As a reminder, all Consumer Directed Service (CDS) providers are required to file quarterly and annual reports.

 

 

For your convenience, these reports may now be submitted to our new e-mail address or fax at:

 

EMAIL:                    MMAC.CDS@DSS.MO.GOV

FAX:                          573-526-4375

Mailing address:     205 Jefferson Street, 2nd Floor, P.O. Box 6500, Jefferson City, MO 65012

 

 

The CDS Quarterly Financial & Service Report and CDS Annual Service Report have been updated and are posted on MMAC’s website at

https://mmac.mo.gov/providers/provider-enrollment/home-and-community-based-services/provider-contracts-forms/

 

Due date for CDS Quarterly Financial & Service Report is on a calendar year as follows:

 

January 1 through March 31, due by April 30th

April 1 through June 30, due by July 31st

July 1 through September 30, due by October 31st

October 1 through December 31, due by January 31st

 

 

The CDS Annual Service Report for January 1 through December 31 is due by January 31st of the following year.

 

Before submitting reports, please review for completeness and that the form has been signed (print the name and title of the person signing under the signature).

The Level of Care Transformation Project Web Page has been updated by the Department of Health and Senior Services (DHSS), Division of Senior and Disability Services (DSDS) and includes the Level of Care (LOC) Transformation Project – Draft LOC Algorithm Release Memo, as well as Level of Care (LOC) Presentations, Video Tutorial, and LOC Algorithm and the Survey.

 

 The goal of the Level of Care Transformation Project is to review all aspects of the HCBS assessment process to ensure the right services are provided to the right individuals at the right time. DSDS is now asking HCBS providers and other stakeholders to assist in this effort.

 

Questions should be directed to the Bureau of Long Term Services and Supports at (573) 526-8557 or via e-mail at LOCTransformation@health.mo.gov

State and federal regulations (13 CSR 65-2 and 42 CFR 455.460) require Missouri Medicaid Audit and Compliance (MMAC) to collect an application fee 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.

 

The application fee is currently set at $569.00, and it will increase to $586.00 on January 1, 2019.

 

Click here to read more about the application fee and hardship waivers

 

MMAC is pleased to announce that a new Provider Revalidation Portal will be available for MO HealthNet providers starting January 7, 2019.  Federal and state regulations require all providers to revalidate their Medicaid enrollment at least every five years.  To make that process quicker and easier, providers will be able to complete their revalidation applications using the same EMOMED portal that is used to submit electronic claims to MO HealthNet.  Approximately 15,000 of the 60,000+ currently enrolled MO HealthNet providers will need to complete revalidation by June 30, 2019.

 

Starting January 7, 2019, emails will be sent to providers and administrators; letting them know a provider they manage is due for revalidation.  The email will direct the providers and administrators to sign onto EMOMED and access the Revalidations Portal to see which of their providers need to revalidate.  The providers and administrators will be able to view the provider’s current enrollment information.  They will be able to edit any outdated or incorrect information, verify the updated information, and upload any required documentation needed to complete the revalidations process.  They will then be able to submit the completed revalidation application to MMAC via EMOMED.

 

Additional information will be posted under the Revalidations section of MMAC’s web page on January 7th.  The entire MMAC team wishes everyone a safe and happy holiday season !!

 

Warmest Regards – Dale Carr, MMAC Director

HB1350 was enacted into law as section 192.2495 RSMo effective August 28, 2018.

 

Providers are responsible for ensuring aides are registered with the Family Care Safety Registry (FCSR), that screenings are done at the time of hire and before any contact with a participant, and an application for a Good Cause (GCW) has been submitted, if applicable.  It is also a good business practice to check the FCSR annually.  Documentation of the FCSR screening and GCW, if applicable, must be maintained by the provider for five years and be readily available when requested by MMAC.  One suggested way of documenting the decision is to make a note on the screening with the date and name of the person that reviewed the information.

 

Under section 192.2495, not every finding (hit) requires a GCW.  For example, local ordinance violations, misdemeanor DWIs, and most other misdemeanors do not require a GCW.  Even if the crime is not listed below and is considered a lesser crime, the provider may choose not to hire an applicant.  Most court reports list the state statute that was violated under the headings “State Code” and “Statute Citation”.  Comparing the state statute found on the report to the list below will help guide the provider in deciding if a GCW is required.

 

Per section 192.2495 RSMo, anyone who has been found guilty, plead guilty, or plead nolo contendere to any felony violations under the RSMo sections listed below must obtain a GCW.

