As reported in a previous gov.delivery message by Missouri Medicaid Audit and Compliance (MMAC), HMS will soon begin conducting credit balance audits on behalf of the Missouri Department of Social Services, MO HealthNet Division, (MHD) and MMAC. Click here to view the original message and website post.

 

When your long-term care facility is scheduled for an audit, MMAC will send a letter notifying you, before you receive any correspondence from HMS.  MMAC will also notify the Missouri Health Care Association and LeadingAge Missouri.  Long-term care facilities can expect to begin receiving letter regarding the credit balance audits after May 1, 2016.

 

Long-term care facility audits will be Medicaid-specific, and will be “desk audits”, where HMS will request that you send them information.  This means HMS will not come on-site to conduct the audit.

 

Providers will all have the opportunity for an entrance and exit conference, and MMAC and HMS will provide contact information for any questions, comments, or concerns that providers may have.

 

HMS has prepared its initial schedule for long-term care facility audits.

 

Review Start Date Provider Name 6/1/2013 BLUFFS (THE) 6/1/2013 GIDEON CARE CENTER 6/1/2013 GOWER CONVALESCENT CENTER 6/1/2013 LAVERNA VILLAGE OF ST JOSEPH 6/1/2013 LUTHERAN SENIOR SERVICES 6/1/2013 MARY QUEEN AND MOTHER CENTER 6/1/2013 MILAN HEALTH CARE CENTER 6/1/2013 VILLA MARIE-A STONEBRIGDE COMMUNITY 6/1/2013 VILLAGES OF JACKSON CREEK, THE 6/1/2013 WESTWOOD HILLS HEALTH & REHABILITATION C

 

If you have any questions, please contact MMAC at tricia.smith@dss.mo.gov

 

As reported in a previous gov.delivery message by Missouri Medicaid Audit and Compliance (MMAC), HMS will soon begin conducting credit balance audits on behalf of the Missouri Department of Social Services, MO HealthNet Division, (MHD) and MMAC. Click here to view the original message and website post.

 

When your hospital is scheduled for an audit, MMAC will send a letter notifying you, before you receive any correspondence from HMS.  MMAC will also notify the Missouri Hospital Association. Hospitals can expect to begin receiving letters regarding the credit balance audits after May 1, 2016.

 

Hospital audits will be Medicaid-specific, and may be desk audits, where HMS will request that you send them information; or, the audits may be completed on-site.

 

Providers will all have the opportunity for an entrance and exit conference, and MMAC and HMS will provide contact information for any questions, comments, or concerns that providers may have.

 

HMS has prepared its initial schedule for hospital credit balance audits.  Click here to view the schedule.

 

If you have any questions, please contact MMAC at tricia.smith@dss.mo.gov

What are Home and Community-Based Setting Requirements?

 

The Centers for Medicare & Medicaid Services (CMS) published a final rule to enhance the quality of Home and Community-Based Services (HCBS) and to provide protections for participants.  The rule, or “setting requirements” makes sure individuals receiving HCBS have full access to the benefits of community living and have the opportunity to receive services in the most integrated and still appropriate type of setting.

 

Missouri, like other states, is in a transition period, during which the state agencies will assess the HCBS programs, and the rules and regulations that govern the programs, to ensure services will be delivered in settings that meet the new requirements.

 

The Missouri Medicaid Audit and Compliance Unit (MMAC) is participating in the state’s transition plan and transition activities in the following ways:

 

MMAC conducted on-site visits of all the Adult Day Care and AIDS Waiver locations, and completed HCBS surveys with those providers.  You can access the report here.

 

 

MMAC will include the HCBS surveys in future pre-enrollment site visits and provider revalidation site-visits, for all HCBS providers.  This means MMAC personnel will go over the survey with you and give you the opportunity to ask questions and discover where you may need to make improvements in order to be compliant in the future when these requirements take effect.  The state is expected to promulgate rules that will require providers to be compliant with the new setting requirements.

 

MMAC will include the survey in future audits and investigations of HCBS providers to ensure we continue to monitor the locations for the new setting requirements as well. Auditors will provide you with the survey and go over it with you.  Investigators may be on-site in consumers’ and participants’ homes and will verify the services are being delivered in the most integrated and still appropriate setting.

 

MMAC will also provide education and information about the new setting requirements to all HCBS providers at Provider Update Training and Designated Manager Training.

 

MMAC is not citing any errors or violations at this time.  This is a transition time.  MMAC will give information about the new setting requirements and how to achieve compliance.  In the future, MMAC will inform providers about any new regulatory language that will require them to become compliant or face possible sanctions.

 

MMAC is also giving providers the opportunity to complete an annual self-assessment. In the future, MMAC will inform providers about any new regulatory language that will require them to complete the annual self-assessment or face possible sanctions.  Click here for the Annual Self-Assessment.

