ARRM's Daily Dispatch

In-home billing and Rule 40 survey updates

ARRM has been working with DHS on a variety of issues ths summer.  We would like to provide a quick update on two of those issues.

In-home billing:  Members alerted us to the fact that some counties were changing what they allowed to be billed for in-home services provided under the DD waiver.  ARRM has been working with DHS staff to resolve the problem.  At this point, DHS has contacted those counties that we were aware of and is asking them to not make any changes while DHS does some further research on the billing issue.  ARRM will continue to work on this issue until it is completely resolved.  If members are having problems with counties on this issue, please let me know. bturner@arrm.org

Rule 40/psychotropic medication survey:  In a previous blog we informed members that we were trying to address the concerns they had with the request from DHS to complete a survey on the use of restrictive, aversive and deprivation procedures.  Although
we have shared our concerns it does not appear that DHS plans to make any changes to their request.  Dean Ritzman, who is the DHS staff leading this project, has stated that if providers have concerns or questions they can contact him directly. His email address is dean.ritzman@state.mn/us

As always, feel free to contact me bturner@arrm.org or 651-291-1086 ext. 3 if
you have questions.

 

---Barb Turner COO

ARRM continues to work with DHS on in-home billing issues

ARRM has been working with DHS for several weeks to address issues that have arisen in some counties regarding billing for in-home services through the DD waiver.  There has been a recent interpretation that billing for in-home services can only be done for face to face time with the individual. 

ARRM contacted Alex Bartolic and discussed concerns over what we believe is an inaccurate interpretation of what is billable.  At the most recent up date with Alex last week she shared that she had instructed her staff to do several things.  This includes:

• Going back to the waiver plan to confirm what language it contains
• Contacting some specific counties that we identified to discuss the issue with them

At that time we requested that DHS contact all counties and instruct them to not make any changes to billing for in-home services until they recieve further direction from DHS.

There is a concern that some counties may feel they have been doing things incorrectly and are now taking action to change things.  DHS is trying to confirm all the facts and then proceed as neccessary to assure that services for individuals are not disrupted and that providers are not negatively impacted.

ARRM will continue to follow up on this issue until it is resolved.  We will keep members up to date as we recieve information.

If you are having problems with specific counties on this issue, please contact Barb Turner bturner@arrm.org and provide the details on which county/counties and what action they have taken.

---Barb Turner COO

ARRM submits comments on Medicaid Reform Waiver

Back in June, the Department of Human Services (DHS) submitted an application to make changes to the state’s Medicaid program (Medical Assistance), as directed by the 2011 legislature. The purpose of this reform was: to provide long-term sustainability of needed services through better alignment of available services that most effectively meet people’s needs, to increase community integration and independence; to improve health; to reduce reliance on institutional care; and to obtain or maintain employment and housing. Often referred to as the “global waiver,” the proposal is now known as Reform 2020. Additional information on the project is available on DHS’s website here, and a copy of the waiver application is available here.

Once submitted, all interested parties had 30 days to submit comments before the waiver is submitted to the Centers for Medicare and Medicaid Services (CMS) for their review. ARRM reviewed the proposal for the impact on members and the individuals you serve. In general, we support the direction of the reforms, but cannot fully endorse them without additional detail. Additional stakeholder input on the development and implementation is needed first. There are several items we support: expanding of the current PCA program to include more services such as coaching and prompting, adding more flexible services to existing waivers and additional services to support individuals living in the community. Most of the other items, including changes to fiscal support entities, creating individualized budgets for services, and providing consumers with information on choosing services are good concepts, but need more detail. You can click on the "download here" link to read the full text of ARRM's letter to the department. Download Here

If members have submitted comments directly to the department on the Reform 2020 Waiver, please pass those comments on to me at cwieber@arrm.org. If you have any other questions or concerns on the Reform 2020 proposal or our comments, please contact me at cwieber@arrm.org or by phone at (651)291-1086 ext. 9.

DHS provides information on rate setting methodology

Rate Setting Methodology Update

Three new documents are available from the Department of Human Services on the Disability Waivers Rate System web page. These documents provide additional definition of the rate setting frameworks. It gives clarification to the definition of shared and direct staffing, as well as some other terms. These documents provide a definition of what qualifies an individual for the customization under each framework. These qualifications are:

Individuals with high medical needs:

• DD:Screening Document: Field 26 – Medical, with score of 5; and Field 45
  – Special Support Services Needed, A – Specialized Medical Services, scored “yes”
• Long Term Care Screening Document: Case Mix I, J, or K

 Individuals with high behavior needs:

• DD: Screening Document: Field 38 – Challenging (Excess) Behavior Scales, any
  single attribute (A‐J), with score of 5; and Field 45 – Special Support Services Needed, F – Program to Address Excess Behavior, scored “yes”
• Long Term Care Screening Document: Behavior score of 4

Individuals with high mental health needs:

• DD Screening Document: Field 38 – Challenging (Excess) Behavior Scales, any single attribute (A‐J), with score of 5, and Field 45 – Special Support Services Needed, G –Mental Health Services, scored “yes”
• Long Term Care Screening Document: Field 19 on the (History of MI Diagnosis)
  be checked Y, and a Field 46 (behavior) score of 3 or 4

Individuals who are deaf and hard of hearing:

• DD: Screening Document: Field 28 – Hearing score of 5 or 6, and Field 3– receptive communication score of 4
• Long Term Care Screening Document: Field 56 – 02 or 03 (no useful hearing)
  and; Field 57 – 02 (communicates needs with sign language, symbol board, written messages, gestures, or an interpreter)

All of the framework definitions are available on the DHS waiver rate system page. Here are direct links to the documents for the residential, day ,and unit-based services.

