Massachusetts School-Based Medicaid: Lessons Learned from Expansion/Free Care Preparations

Similar documents
MassHealth School-Based Medicaid Program: School Year Back to School Training

Changes in the School Based Access Program (SBAP)

PCG Medicaid School-Based Services (SBS) Programmatic Updates

Center for Medicaid and State Operations DATE: MAY 28, 2003

Telehealth Reimbursement Policy in

Medicaid Interpreter Services Pilot: Report on Program Effectiveness and Feasibility of Statewide Expansion

Appendix 3: PPACA Provider Questions and Answers from CMS

Medicaid Billing Changes. Background Information. Summary of Changes 7/1/2015

Medicaid School Based Services Update

Special Education Medicaid Initiative (SEMI) for Service Providers

AZ RMTS Staff Pool List Guide

Special Education Data Reporting Overview. Cost Based Reimbursement Methodology for School-Based Health Services

SECTION I: INTRODUCTION... PAGE 1 SECTION II: TERMS AND DEFINITIONS... PAGE 3

QUALITY ASSURANCE. Presented by Oakland Schools

Medicaid and Free Care Opportunities for Covering Services in Schools

The American Recovery and Reinvestment Act: Incentivizing Investments in Healthcare

Legislative Report TRANSFORMATION AND REORGANIZATION OF NORTH CAROLINA MEDICAID AND NC HEALTH CHOICE PROGRAMS SESSION LAW

Medicaid and Special Education Transportation Services

California School-Based Medi-Cal Administrative Activities Manual

AUDITS & REVIEWS OF SCHOOL BASED SERVICES T I M K U B U K A B E E R S I N G H

February 2004 Report No

The Pennsylvania School-Based ACCESS Program

School Health and Related Services (SHARS) - Cost Report and Audit Advice. Presented by HHSC Rate Analysis and the Texas Education Agency

Section 2703: State Option to Provide Health Homes for Enrollees with Chronic Conditions

BILLING PROCEDURES FOR EPSDT SCHOOL HEALTH RELATED SERVICES AND

Indian Health Services (IHS)/Memorandum of Agreement (MOA) New Managed Care Payment Arrangement 4/17/2018

Using Medicaid Home and Community Based Services or ICF/MR Funding to Pay for Direct Support Staff Training and Credentialing Programs

CHCANYS Conference October 31, 2016

Maryland Medicaid Program. Aaron Larrimore Medicaid Department of Health and Mental Hygiene May 31, 2012

OHIO DEPARTMENT OF MENTAL RETARDATION AND DEVELOPMENTAL DISABILITIES NEW FUTURES WAIVER

FLORIDA S STATE ORAL HEALTH

Joseph Lugo. Administration for Community Living. Slide 2

EPSDT HEALTH AND IDEA RELATED SERVICES

1 MINNESOTA STATUTES J.692

Florida Medicaid. Medicaid School Based Services Coverage Policy. Agency for Health Care Administration. Draft Rule

Medicaid 101: The Basics for Homeless Advocates

Medicaid Eligibility Report. January 10, 2017

School Corporation Services

Local Educational Agency (LEA) Billing

The Next Chapter in Kids Medicaid Coverage: Improving Care Delivery for Children and Leveraging the Medicaid Benefit for Children & Adolescents

School Health Services Local Services Plan Guidelines

Health Homes (Section 2703) Frequently Asked Questions

Estimated Decrease in Expenditure by Service Category

KANSAS MEDICAL ASSISTANCE PROGRAM. Fee-for-Service Provider Manual. Local Education Agency

Tri-City Mental Health Authority Spending Plan. April 2018 DRAFT. Tri-City Mental Health Authority Rimmi Hundal, MHSA Director

Florida Medicaid. Statewide Inpatient Psychiatric Program Coverage Policy

Alternative Managed Care Reimbursement Models

State Supported Living Centers

Medicaid EHR Provider Incentive Payment Program. January 2011

Updates: BHCS Mental Health Contracting for FY Frequently Asked Questions Last Update: 4/6/17

