We know there is a lot of information coming your way right now and things could get a little muddled up. One place we don't want you to struggle is knowing how to get paid! To help we have compiled this is brief description of the structure and a step-by-step process for receiving your organization's distribution payments for Medicaid Transformation milestones and deliverables.
And for those of you who want all the nitty-gritty details, you will find a thorough Q&A section farther below. If you have a question not addressed here, please don't hesitate to contact us and we will get it answered as quickly as possible.
Who is Paying Me?
The Health Care Authority (HCA) has contracted with Public Consulting Group (PCG) and has structured the MTP’s financial administration through a Financial Executor (FE) Portal, where funds will be held until the BHT Board approves payments for distribution each month.
PCG will also provide providing banking and accounting supportsupport for DSRIP incentive dollars, distribute earned funds through the Financial Executor Portal (FE Portal), submit fund distribution reports to the state, and develop and distribute budget forms to participating providers for receipt of incentive funds.
Registering with the FE Portal is a prerequisite for receiving payment dollars. However, registration with the FE Portal does not guarantee that you will receive a payment. Funding allocations will be approved by the BHT Board on a monthly basis.
The FE Portal conducts batch uploads on the 15th of every month. BHT will send the FE Portal all the Partner information we have collected by that time.
Steps to Get Paid
- BHT enters your organization's details into the FE Portal using the Organization Name and EIN number you supplied on the W-9.
- Financial Executor verifies provider names and EINs to ensure they match what is on file with the IRS. It may take up to two working days to verify EINs.
- If they do not match, it will be reflected in the FE Portal and ACHs must contact organizations to correct it and/or refer organizations to the Financial Executor who will provide necessary assistance.
- If the If the EIN and organization name match, you will receive an automated email containing information about how to register yourself in the FE Portal.
- You will execute (click-through) a Standard Partnership Agreement
- You register in the FE Portal, completing bank information (first time registering). You can then add and assign permission to additional users within your organization in the Admin > User Management tab.
For more detailed directions in video form, here is a link to a recorded training webinar. This training includes information on first time registration, how to accept and register with another ACH, how to add a user, and how to switch bank accounts.
How often does BHT to add providers to the FE Portal?
BHT may add providers at any time throughout the course of the demonstration. However, batch uploads will occur on the 15th of each month, through June 15.
What happens after providers are uploaded to the FE Portal?
After providers are entered into the FE Portal, PCG will conduct an IRS match to confirm that provider information is correct. PCG will notify BHT if there is an issue with the matching process and BHT will work with the Providers to correct.
Providers will then receive an automated email containing information about how to register themselves in the FE Portal. Providers will then execute a Standard Partnership Agreement, which completes the registration process.
Will there be a notification sent to BHT to approve the providers in the FE Portal?
Yes. After the provider/partner completes registration in the FE Portal, an email will be sent to BHT administrative users notifying them that the provider/partner has completed the registration process. BHT may approve providers/partners at that time.
Are there any costs to providers/partners to being registered in the FE Portal?
There are no costs to providers or BHT associated with being registered in the FE Portal.
How does a provider/partner with multiple EINs and multiple locations register in the FE Portal?
Should a provider/partner have multiple EINs (i.e. a different EIN for each location), the provider/partner must be registered with each EIN to which BHT anticipates issuing payment. EINs can be associated with only one Organization (Partner). Organizations can add additional users and assign permissions through the Admin > User Management tab.
What if a provider/partner is participating in multiple projects in multiple regions? Will the provider/partner need to register with each specific ACH?
The provider/partner will only register once in the FE Portal, and each ACH would approve that provider/partner in their respective region. The first contact enrolled will need to assign additional users within their organizations as needed. Payment to the providers/partners will come from the FE. Partners in multiple regions can add bank accounts, designating which ACH to receive funding from. Please contact BHT directly if your organization is in this situation and you need further assistance.
Are counties and tribes paid via the FE Portal?
Tribes and counties may be paid through the FE Portal as participating partnering providers. Counties should be registered as a non-traditional provider, and tribes have their own designation in the FE Portal.
What happens if a provider adds or drops a project? Does an ACH need to update that?
Provider information is not related to how the payment is distributed. We’ll pay Providers based on use category.
If a provider/partner registers for the FE Portal, but ultimately decides not to participate in DSRIP project activities, can they be removed?
Yes, the provider/partner account can be deactivated. BHT has the ability to manage this process in the FE Portal. It is recommended that ACHs deactivate non-participating providers from the FE Portal prior to funds distribution by the ACH.
Reporting and auditing
How should the source of the payments be classified; state, federal, or private donations?
All orgainzations should consult their own legal or finance teams for guidance on how to categorize the funds or any other reporting questions.
What is the legal/fiduciary responsibility of BHT for funds that pass by, but not through, BHT in the FE Portal? If an ACH is audited, do they need to know how a provider spent earned dollars?
BHT will need to track how partnering providers earned the incentives according to our region’s approach to funds flow. However, BHT is not required by the state to manage how the money is spent by providers/partners. BHT may elect to work with providers/partners to capture provider/partner-level spending of incentive dollars.
Will BHT need any additional detail or reporting other than what is already outlined in the FE Portal and Project Plans?
HCA encourages ACHs to keep detailed records of their budget and funds flow to partnering providers in preparation for implementation plans and semi-annual reports. It is likely that BHT may be asked for further detail regarding how they are investing incentive dollars. Therefore, it would be a smart practice for Providers to keep detailed information on how their incentive payments were spent. Further guidance will be issued as implementation plan and semi-annual reporting templates are developed.
Who is considered the payer on the 1099 form?
The FE will be considered the payer on the 1099 form, there will be a memo that identifies the payment was made by the specific ACH.
If a provider has multiple EINs, will the provider receive one 1099 form?
The 1099 forms will be sent to providers based on how the providers were paid in the FE Portal. If the provider has multiple EINs registered and receiving payments via the FE Portal, each EIN will receive a 1099 form. If a provider receives payments from multiple ACHs to the same EIN, the incentives will be broken down by ACH on the 1099 form associated with that EIN.
Will BHT receive the full Year 1 amount in one lump sum?
ACHs will receive all earned DY 1 funds through the FE Portal in one lump sum. Earned funds in DY 2-5 will be distributed semi-annually, aligned with P4R and P4P measurement cycles.
Are ACHs accountable to the budget amounts by category as submitted in project plans? If not, is there a point in time where these categories and amounts are considered “locked in” or will there always be flexibility?
The budget amounts are, and will always be, flexible during the course of the Medicaid Transformation project. It is up to BHT on how they wish to spend the funds once they earn it.
What happens to interest earned from the funds held by the FE?
All payments held by the FE are required to be in non-interest bearing accounts. There is no interest earned in any of the accounts held by the FE.