 

What else do providers need to know?

 

See below for links to the full content of the final rule, including all the requirements.  Some highlights:

 

Home and Community-Based settings will be expected to be integrated in the community, and support access to the greater community.

 

The HCBS setting should also provide opportunities to seek employment and work in competitive integrated settings, engage in community life, and control personal resources.

 

The HCBS setting should ensure the participant’s or consumer’s rights of privacy, dignity, respect, and freedom from coercion and restraint.

 

Participants and consumers should be able to have visitors at any time.

 

The setting should be physically accessible to the participants and consumers.

 

Additional Resources:

 

Click here to see a PowerPoint presentation of the final rule and the new requirements.

 

Click here to be directed to the MO HealthNet Division’s webpage where you can access the state’s Transition Plan, Transition Plan Summary, and Settings Analysis (see Alerts and Notifications).

 

Click here to see more information about Home & Community Based Services, including the final rule, and questions and answers at Medicaid.gov.

Credit balances on patient accounts occur for a variety of reasons.  For instance, providers sometimes receive duplicate payments, charges may be reversed, billing data may be incomplete, and third party liabilities may be incorrectly applied.  Providers routinely identify and refund these credit balances (overpayments), but sometimes the ability to refund the overpayment in a timely fashion is constrained by limited resources or imperfect information.  Sometimes, providers aren’t aware the overpayments exist.  Not all credit balances result in an overpayment, and out of those, not all require a refund; some simply require an adjustment.

 

HMS will soon begin conducting credit balance audits, on behalf of the Missouri Department of Social Services, MO HealthNet Division, (MHD) and Missouri Medicaid Audit and Compliance (MMAC).  When your hospital or nursing home is scheduled for an audit, MMAC will send a letter notifying you, before you receive any correspondence from HMS.  MMAC will also notify the Missouri Hospital Association, Missouri Health Care Association, and LeadingAge Missouri.

 

Nursing home audits will be conducted as “desk audits”.  This means that HMS will review the patient accounts off-site after receiving any necessary documentation from the nursing home.  These audits will be specific to Medicaid patients (participants.)

 

Hospital audits will be Medicaid-specific, as well.  Hospital audits may be desk audits, or they may be completed on-site.

 

Providers will all have the opportunity for an entrance and exit conference, and MMAC and HMS will provide contact information for any questions, comments, or concerns that providers may have.

 

Missouri State Regulation requires documentation of a pharmacist’s offer to counsel, for all MO HealthNet participants’ prescriptions.  The regulation states, “Documentation of Offer to Counsel:  The pharmacist shall document for each MO HealthNet patient’s prescription in a uniform fashion, whether the offer to counsel was accepted or refused by the patient or the patent’s agent. “  Click here to read the regulation:  13 CSR 70-20.310(7).

 

Additionally, pharmacies must obtain the signature of the participant or his/her representative, and the relationship of the representative to the participant.  Participants living in long-term care facilities such as nursing facilities, ICF/MR facilities, and psychiatric residential treatment facilities are granted an exemption from this requirement.

 

The signature log serves as verification that the participant received the prescription dispensed.  One signature per prescription is required, and electronic signatures are acceptable.  Providers must make the signature log and offer to counsel available upon request by MO HealthNet or MMAC.  More information about signature log requirements is found in the MO HealthNet Pharmacy Manual.  Click here to access the manual.

 

Please contact Missouri Medicaid Audit and Compliance (MMAC) at MMAC.PROVIDERREVIEW@DSS.MO.GOV  if you have any questions

The 2016 Spring Session of the Annual Provider Update Meeting for Home and Community Based Providers (HCBS), hosted by Missouri Medicaid Audit and Compliance (MMAC) is scheduled for April 19, 20, and 21, 2016.  Click here for information about the meeting.

 

A new feature for providers has been added to the MMAC website at the location (link) above.  Copies of the meeting’s Power Point presentations and handout materials are posted to the website.  Providers may review the materials prior to the meeting, and make copies to bring with them if they choose.  The materials will not be handed out at the meeting in order to save resources, so please bring a copy with you if you wish to have it during the meeting.  The materials will be projected for viewing during the presentations.

 

If you have any questions, please contact MMAC at MMAC.IHSContracts@dss.mo.gov

Missouri Medicaid Audit and Compliance (MMAC) is responsible for reviewing Medicaid (MO HealthNet) participants who may be subjecting the Medicaid program to fraud, waste, and abuse due to mis-utilizing or over-utilizing some of their MO HealthNet benefits.  MMAC will review the number of physicians prescribing services to a particular participant, the number of pharmacies used by the participant to obtain prescriptions, the frequency of refills or overlapping prescriptions, the number of emergency room visits, and the services received by the participant. 