Physician Quality Reporting System (PQRS) Changes

Welcome to the first of a four part series on Early Childhood Intervention and Medicaid managed care. Throughout the four parts, you will learn about

Alternative in lieu of Services under Managed Care

STATE POLICY UPDATE. MNACHC Annual Conference October 30,

HEALTH PROFESSIONAL WORKFORCE

Telehealth and Children With Special Health Care Needs. Improving Access to Care and Care Coordination

Core Services Provided in Federally Clinical Coverage Policy No: 1D-4 Qualified Health Centers and Amended Date: October 1, 2015 Rural Health Clinics

Building a Sustainable Community Health Worker Workforce in Massachusetts

New Opportunities in Long Term Services and Supports

Children s Medicaid System Transformation: HCBS Rates & SPA Rate Code Review. December 21, 2017

The Evolving Landscape of Healthcare Payment: Incentive Programs and ACO Model Optimization. Quality Forum August 19, 2015

MINUTES Budget SubCommittee DAVIDSON COUNTY BOARD OF HEALTH. February 25, :00 pm BOARD MEMBERS PRESENT STAFF PRESENT VISITORS PRESENT

Division C: Increasing Choice, Access, and Quality in Health Care for Americans TITLE XV: Provisions Relating to Medicare Part A

GENERAL ASSEMBLY OF NORTH CAROLINA SESSION SENATE DRS15110-MGx-29G (01/14) Short Title: HealthCare Cost Reduction & Transparency.

MACRA Frequently Asked Questions

The Changing Role of States in Long-Term Services and Supports

KANSAS MEDICAL ASSISTANCE PROGRAM. Fee-for-Service Provider Manual. Rural Health Clinic/ Federally Qualified Health Center

Medi-Cal APR-DRG Updates. Medi-Cal Updates. Agenda. Medi-Cal APR-DRG Updates Quality Assurance Fee (QAF) Program

FISCAL YEAR 2015 HEALTH AND HUMAN SERVICES BUDGET

AN ACT authorizing the provision of health care services through telemedicine and telehealth, and supplementing various parts of the statutory law.

The Budget: Maximizing Federal Reimbursement For Parolee Mental Health Care Summary

Florida Medicaid. Early Intervention Services Coverage Policy. Agency for Health Care Administration August 2017

Florida Medicaid. County Health Department School Based Services Coverage Policy. Agency for Health Care Administration.

Section. 42School Health and Related Services (SHARS)

Illinois Department of Public Aid ILLINOIS GUIDE FOR SCHOOL-BASED HEALTH SERVICES ADMINISTRATIVE CLAIMING

TRANSITION OF NURSING HOME POPULATIONS AND BENEFITS TO MEDICAID MANAGED CARE

ICHP : Department of Health Care Policy & Financing Updates

State of California-Health and Human Services Agency EDMUND G. BROWN JR. GOVERNOR

Florida Medicaid. Outpatient Hospital Services Coverage Policy. Agency for Health Care Administration. Draft Rule

Roles and Responsibilities of Hospitals and the Oregon Health Authority

AMERICAN INDIAN 638 CLINICS PROVIDER MANUAL Chapter Thirty-nine of the Medicaid Services Manual

Early and Periodic Screening, Diagnosis and Treatment (EPSDT)

Providing and Billing Medicare for Chronic Care Management Services

The Telemedicine Train is Leaving the Station: Don t be left behind

Department of Human Services Division of Medical Assistance and Health Services Transportation Broker Services Contract Capitation Rates

Telemedicine and Telehealth Services

DEPARTMENT OF HUMAN SERVICES DIVISION OF MENTAL HEALTH & ADDICTION SERVICES

HR Telehealth Enhancement Act of 2015

Adult Behavioral Health Home and Community Based Services Quality and Infrastructure Program: Improving Lives

QUALITY PAYMENT PROGRAM

State Approaches to Providing Health-Related Supportive Services through Medicaid

ATTACHMENT I SCOPE OF SERVICES Effective Date: October 1, 2014 STATEWIDE MEDICAID MANAGED CARE PROGRAM

What is the QRUR? Understanding Your Annual Quality and Resource Use Report

Florida Medicaid. State Mental Health Hospital Services Coverage Policy. Agency for Health Care Administration. January 2018

ACO Practice Transformation Program

Texas Health Care Transformation and Quality Improvement Program - FAQ

Cancer Hospital Workgroup

Cancer Hospital Workgroup. Agenda. PPS-Exempt Cancer Hospital Quality Reporting Program. Roll Call PCHQR Program Updates HCAHPS Updates

Feather River Tribal Health, Inc.

