI.
WHEREAS, Central Peninsula Heath Centers Inc., a nonprofit entity that provides health care
services to under and uninsured residents of the central Kenai Peninsula including Medicaid
eligible patients, intends to expand its operations to include dental services by establishing a
new clinic in Kenai; and,
WHEREAS the State of Alaska has agreed to provide financing to Central Peninsula Health
Centers Inc. through the disproportionate share hospital (DHS) payment program; and,
WHEREAS, the DHS program requires local participation in the form of an intergovernmental
transfer of funds to the State; and,
WHEREAS, the State of Alaska Department of Health and Social Services (DHSS), has
determined that Medicaid regulations allow the local participation funding to be returned to the
local government along with a reasonable administrative fee; and,
WHEREAS, due to their deadline for budget development, the State of Alaska DHSS is seeking
immediate approval from the City of Kenai to pursue this project; and,
WHEREAS, the City administration is performing due diligence work with the goal of
determining, and if possible eliminating, the risks of City involvement in this project; and,
WHEREAS, at this time the administration recognizes that Medicaid regulations are extremely
complex and that there are risks to the City of Kenai that are not completely quantifiable.
NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF KENAI, ALASKA,
that the City of Kenai supports the Central Peninsula Health Centers Inc. dental clinic project
and directs the administration to continue its due diligence work and to bring an appropriation
ordinance before the council so that the council can aPprove or reject the City's financial
participation in the project.
PASSED BY THE COUNCIL OF THE CITY OF KENAI, ALASKA, this 16th day of October, 2002.
~ "
./'~OHN J~~I'I~LIAMS, MAYOR
ATTEST: ~/ ~
Carol L. Freas, ~ity C~erk
Approved by Finance' ~
(10/11/2002) jc
DEPT. OF HEALTH AND SOCIAL SERVICES
OFFICE OF THE COMMISSIONER
P.O. BOX 110601
JUNEAU, ALASKA 99811-0601
PHONE: (907) 465-3030
FAX: (907) 465-3068
Honorable John Williams, Mayor
Citv o f Kenai
o
210 Fidalgo Avenue, Suite 200
Kenai, Alaska 99611
September 16, 2002_
; :.":e !8
Dear Mayor Williams'
Thank you for your interest in the Alaska Medicaid Program, support of the Disproportionate
Share Program (DSH), and the Department of Health and Social Services' efforts to facilitate a
DSH payment to Central Peninsula General Hospital to provide Medicaid dental services in the
Kenai area.
Often, difficult funding issues arise while the legislature contemplates fiscal year appropriations.
This year, an even greater challenge is unfolding as the legislature debates the use of new taxes to
fund services. The involvement with the DSH program and its contribution to the non-federal
Medicaid funding is a major factor in keeping the level of services offered under Alaska's
Medicaid Program in place for Medicaid-eligible persons.
In working through the concept of Intergovemmental Transfers (IGT), we understand there are
concerns about the IGT, which provides the general fund match amount, and concerns about the
IGT from the public hospital to the local government. Health care financing operates under many
complicated laws and regulations, so such concerns a~'~ reasonable and under~tandabl~. This is
especially true with respect to federal funding of Medicaid.
Federal law, specifically Social Security Act 1903(w)(6)(A), indicates that the Secretary of the
U.S. Department of Health and Human Services may not restrict a state's use of funds where
such funds are transferred from units of government within a state as the non-federal share of
expenditures.
The Division of Medical Assistance has worked with the Department of Law to draft the
Intergovemmental Transfer agreement and deems the agreements to be allowable and consistent
with the intent of this law.
The Department of Health and Social Services (DHSS) has worked on many fronts to improve
access to Medicaid dental services. This DSH payment provides important funding to the
Cottonwood Clinic, which is necessary to establish Medicaid dental access in the Kenai area.