Earlier this year, ARRM asked some members to compare existing individual rates to those under the proposed DHS framework. At that time, we told members to assume no one would receive customizations because no definitions were available. Now, members can do the same exercise knowing who gets these add-ons. We aren’t collecting that information again at this point.

As the process moves forward, ARRM will examine these definitions to determine the impact on the individuals receiving services, and the rates paid for providing those services. We will work with DHS to understand the number of individuals these definitions will impact, and the overall impact they have on aggregate waiver spending.

If you have any feedback on these definitions, if they are either too stringent or too loose, please contact me and let me know. Also, contact me with any other questions or concerns. Please contact me at cwieber@arrm.org or by phone at (651)291-1086 ext. 9.

---Craig Wieber

ICF/DD billing now requires physician NPI number

Change in Medicaid Reporting Requirement

There was a change in 2011 session law that changed reporting requirements for Medicaid. ARRM members providing certain services will have to comply with this new requirement. This includes ICF/DD services, it does not include residential waiver services. Here is the legislative language:

Subd. 5. Ordering or referring providers. Claims for payments for supplies or services that are based on an order or referral of a provider must include the ordering or referring
provider's national provider identifier (NPI). Claims for supplies or services ordered or referred by a vendor who is not enrolled in medical assistance are not covered.

This change was implemented as of May 2012. The change in law requires that fee-for-service claims for payments for items or services that are based on an order or referral must include the ordering or referring professional’s national provider identifier. If this information isn’t included, claims submitted will not be paid.

For additional information, please visit DHS’s website for MHCP
Provider Update MHP-12-05. That page will provide members with the
additional information, including directions for compliance and a link to the MHCP provider directory, needed  to satisfy this new requirement.

As always, if you have any questions or concerns, please contact me at cwieber@arrm.org or by phone at (651)291-1086 ext. 9.

 

ARRM member implications: Supreme Court upholds the Affordable Care Act

As you’ve already likely heard, the Supreme Court issued its ruling on the constitutionality of various portions of the Patient Protection and Affordable Care Act late last week. Click here for a story with a detailed description of the court’s decision. For ARRM members, the court upheld the major policy changes in the bill, two of which impact the operations of our members and the services we provide: the individual mandate and the expansion of Medicaid.

The first major issue, the individual mandate, was upheld on the grounds that the mandate is a tax and permissible under Congress’s authority to impose taxes. The court rejected the argument that the mandate was authorized under the Congress’s ability to regulate commerce. This means that citizens will be required to hold private insurance, be covered under an employer based health plan, or be enrolled in a public program like Medicaid. Employers will be required to provide insurance to full-time employees. If an employer doesn’t offer insurance or an individual doesn’t have insurance, they would both be subject to penalties. How that will work and how it will be enforced are still open questions.

The second key issue of Medicaid expansion was also upheld. The court found the expansion of Medicaid services under the new law is constitutional; states may agree to expand coverage in exchange for increased funding; and if states accept the additional funds, they must comply with the new rules for expanded coverage. And, states may choose not to participate in the expansion and not lose all other Medicaid funding.

For ARRM members, the most significant issue decided by the court was on the individual mandate. The expansion of Medicaid does add new individuals to the program, but not many of those were previously ineligible for the services we provide. Now, as employers, ARRM members will be required to offer insurance to full time employees meeting certain coverage requirements or face penalties. 

The Supreme Court’s ruling will allow implementation of the Affordable Care Act to move forward. ARRM knows there will be many questions and issues as provisions of the new law take effect. We will continue to monitor the situation and plan to provide training to assist members with compliance at upcoming events.

As always, if you have any questions or concerns, please contact me at cwieber@arrm.org or by phone at (651) 291-1086 ext. 9

--Craig Wieber, Chief Fiscal Analyst

Rate setting methodology update: Customized living and residential sites of 5 or more

DHS has announced that the existing customized living tool will be used to gather information on the specific service delivery expectations based on the current needs of recipients in settings of five or more. Lead agencies (counties) are being asked to complete the tool for disability waiver recipients receiving customized living or 24-hour customized living, regardless of size. It will be used for any residential care services in settings of five or greater. 

Since counties are being asked to complete this information, it is very likely that counties will be contacting providers to gather information and data on the individuals they serve. The level of information needed is likely to vary across the state, depending on how extensive the information each county already possesses. Back in December, DHS asked counties to gather information and data on staffing and service levels for individuals to populate the rate management system for residential services in settings of four or fewer. Now, they are doing the same thing for larger settings, but using the customized living tool. The information gathered in this survey will be used to determine variables and model the impact of different variables on this portion of overall waiver spending.

A copy of the announcement that was sent to counties is available here. Additional information, instructions, and the tool itself is available on DHS’s website here. I’d encourage members to work with county staff to provide the most update to date and reliable information to ensure the underlying data and information used build frameworks is accurate and dependable.

As always, if you have any questions or concerns, please contact me at cwieber@arrm.org or by phone at (651) 291-1086 ext. 9

--Craig Wieber, Chief Fiscal Analyst