1.2.4(a) PURCHASE OF SERVICE POLICY TABLE OF CONTENTS. General Guidelines 2. Consumer Services 3

Transcription:

Massachusetts School-Based Medicaid: Lessons Learned from Expansion/Free Care Preparations Healthy Students, Promising Futures Meeting Washington, D.C. Wednesday, December 5, 2018 Executive Office of Health and Human Services Presented by: Caitlin N. Feuer, Cross Agency Medicaid Program Manager, Massachusetts Office of Medicaid caitlin.feuer@state.ma.us

Agenda 1. 1 Massachusetts Medicaid and School-Based Medicaid Program overview 2. 2 Expansion processes SPA submission and approval Implementation preparations 3. 3 Expansion changes Covered services Direct Service Claiming 4. 4 Takeaways Expansion challenges Suggested questions before submitting your own SPA 2

Overview Massachusetts Medicaid and School-Based Medicaid Program 3

Massachusetts Medicaid & School-Based Medicaid 1 Massachusetts administers the Children s Health Insurance (CHIP) and Medicaid as one program called MassHealth The School-Based Medicaid Program (SBMP) offers Local Education Agencies (LEAs) an opportunity to receive federal dollars to offset costs for providing certain Medicaid-covered services and administrative activities in a school setting. MassHealth oversees SBMP and monitors compliance with state and federal Medicaid law The University of Massachusetts Medical School (UMMS) administers the program on behalf of and in conjunction with MassHealth since the Program s inception in 1994 4

SBMP History 1 1994-2009 Bundled rate claiming for direct services 2009-present - Random Moment Time Study (RMTS) implemented - Interim direct service claims submission & annual cost report reconciliation - Quarterly Admin claims 2016 State Plan Amendment (SPA) in response to Free Care Reversal submitted ( Expansion ) 2018 Expansion announced with July 1, 2019 effective date 1994 1998 2009 2015 2016 2017 2018 1998-2009 Administrative claiming added with 15-minute time study methodology 2015 Applied Behavior Analysis (ABA) services included under preexisting School-Based State Plan authority 2017 Expansion SPA approved 5

SBMP Claiming 1 LEA reimbursement is based on actual costs and LEAs can seek reimbursement for: 1. Direct health services through Direct Service Claiming (DSC) 2. Certain administrative expenses associated with the provision of medical services and MassHealth outreach/enrollment assistance through Administrative Activity Claiming (AAC) Local Education Agencies can seek DSC reimbursement for children whose non-emergency services can be claimed under Medicaid or CHIP authority 6

1 Cost-Based Reimbursement Structure Simplified Direct Service & Admin Activities Cost Report Calculation Allowable Costs for Covered Services Medicaid Eligibility Rate RMTS Results (Statewide per pool) Gross Medicaid Reimbursable Amount (LEA-specific) Annual Cost Report Calculation (Direct Service Only) Gross Medicaid Reimbursable Amount Interim Payments Cost Report Payment 7

Processes 2 SPA submission and approval Implementation preparations 8

How did we get to Expansion? 2 Centers for Medicare and Medicaid Services (CMS) letter (SMD#14-006 dated December 15, 2014) removed the free care limitation CMS confirmed guidance that medically necessary services, regardless of IEP, may be considered for reimbursement in schoolbased Medicaid programs at 2015 NAME Conference January 2016 joint call held by U.S. Dept. of Health and Human Services (HHS), CMS and U.S. Dept. of Education (DOE) encouraged states to submit State Plan Amendments 9

