MISSOURI RECEIVES APPLICATION FEE WAIVER FOR CERTAIN PROVIDER TYPES

 

State and federal regulations (13 CSR 65-2 and 42 CFR 455.460) require MMAC to collect an application fee, currently set at $542.00, from all new and revalidating “institutional” Medicaid providers.  “Individual” providers such as physicians, dentists and other individual non-physician practitioners are not required to pay the application fee.

 

Effective July 1, 2015, MMAC began collecting the required application fee from all new, reenrolling and revalidating MO HealthNet institutional providers.

 

Providers can request a hardship waiver of the application fee from CMS, but the fee must be submitted before the application will be processed by MMAC.  If CMS approves the hardship waiver, MMAC will refund the application fee to the provider. Click here for more information regarding requesting a hardship waiver from CMS.

 

Providers who paid the $542 fee to Medicare or another state Medicaid agency will be exempt from paying an application fee.

 

The only providers who will be paying the required application fee during state fiscal years 2016 and 2017 (July 1, 2015 to June 30, 2017) will be newly enrolling institutional providers.

 

There are various payment options for providers that are required to submit the application fee during state fiscal year 2016 and state fiscal year 2017:

 

You may pay electronically using a credit card, debit card or e-check through the contracted state vendor, Collector Solutions.  A convenience fee will apply, depending on the form of electronic payment selected. Click here for Collector Solutions website. The vendor will provide a receipt reflecting the application fee was paid which can be submitted to MMAC with your application. Providers also have the option of submitting a cashier’s check or money order, made payable to DSS-MMAC Application Fee.  Cash and personal/business checks will not be accepted.  Mail your check to: For more information about hardship waivers, please click here.

 

On August 14, 2015, MMAC received an exemption waiver from CMS for several provider types, when the provider is publicly funded. Click here to read the letter.  Specifically, the waiver applies to government-operated providers which are publicly funded, such as those operated by city, municipal, county, and state agencies.  As of this date, this applies to all 325 enrolled school-based services providers, all 104 enrolled public health departments, all 13 enrolled long term care state institutions, and all three (3) enrolled state mental hospitals.  It also applies to some providers in other categories. If you are uncertain whether this applies to you, please contact MMAC at mmac.providerenrollment@dss.mo.gov or by calling (573) 751-8619.  If this waiver does not apply to you, you may still request a hardship waiver directly from CMS.

 

 

If you have any questions regarding whether or not the exemption covers you, please contact MMAC at MMAC.ProviderEnrollment@dss.mo.gov or at 573-751-3399 (request provider enrollment.)

Providers who self-audit and discover overpaid amounts are able to “self-disclose” or report those findings.  The findings, along with repayment, can be sent to Missouri Medicaid Audit & Compliance (MMAC) by using the Self Disclosure Form, located here.  Providers do not have to submit multiple checks, as the form allows for a detailed, line-item description of the amount(s).  Submitting one check per disclosure form (for multiple disclosures) is preferable.

 

On August 10, 2015, the Department of Health and Senior Services (DHSS), Division of Senior and Disability Services (DSDS) issued a memo regarding modifications to the Home and Community Based Services (HCBS) Web Tool. The memo also describes a manual calculation for HCBS providers to utilize prior to the Web Tool update taking effect. This calculation applies when Personal Care or Advanced Personal Care services are provided in either an Assisted Living Facility (ALF) or Residential Care Facility (RCF). Click here to read the memo, number PM-16-02.

 

On August 7, 2015, the MO HealthNet Division issued a Provider Bulletin regarding the same topic. Click here to read the bulletin.

 

The bulletin states, in part, “For RCF and ALF personal care providers, when a participant’s plan of care includes at least one task that is to be performed daily, then the participant’s monthly maximum allotment cannot be reached in a month containing fewer than 31 days.

 

When determining compliance with this limitation, the following method shall be used:

Step 1: Identify the daily tasks (tasks shown on the care plan as daily or with a frequency of seven times a week). Step 2: Identify the total number of minutes for these daily tasks in a week (this may appear directly on the care plan, or you can multiply the total number of daily task minutes by seven). Step 3: Divide the number in step 2 by 15. Round up to the nearest whole number (.5 or more rounds up). This gives you the daily task units per week. Step 4: Divide the number in step 3 by seven (7). Round up to the nearest whole number (.5 or more rounds up). This gives you the daily task units per day. Step 5: Multiply the number in step 4 by the number of days fewer than 31 in the month. (Take the number for step four (4) and multiply it by one (1) for April, June, September, and November. Multiply it by three (3) for February. Multiply it by two (2) for February in a leap year. Step 6: Take your total from step 5 and subtract it from the total number of authorized units. This gives you the new total of authorized units for your shorter month.”