 

568.045 Endangering the welfare of a child in the first degree 568.050 Endangering the welfare of a child in the second degree 568.060 Abuse or neglect of a child 568.175 Trafficking in children 570.025 Robbery in the second degree 570.023 Robbery in the first degree 570.030 Stealing 570.040 Stealing 3rd offense (prior to January 1, 2017) 570.090 Forgery 570.145 Financial exploitation of the elderly person or person with a disability 570.23 Identity theft 576.080 Supporting terrorism 577.010 Driving while intoxicated or 577.012 Driving with excessive blood alcohol content and who is alleged and found by the court to be an aggravated or chronic offender under section 577.023 (Felony DWI) Any felony offense under section 579 or (previously) Chapter 195 Any offense (including misdemeanors) requiring registration under section 589.400

 

Anyone who is listed on the department of mental health employee disqualification registry under section 630.170; or has a finding on the child abuse and neglect registry under sections 210.109 to 210.183 must also obtain a GCW.

 

Employee background screening requirements may vary slightly among different programs, and it is important for providers to conduct background screenings appropriately.  The following regulation sections describe requirements for providers ensuring aides are registered with the Family Care Safety Registry (FCSR), that screenings are done at the time of hire, and when a Good Cause Waiver must be requested.  Background screening requirements for in-home services aides are found at 19 CSR 15-7.021 (24) (A) 4 and 19 CSR 15-8.400 for CDS attendants.  Also see section  192.2495 RSMoPersonal Care Manual, and Division of Senior and Disability Services Memo PN-18-17, VM-18-17 dated August 28, 2018.

Applicants desiring to contract with MO HealthNet for the purpose of providing In-Home Personal Care Services (IHS) or Consumer Directed Services (CDS) to Medicaid participants are required by 19 CSR 15-7.021(5) to submit a complete proposal packet to Missouri Medicaid Audit & Compliance (MMAC).  Previously, applicants paid the Medicaid enrollment application fee at the time they submitted their proposal.

 

Effective Monday, October 15, 2018, applicants submitting IHS or CDS proposals will no longer be required to submit the enrollment application fee with their proposal packet; it will be submitted later after the proposal has been approved.  MMAC will refund or return any application fees received with a new proposal packet after October 15th.  Applicants who submitted their IHS or CDS proposal prior to October 15th and paid the enrollment will not have their enrollment application fee returned unless their proposal is rejected; it will be applied to their Medicaid application once their proposal has been approved.

 

The MMAC Contracts Unit will send the applicant an email acknowledging receipt of a proposal packet.  The proposal will be evaluated for completeness and compliance with the program requirements for the type of contract being sought.  Applicants should review the proposal requirements and program guidance available on MMAC’s website (IHS and CDS Proposal Information) and make sure they are submitting all required documents.  Applicants also need to keep a copy all documents submitted as part of their proposal packet.

 

Incomplete or non-compliant proposals will be rejected by the MMAC Contracts staff.  Applicants will receive a letter or email from MMAC identifying any parts of their proposal packet that do not meet program requirements.  The rejected proposal will not be returned by MMAC.  Applicants will be required to submit a new and complete IHS or CDS proposal packet to MMAC.

 

Once an IHS or CDS proposal packet has been accepted and approved by MMAC, the applicant will be asked to submit the required Medicaid provider enrollment forms and enrollment fee.

 

Questions regarding proposals or Medicaid enrollment for Home and Community Based Services should be sent to MMAC.IHSContracts@dss.mo.gov

Current state and federal regulations (13 CSR 65-2 and 42 CFR § 455.410) require Ordering, Prescribing, or Referring (OPR) physicians or other professionals providing services under the state plan or under a waiver of the plan to be enrolled as participating providers with the state Medicaid agency.  Federal regulation 42 CFR § 455.440 requires all Medicaid claims for payment of items and services that were ordered, prescribed, or referred to contain the National Provider Identifier (NPI) of the physician or other professional who ordered, prescribed, or referred such items or services.

 

Drug claims with a date of service on or after October 14, 2018, will deny unless the prescriber is actively enrolled with MO HealthNet.

 

All outpatient or medical claims billed using the National Drug Codes (NDC) with the appropriate HCPCS or CPT procedure code for the medication administered must also contain an actively enrolled MO HealthNet prescriber.  This includes but is not limited to C-codes, G-codes, J-codes, Q-codes, S-codes and non-VFC vaccination CPT codes.  For medications billed on outpatient claims the attending provider is treated as the prescriber and for medical claims the rendering provider is used.

 

In addition, effective October 14, 2018, MO HealthNet will no longer accept a Drug Enforcement Administration (DEA) number in the “Prescribing Provider ID” field on drug claims.  Providers must submit the actively enrolled prescribing provider’s NPI in the “Prescribing Provider ID” field.  Claims submitted with a date of service on or after the effective date with a DEA number in the “Prescribing Provider ID” field will deny.