How did we get to Expansion? (cont.) 2 March 2016 Massachusetts assembled a workgroup to explore submitting a SPA and prepare for expansion. The workgroup included: MassHealth program, finance, legal, clinical staff UMMS as program vendor Massachusetts Dept. of Elementary & Secondary Education (DESE) Massachusetts Dept. of Public Health (DPH) School Nursing Director SPA submitted to CMS September 2016 Formal questions received in November 2016 Second round of questions received February 2017 CMS approved SPA July 2017 10

While we were waiting for SPA Approval 2 Tried our best to prepare Developed implementation plan, which included: Training plan Identification of MMIS changes Identification of UMMS system changes Identified specific nursing services, potential billable procedure codes & interim rates Began updating instruction manuals/guides Staff transition CMS indicated we could NOT implement RMTS pool or activity code changes or otherwise begin implementation 11

SPA Approval! Now what? 2 Approved with a July 2016 effective date in July 2017 Could not retroactively claim per CMS Could not implement in the fiscal year that was underway (no LEA preparation, IT infrastructure changes required) Asked ourselves what effective date would be reasonable for LEA compliance and participation and then we asked the LEAs 12

and then we asked the LEAs 2 In March 2018, MassHealth shared written material and video of narrated PowerPoint about key opportunities and barriers for expansion What expansion will entail Amended contract requirement (previously took 6-8 months) DESE shared guidelines around parental consent requirement per FERPA MassHealth administered the survey and asked whether July 1, 2018 or July 1, 2019 was most feasible and desirable implementation date Overall feedback indicated while LEAs would want a revenue pickup as soon as possible, it was not feasible to implement in four months Shared results of survey with LEAs before formally announcing expansion would be effective July 1, 2019 13

Launching LEA expansion prep: partnership in action 2 In order to maximize participation and compliance, engaging LEAs every chance we get Email-based outreach Mentioning expansion/contracts during help desk calls Trainings DESE s Commissioner Updates DPH Nurse Training Days Communicated to LEAs that they would directly need to be involved Give them every tool possible to succeed, including meaningful resources and access to information 14

Developing SBMP Communications Strategy 2 Reviewed entire body of communications Determined strategy website/accessibility forward Website redesign New online Resource Center Began overhauling all externally facing materials and created new documents Updated Program Guidelines Created Quick Reference Pages/formalized cheat sheets Updated Contact Forms - required LEA contacts 15

LEA training 2 Kicked off training for LEAs with all-day trainings during the last week of September Jointly presented by MassHealth, UMMS, DESE, and DPH Worked aggressively to encourage LEAs to directly engage the right people in the process LEA representatives sending billing vendor is not enough Multiple staff per LEA (e.g. RMTS coordinators, Special Education Director AND Nursing/Health Director, billing staff, LEA revenue/accounting staff, etc.) Unprecedented 500 person attendance in-person and via livestream with 90% of LEAs represented at the training Due in large part to multi-agency outreach and UMMS push to ask why aren t you registered? Focus was on reinforcing existing program requirements and explaining how expansion fits within the program Offered takeaway questions to aid in preparation efforts and ongoing compliance 16

Continuous LEA training future plans 2 Planned for Spring 2019: Nursing Services-focused training planned for Spring All other direct medical services focused training(s) RMTS focus training Planned for late Summer/early Fall 2019: RMTS training for RMTS coordinators Administrative Activity Claiming training Additional training and resources likely to be added Sent a digital training evaluation to all LEAs to learn what worked, what did not work, and why 10% of LEAs did not attend MassHealth and UMMS will develop additional training and materials based on LEA feedback 17

Expansion Changes 3 Covered services Direct Service Claiming 18

Expansion Methodology Changes 3 Simplified Direct Service Cost Report Calculation Allowable Costs for Covered Services RMTS Results (Statewide per pool) Medicaid Eligibility Rate (LEA-specific) Gross Medicaid Reimbursable Amount All three direct service inputs above changed as a result of program expansion (admin claiming methodology unchanged) 19

Covered Services & Providers 3 The services listed below are the MassHealth Covered Services within the current scope of the School-Based Medicaid Program SBMP Covered Services Through June 30, 2019 Services MUST be Pursuant to an IEP Applied Behavior Analysis Services Audiology Occupational Therapy Personal Care Services Physical Therapy Psychological Counseling Skilled Nursing Services Speech-Language Therapy Vision Services 20