06-F38LH
~ pdnted on recycled paper
CITY OF KENAI
210 FIDALGO AVE., SUITE 200 KENAI, ALASKA 99611-7794
TELEPHONE 907-283-7535
FAX 907-283-3014 ~
1992
MEMORANDUM
TO:
F} OM£
DATE'
Rte
Mayor John J. Williams and City Council Members
Cary R. Graves, City Attorney and Larry Semmens, Finance Director
October 10, 2002
Cottonwood Health Clinic / DSH Program
The Mayor requested a memorandum regarding the proposal by the State's Division of Medical
Assistance to fund part of Cottonwood Health Clinic. The clinic, as we understand it, would
provide dental care to Medicaid recipients and indigent people without access to dental care.
The memorandum focuses on the funding method proposed by the State. It is not meant to
discuss the public policy considerations of whether the City should support the idea of the clinic.
What is the DSH program?
DSH is an acronym for the Disproportionate Share Hospital Payment Program. The program is
mn by Medicaid (specifically an agency called the Health Care Financing Administration) and is
intended to compensate those hospitals that serve a large share of Medicaid and uninsured
patients. The idea is that because of low Medicaid reimbursement rates, and uninsured and poor
patients, hospitals with large numbers of those patients lost money because of the
uncompensated health care.
The program was started in the early 1980's, and grew slowly until the 90's when states realized
that a unique "matching grants" segment program allowed them to get extra Medicaid money
without providing a real matching grant. DSH spending grew from $1.4 billion in 1990 to $15
billion in 1996. The concept is called an IGT (Intergovernmental Transfer). Here's how it
works.
Step 1' The State receives an IGT from a local government. In this example, it is $10 million.
Step 2' The State makes a $12 million payment to a DSH eligible hospital. The $12 million
consists of the original $10 million donation and $2 million in an extra DSH payment. The
hospital uses part of the $12 million to refund the original $10 million IGT to the local
government.
Mayor John J. Williams and City Council Members
October 10, 2002
Page 3 of 3
dental care; 3) $25,000 goes to the City of Kenai as an administrative fee; and 4) $25,000 goes to
CPGH as an administrative fee.
One concern we had was the fact that the City was in essence receiving $25,000 in FFP money
that would go to non-Medicaid purposes. The answer is that while the federal government may
not like it, it does appear to be legal. The federal government is aware of such expenditures and
has declined to prohibit them. Vol. 66 Federal Register 3164-65 (2001).
Another concern is that the normal definition of a "match" does not apply. While the City's
contribution of $795,000 is critical to obtaining the $1.1 million of federal funding, no part of the
City's money actually ends up in the project.
Conclusion- The proposal is probably legal under Medicaid regulations. While probably legal,
it is an aggressive interpretation of the federal regulations and could be determined to be illegal.
If the federal government decides the plan is not allowed under the Medicaid roles, it will not
reimburse the State the $1,099,702. In that case, the State could seek to recoup its money from
Central Peninsula General Hospital. Central Peninsula General Hospital would then seek to
recoup its $819,785 from the City. If that happened, the City would be out that money with no
real recourse.
We asked if the State would indemnify the City against such a possibility. The State personnel
indicated it would not. My understanding is that the State will give a verbal promise to not
recoup the money, but it will not put that in writing. There is some question whether it could
lawfully indemnify us, or promise not to recoup the money in such a situation.
We also asked for an opinion from the Attorney General's Office that the State's proposal is
legal under Medicaid roles. We have not yet been provided with such an opinion.
In short, there is a risk that if the federal government decides the proposal is not allowable under
Medicaid roles the City could lose the $794,785 it granted to the Division of Medical Assistance.
We cannot quantify the likelihood of such an event. Given the large amount of the City's money
involved ($794,785), we are uncomfortable with the risk unless the State gives us adequate
assurance of indemnification or the federal government indicates the program is allowable under
the Medicaid roles.
Please let us know if you have any questions.
CRG/sp