 

 

The Missouri Medicaid Audit and Compliance Unit (MMAC) defers to and supports the guidance provided above.

Cognosante, LLC is the RAC for Missouri.  Section 6411 of the Affordable Care Act, Expansion of Recovery Audit Contractor (RAC) Program, amends section 1902(a)(42) of the Social Security Act and requires states to contract with a RAC vendor and allows states to reimburse contractors who assist in the identification and recovery of improper payments.

 

Should you receive any communication from an entity representing itself on behalf of Missouri Medicaid Audit and Compliance (MMAC), or Cognosante, and you are concerned about the legitimacy of the person or company, you should contact MMAC at (573) 751-3399 to verify the communication or request is legitimate.

 

In 2015, the RAC will finish its work on outstanding pharmacy and durable medical equipment (DME) audits, and will begin conducting audits of hospital billing submitted by enrolled Missouri hospital providers.  The RAC may request documentation to support billing of outpatient encounters, including professional and facility services.  The RAC will review paid claims for proper billing of both professional and facility services, and the appropriate utilization of facility resources, such as supplies and facility charges.  Documentation requests may include requests for itemized statements, medical records, medication administration records, radiology interpretations, and laboratory results to support the claims submitted for payment.

 

The RAC will begin issuing medical records requests to those hospitals selected for audit beginning July 2015.

Effective July 1, 2015, all In-Home and Consumer Directed Services providers are required to have, maintain, and use a telephone tracking system “telephony” for the purpose of reporting and verifying the delivery of In-Home and Consumer Directed services authorized by the Department of Health and Senior Services (DHSS).  To review the statutes for In-Home Services and Consumer Directed Services, click on the links.   660.023   208.909 RSMO

 

Providers are no longer required to submit a change request or an addendum to MMAC to utilize telephony.   These were requirements of the pilot project, which has now ended.  The previous post on the MMAC website dated September 2014 described requirements of the pilot project.  The pilot project is no longer in effect.

 

DHSS is drafting a regulation regarding telephony and is working closely with MMAC and the HCBS provider associations to gather input and feedback. After the rule is drafted, there will be a public comment period.

 

MMAC has determined not to require an attestation statement in the provider agreements at this time.

Brown Smith Wallace LLC, Missouri’s EHR Audit Contractor

As part of the ongoing program to monitor MO HealthNet’s Electronic Health Record (EHR) Incentive Program payments, the Missouri Department of Social Services has contracted with Brown Smith Wallace LLC  to conduct reviews of payments made to participating hospitals and professionals for program year 2013.

 

Federal regulation 495.368 requires States to comply with Federal requirements to combat fraud and abuse.  Brown Smith Wallace LLC is authorized to conduct post-payment audits through desk and/or on-site reviews.  Selected hospitals and professionals will receive a letter of notification indicating that they have been chosen for a review.

 

The purpose of the audit is to validate certain information utilized as the basis for dispersing an incentive payment, including information used in eligibility determinations and hospital payment calculations. Section 1903(t)(2) of the HITECH Act states that all Eligible Professionals and Hospitals need to meet certain patient volume thresholds in order to be eligible for Electronic Health Record incentive payments.

 

Information Required of Eligible Professionals and Hospitals

The following information may be required from eligible professionals and hospitals. A tip sheet with more detailed descriptions is referenced in the last bullet under each heading below.

 

Eligible Professionals:

Detailed encounter listing to support the numerator and denominator utilized in the eligibility calculation, Documentation to support an eligible professional’s affiliation with locations for which patient encounter volume was reported, Documentation to support an eligible professional’s affiliation with a group practice when that eligible professional utilized the group proxy to report encounter volume, and When appropriate, documentation to confirm the provider or provider organization had a legal or financial obligation to the Certified Electronic Health Record Technology at the time of A/I/U (Adopt, Implement, or Upgrade) attestation. A tip sheet for eligible professional: https://dss.mo.gov/mhd/ehr/pdf/post-payment-review-tips-eligible-professional.pdf

 

Eligible Hospitals:

Detailed encounter listing to support the numerator and denominator utilized in the eligibility calculation, Documentation to support discharges according to the applicable cost reports or other documentation utilized in calculating the growth rate and discharge-related amount, Documentation to support the Acute Medicaid Days, Acute Medicaid HMO days, and Total Acute days utilized in calculating the Medicaid share, Documentation to support Charity Care Charges and Total Hospital Charges utilized in calculating the Medicaid share, and When appropriate, documentation to confirm the hospital had a legal or financial obligation to the Certified Electronic Health Record Technology at the time of A/I/U (Adopt, Implement, or Upgrade) attestation. A tip sheet for eligible hospitals: https://dss.mo.gov/mhd/ehr/pdf/post-payment-review-tips-eligible-hospitals.pdf

The following is from a memo published by the Director of the Division of Senior and Disability Services on May 26, 2015 regarding the requirement for Telephony Tracking Systems.  Click HERE to download the full memo.

 

Effective July 1, 2015, pursuant to Sections 660.023 and 208.909, RSMo, all In-Home Services and Consumer Directed Services providers are required to have, maintain, and use a telephone tracking system for the purpose of reporting and verifying the delivery of all In-Home and Consumer Directed Services as authorized by the Department of Health and Senior Services (DHSS). The telephone tracking system must meet the applicable requirements of Sections 660.023 and 208.909, RSMo.

 

The telephony pilot project ended when the completed report was provided to the general assembly in 2013. Therefore, Missouri Medicaid Audit and Compliance (MMAC) will no longer provide a list of telephony vendors who were approved for participation in the pilot project. Home and Community Based Services (HCBS) providers are no longer required to complete an addendum when they begin telephony. MMAC will add an attestation statement to the provider agreements beginning July 1, 2015.

 

Pursuant to Sections 660.023.3 and 208.909.5(4), RSMo, DHSS will be drafting a regulation regarding telephony. DHSS will be working closely with MMAC and the HCBS provider associations to gather input and feedback. After the rule is drafted, there will be a public comment period.

 

Additionally, if you are looking for information regarding telephony vendors that others in your industry are using, the associations will be able to assist you.

 

The statutory requirement for using telephony does not apply to Residential Care Facility Personal Care providers, Adult Day Care Centers, or Home Health providers.”

 

MMAC is committed to working with the provider industry and the Department of Health and Senior Services to assist our providers with the implementation of telephony.  As the memo states, MMAC will no longer require an addendum, as this was part of the pilot project.  We will not have a list of telephony vendors published on our website.  We will add an attestation statement to the provider agreements beginning July 1, 2015.

 

MMAC will incorporate telephony requirements into its pre-enrollment on-site visits, and its on-site audits.  Any questions or concerns may be sent to MMAC.IHSCONTRACTS@dss.mo.gov

 

UPDATE:  (JULY 6, 2015) AT THIS TIME MMAC WILL NOT BE ADDING AN ATTESTATION STATEMENT TO THE PROVIDER AGREEMENT AS STATED ABOVE.  FOR THE LATEST INFORMATION CLICK HERE.

Currently enrolled In-Home Services (IHS) and Consumer-Directed Services (CDS) providers’ participation agreements are valid for five (5) years.  This is consistent with re-validation requirements.  Most currently enrolled IHS and CDS providers have a renewal date of June 30, 2019.  Providers can check the date by looking at their copies of the participation agreements.

 

Missouri Medicaid Audit & Compliance (MMAC) has begun implementing new provider enrollment procedures including provider revalidation.  Any provider whose address has changed since initial enrollment should submit the updated information to MMAC by downloading the “Provider Update Request” form at https://mmac.mo.gov/providers/provider-enrollment/new-providers/provider-enrollment-forms/.  The completed forms can be scanned and sent by e-mail to mmac.providerenrollment@dss.mo.gov or they can be faxed to the Provider Enrollment Unit at (573) 751-5065.

 

Be sure to check MMAC’s website regularly to get information on upcoming changes and other helpful tips for MO HealthNet providers.

State and federal regulations require all currently enrolled Medicaid providers to revalidate their enrollment at least every five (5) years.  MMAC has established a revalidation schedule for all currently enrolled providers.  MMAC will contact currently enrolled providers approximately 120 days prior to their scheduled revalidation due date.  Instructions and forms will be provided by mail or e-mail.  More information on revalidation is available under the Providers tab here on our website.  Under the Providers tab, choose Provider Enrollment, and Revalidating Providers.