Current vs. Expansion 3 SBMP Expansion includes the following changes: 1 IEP requirement lifted, including coverage of initial evaluations Covered services can be pursuant to a Section 504 plan, other health plan, or are otherwise medically necessary 2 Inclusion of additional licensed practitioners DESE-licensed School Psychologist (most anticipated) Optometrist Licensed Dietician / Nutritionist Dental Hygienist 3 Inclusion of new service specialty types Medical Nutritional Services provided by a registered dietician or licensed nutritionist Dental assessments/screenings provided by a dental hygienist or fluoride treatments provided by a nurse 21

Covered Services & Providers 3 The services listed below are the MassHealth Covered Services within the scope of the SBMP starting July 1, 2019, regardless of inclusion in an IEP SBMP Covered Services Effective July 1, 2019 Applied Behavior Analysis Services Audiology Dental Assessments / Screenings (Fluoride varnish) Medical Nutritional Services Health / Behavioral Health Screenings and other services under EPSDT Occupational Therapy Personal Care Services Physical Therapy Physician Medical Evaluations Psychological Counseling Skilled Nursing Services Speech-Language Therapy Vision Services 22

Methodology Changes: RMTS 3 Random Moment Time Study (RMTS) Pools Current (through June 30, 2019) Three pools: 1) Direct Service 2) Admin Only 3) ABA Therapy Expansion (Starting July 1, 2019) Four pools: 1) Mental/Behavioral Health 2) Therapy Services 3) Medical Services 4) Admin Only Mental/Behavioral Health Therapy Services Medical Services ABA providers Counselors Psychologists Social Workers Speech/Language providers Occupational Therapy providers Physical Therapy providers Audiology/Hearing providers Dental Hygienists Nurses Nutritionists/Dieticians Optometrist Personal Care Service providers Physicians Medicaid Billing Personnel 23

Methodology Changes RMTS (cont.) 3 Mental/Behavioral Health Pool - IEP Direct Service % - Non-IEP Direct Service % - Admin % Therapy Services Pool - IEP Direct Service % - Non-IEP Direct Service % - Admin % Medical Services Pool - IEP Direct Service % - Non-IEP Direct Service % - Admin % - Admin % Admin Only Pool Under expansion, direct service RMTS % will be split into IEP and non-iep percentages. The admin calculation remains unchanged. 24

Methodology Changes - RMTS 3 RMTS questions and pre-defined answer mapping required substantial revision to accurately isolate the IEP vs. non-iep reimbursable direct service time Used the opportunity to improve, clarify existing wording based on LEA feedback and historical write-in answers Revised RMTS pre-defined answers rolled out this school year (without impact to reimbursement) Offers RMTS participants opportunity to get used to the new organization and wording Offers MassHealth/UMMS opportunity to get feedback about the wording and language so that it can be further improved prior to expansion implementation next year when it impacts reimbursement 25

Medicaid Eligibility Rates 3 Three separate Medicaid Eligibility Rate (MERs) will be used: 1. Direct Service Claiming for IEP Services: MER based on population of IEP students for whom the LEA seeks reimbursement 2. Direct Service Claiming for non-iep Services: MER based on district-wide population of students for whom the LEA seek reimbursement 3. Administrative Activity Claiming (unchanged under expansion): school-district wide total student population eligibility percentage 26

Current Cost Report calculation reminder 3 Simplified Direct Service & Admin Activities Cost Report Calculation Allowable Costs for Covered Services RMTS Results (Statewide per pool) Medicaid Eligibility Rate (LEA-specific) Gross Medicaid Reimbursable Amount 27

Expansion Cost Report calculation 3 Therapy Pool Example Allowable Costs for Covered Services Allowable Costs for Covered Services IEP Services RMTS Results (Statewide Therapy Pool) Medicaid Eligibility Rate (LEA-specific for students on IEPs) Non-IEP Services RMTS Results Medicaid Eligibility Rate (Statewide Therapy Pool) (LEA wide) Gross Medicaid Reimbursable Amount for Therapy Green indicates new RMTS pool and percentage and new MER 28