 

If a MO HealthNet participant is determined to by mis-utilizing MO HealthNet benefits, he or she can be restricted to a physician/clinic, pharmacy, or both, in accordance with 13 CSR 70-4.070.  This restriction is called “Locked In”.  The Lock-In program is also described in the MO HealthNet Physician Manual.

 

When a participant is “locked in” to a specific provider, the provider’s name and telephone number are identified on the internet, IVR, or point of service terminal used when verifying eligibility.  Payment for services for a “locked-in” participant will not be made to unauthorized providers, except for emergency services, and authorized referral services.  Emergency services must be supported by medical records documenting the emergency circumstances.

 

The designated (authorized) “lock-in” provider is responsible for the participant’s primary care and for making necessary referrals to other providers as medically indicated.  When a referral is necessary, the authorized physician must complete a Medical Referral Form of Restricted Participant (PI-118) and send it to the provider to whom the participant is referred. 

 

The referral forms are available on the MMAC website.  Click here to access the forms.

 

The referral is good for 30 days only from the date of service.  The Reason for Referral field should be completed on the form, and the form must contain the NPI (and taxonomy code if appropriate) of the authorized provider.  If the participant is locked into a clinic, use the clinic’s NPI (not the individual physician’s).  The form must be submitted by  the unauthorized provider via the internet at www.emomed.com, or mailed to Infocrossing Healthcare Services, P.O. Box 5900, Jefferson City, MO 65102.

 

Read more about the Participant Lock-In Program at the MMAC website.

 

RCFs  and ALFs enrolled with Missouri Medicaid (MO HealthNet) may receive payments for personal care services provided in the facilities.  Missouri Medicaid Audit and Compliance (MMAC) may conduct an on-site audit or a desk review to determine whether the services were properly documented and billed, and that providers were paid appropriately.   An on-site audit means MMAC auditors will conduct an on-site visit, and scan the needed documentation.  A desk audit means MMAC will request records be sent by mail, fax, or email, without coming on-site.  To view the complete MMAC Provider On-Site and Desk Audits Guidance and Reference Material, click here.

 

For an RCF or ALF audit, MMAC auditors will generally ask to see the following documentation:

 

The care plan (Web Tool print-out or LTACS) for each participant, that corresponds with the review period EVV (Telephony) is not required for RCFs or ALFs Any and all documents that support services billed for each participant, for dates of service in the review period.  These may be timesheets, calendars, call-in logs, service delivery logs, or any other documents deemed necessary to complete the review.  MMAC auditors know that some providers use different names for documentation, and will communicate with you if they feel something is missing. A service delivery log must include the participant’s name, date of service (including the year), documentation of tasks performed, and appropriate daily signatures Census records.  If there are no census records, the auditors will request the medication administration records or nurse’s notes for the time period being reviewed Documentation of appropriate employee background (screening) checks, and documentation of a Good Cause Waiver if required A list of all employees who provided services during the review period (complete name, address, date of hire, date of first client contact, and termination date if applicable) Documentation of authorized nurse visits

 

MMAC auditors will use the following statute, regulations, and provider manual while reviewing the billing and the documentation for compliance:

 

RSMo 192.2495.2 13 CSR 70-3.030 13 CSR 70-91.010 19 CSR 30-86.042 19 CSR 30-82.060 MO HealthNet Provider Manual for Personal Care 

 

Missouri Medicaid Audit and Compliance (MMAC) is holding the spring session of the 2016 Annual Provider Update Meeting for Home and Community Based Providers on April 19, 20, and 21, 2016.  The presentation runs from 10:00 a.m. to 3:00 p.m. each day.

 

You are not required to attend all three days.  Attend either the 19th, the 20th, or the 21st.

 

The meeting will be held at the Harry S. Truman State Office Building at 301 West High Street in Jefferson City, MO.  You can access the driving directions at the MMAC website by clicking here.

Each year,  Missouri Medicaid Audit and Compliance (MMAC) sends “DRA Attestations” to Medicaid providers that received at least five (5) million dollars in annual Medicaid payments during the previous federal fiscal year.

 

The Deficit Reduction Act (DRA) of 2005 states that those providers (receiving at least $5 million in payments) shall:

 

establish written policies for all employees about the False Claims Act include provisions in those policies about how to detect and prevent fraud, waste, and abuse, and include this information in any employee handbook

 

State regulation requires Medicaid providers to make an annual attestation of compliance with these requirements, by March 1 of each year.  If you received an annual attestation form and have not completed it and returned it to MMAC, you will receive a second notice, providing you with another opportunity to comply.  MMAC encourages providers who receive the annual attestation to complete it and return it, in order to avoid any possible sanctions.

 

Click here to read the regulation.

 

Click here to read about the Deficit Reduction Act.

 

If you have any questions, please contact MMAC at  dss.mmac.compliance@dss.mo.gov