 

The Missouri Medicaid Audit and Compliance Unit (MMAC) provides an OPR Application that can be downloaded (link) or utilized as a fillable PDF form (link).  MMAC’s provider enrollment personnel will expedite all OPR applications received.  Please fax completed applications to (573) 634-3105.

 

Authorization for emergency medications only may be obtained by contacting Pharmacy and Clinical Services at (573) 751-6963.  Prescribers should immediately submit an OPR application to MMAC or a subsequent override authorization may be denied.

 

The “Medicaid and CHIP Managed Care Final Rule” and 42 CFR 438.602(b)(1), require states to screen and enroll, and periodically revalidate, all network providers of Managed Care Organizations (MCOs); including Ordering, Prescribing, and Referring (OPR) providers.  This requirement was effective January 1, 2018.  Missouri Medicaid Audit & Compliance (MMAC) enrolls all health care providers for the Missouri Medicaid program operated by MO HealthNet.

 

The MCOs contracted with MO HealthNet have been notified that their network providers need to be enrolled with MMAC, or have submitted an enrollment application to MMAC, by the close of business on October 31, 2018.  The MCOs have been directed to remove any of their network providers who have not submitted an enrollment application to MMAC by that date.

 

Providers enrolled with any of the three MCOs contracted with MO HealthNet, but who are not yet enrolled with MMAC, should do so before the deadline.  MMAC has streamlined MCO network provider application forms for individual providers (Individual Application) or organizational providers (Organizational Application).  Providers completing the MCO network provider enrollment application will not submit claims to MO HealthNet, nor will they be required to provide any services to Medicaid Fee for Service participants.

 

Providers who are enrolled with MCOs under more than one National Provider Identifier (NPI) will need to make sure each of those NPI numbers are enrolled with MMAC.

 

Any questions regarding enrolling with MMAC as a MCO Network Provider should be submitted to MMAC.ProviderEnrollment@dss.mo.gov

The Missouri Medicaid Audit and Compliance (MMAC) unit conducts post-payment reviews (audits) of Medicaid-enrolled providers’ billing.  As a service to our enrolled providers, MMAC wishes to remind providers of the requirements to file and pay taxes.   

 

Consumer Directed Services (CDS) providers/vendors are required to pay taxes on behalf of the participant. You may find the requirements in the following areas:

Paragraph 5.25 of your company’s Participation Agreement for Home and Community Based Care to provide Consumer Directed Services requires you to “… perform all services under this Agreement in compliance with this Agreement and in compliance with all applicable state and federal statutes and all regulations lawfully promulgated.”

 

19 CSR 15‐400(2) states “Vendors shall perform, directly or by contract, payroll and fringe benefit accounting functions for consumer, including but not limited to: (C) Ensuring all payroll, employment and other taxes are paid timely.”

 

The three main oversight entities who the provider will deal with are the Internal Revenue Service (IRS), Missouri Department of Revenue (DOR) and Division of Employment Security. Providers are also responsible for City taxes, if applicable.

 

The EIN number is not the property of the CDS provider but belongs to the participant. When a participant changes providers, the current provider should notify the IRS, DOR and Division of Employment Security that they are no longer serving the participant. When the provider receives a release from the new provider, they should supply the requested information.  It’s MMAC’s expectation that providers work in a cooperative effort to make this a seamless process.

 

Documentation of paid taxes must be maintained by the provider for five (5) years in a secure location that is easily accessible so the documents may be produced for audit purposes.

 

Helpful websites:

IRS:   https://www.irs.gov/filing

DOR:   https://openforbiz.mo.gov/

Division of Employment Security:   https://labor.mo.gov/des

IRS number the participant can call if they have lost or misplaced their EIN – 800-829-4933

MMAC employees conduct announced or unannounced reviews (audits) of MO HealthNet providers to collect documentation supporting claims that were submitted for services provided to Medicaid participants.  Providers are increasing utilization of Electronic Health Record (EHR) and/or Electronic Visit Verification (EVV) systems to generate and retain their documentation of services provided.  Those records are usually pulled up on the EHR or EVV system by one of the provider’s authorized users and then transferred onto a CD, DVD, or thumb drive for MMAC personnel.

 

MMAC is noticing that the staff responsible for managing providers’ EHR and/or EVV systems frequently encounter difficulties producing the requested records during MMAC’s visit.  MMAC encourages all MO HealthNet providers to make sure appropriate staff are familiar with their EHR or EVV system and know how to retrieve and transfer records for specified Medicaid participants and service dates.