Takeaways 4 Expansion challenges Suggested questions before submitting your own SPA 29

4 Challenges Shared Language around Covered vs. Reimbursable Services Covered Services: Services that are claimable under the SBMP Massachusetts State Plan Amendment Reimbursable Services: Covered Services provided consistent with program requirements Billable Procedure Codes: The CPT codes that LEAs use to submit interim claims after the provision of Reimbursable Services 30

Challenges Reimbursable Services requirements for non-iep services 4 If a Covered Service is delivered, the following requirements must be met to be considered a Reimbursable Service: 1. Practitioner RMTS Direct Service Pool Participation 2. Practitioner Licensure Qualifications 3. Medicaid Medical Necessity 4. Service Authorization 5. Service Documentation 31

Challenges Parental Consent 4 DESE determined FERPA requires consent before an LEA can share information with MassHealth; this is a federal education requirement, not a Medicaid requirement. Restrictions include: Eligibility information for MER for direct service claiming Claim submission This directly impacts on revenue since MER is used in Cost Report and claims submission is required for inclusion in cost report DESE issued updated guidance and a new parental consent form for both IEP and non-iep services for all children in a family Continued with one time consent policy (with annual notification) Guidance from DESE available here: http://www.doe.mass.edu/sped/advisories/13_1.html. DESE assisting LEAs with strategies to obtain consent from families not currently part of the IEP-based reimbursement program 32

Challenges LEA involvement Historically it could be challenging to get LEAs directly involved (rather than depending on billing vendor) Began with outreach efforts and getting LEAs to attend the trainings in September (90% success rate!) Updated contact requirements requiring LEA direct involvement in most processes/components of the program Emphasizing that LEAs are the contracted provider and LEA representatives certify the public expenditure so it is the LEAs responsibility Reminder that ultimately LEAs are the entities audited by MassHealth, CMS, OIG, etc. 4 33

Challenges Interim Billing and Contracts 4 Interim Billing New services and new procedure and diagnosis codes Without interim claims, costs cannot be claimed in cost report On an IEP claim vs. non IEP claim basis Claims modifiers are used to indicate whether claims are pursuant to or outside of an IEP Contracts Previously 6-8 months required to execute contracts Challenge avoided due to preparation year Reimbursable Services requirements directly impact claim submission 34

Challenges TPL & Managed Care 4 TPL not an issue. The SBMP program upon initial implementation was excluded from TPL requirements because private insurers do not cover services provided in the school setting. We provided documentation from all the major insurers stating that exclusion and therefore our LEAs do not work with TPL at all. MCOs and ACOs not an issue. The SBMP program is carved out from MCOs and ACOs. 35

Potential Questions to Take Back to Your Agencies 4 Relationships How is the program currently doing? Could the LEAs handle a major change like expansion/free care? Are they currently engaged with the program? How is our website/externally facing materials? How are our cross-agency relationships? DPH? Dept. of Ed? Since this impacts local aid, do we need to work with the legislature? Are there advocacy groups that we should talk/work with (e.g. nursing associations, parent groups)? How will we manage expectations with LEAs and other internal and external stakeholders? Contracts Will new or amended contracts be required? 36

Potential Questions to Take Back to Your Agencies 4 Services and Provider Types What services and provider types would we want to include in a SPA? FERPA What services are currently provided and by whom? Restrict to specific plans such as Section 504? Include otherwise medically necessary services? Are/could LEAs, particularly nurses, be ready to apply state and federal medical necessity requirements outside of a plan structure? Do legal teams consider FERPA to apply in this case? What is the current IEP consent process? What would new consents look like and how would it impact expansion/free care? Eligibility rate or billing only? 37

Potential Questions to Take Back to Your Agencies 4 Technical Elements What RMTS structure makes the most sense? What data is available to help model financial impact? What data can we get by thinking ahead before SPA submission? What changes would need to be made to infrastructure? RMTS system? Cost report filing? Admin claiming system? LEA systems? How would interim billing be impacted? 38

Expansion firsts 4 39

www.mass.gov/masshealth/schools 40