Missouri Governor Parson approved Executive Order 20-04 on March 19, 2020, waiving 13 CSR 65-2.020(5) and 13 CSR 65-2.020(9) to allow the Missouri Medicaid Audit and Compliance Unit to expedite new provider enrollment applications and to waive certain requirements such as application fees and onsite visits. The Order was effective March 1, 2020 through May 15, 2020, “unless extended in whole or in part.”

MMAC did not request an extension to our part of the order, and resumed regular enrollment and revalidation activities after May 15, 2020.

On August 26, 2020, the Missouri Department of Health and Senior Services (DHSS), Division of Senior and Disability Services (DSDS), issued Directive 3.25 (Appendix 1) for Consumer Directed Services (CDS) Tax Information Documentation Requirements. DSDS directed all CDS vendors to upload proof of the assignment of a Federal Employer Identification Number (FEIN) and a Missouri Tax Information Number (MO-TIN) for each CDS participant into the Home and Community Based Services (HCBS) Web Tool.

 

The DSDS Directive can be located here. HCBS Section 3.25, Appendix 1, with detailed information for CDS vendors on uploading the tax numbers can be located here.

 

CDS vendors who do not upload their participants’ federal and state employer tax ID numbers to the HCBS Web Tool within the timeframes specified in HCBS Section 3.25, Appendix 1, will be subject to administrative sanctions including, but not limited to, suspension of their Medicaid payments or participation in the CDS program.

 

Any questions should be directed to the DSDS Bureau of Long Term Services and Supports via email at LTSS@health.mo.gov

Section 12006(a) of the 21st Century Cures Act (Cures Act) mandated that states implement Electronic Visit Verification (EVV) for all Medicaid PCS by January 1, 2020. Missouri applied for and received a Good Faith Effort Exemption from the Centers for Medicare and Medicaid (CMS) to delay mandated use of EVV for one additional year.

Effective January 1, 2021, the use of EVV is mandatory for all Medicaid PCS in Missouri. This applies to PCS provided under sections 1905(a) (24), 1915(c), 1915(j), 1915(k), and Section 1115 of the Social Security Act. 

Effective January 1, 2021, Medicaid participants cannot opt out of using the PCS provider’s EVV system. Providers must submit notice to MMAC of any participants who refuse to use EVV after the effective date.

Beginning January 30, 2021, Missouri Code of State Regulations (CSR) 13 70-3.320 will contain additional requirements for use of EVV for PCS services provided to Missouri Medicaid participants with a prior authorization, or care plan, as approved by the Department of Health and Senior Services (DHSS), Division of Senior and Disability Services (DSDS); or the Department of Mental Health (DMH), Division of Developmental Disabilities (DD). The new regulation was posted in the Missouri Register on 12/15/2020. Although the new state regulation is not effective until January 30, 2021; the federal requirements under the Cures Act are effective January 1st and have not been waived or extended due to the COVID emergency.

In addition to the services authorized by DSDS and DMH, PCS authorized by the Bureau of Special Health Care Needs and the Bureau of HIV, STD and Hepatitis of DHSS must be verified through use of an EVV system in order to comply with the CURES Act.

In order to submit PCS claims, a provider’s EVV system must verify the following:

Type of PCS performed with details specific to tasks Identity of the individual receiving the service Identity of the individual providing the service Date the service was provided Time delivery of PCS began and ended Location where the service was delivered

The Missouri Medicaid Audit & Compliance (MMAC) unit created a one page, fillable EVV Attestation Form, which is available at www.mmac.mo.gov. PCS providers can submit one form for all their enrolled National Provider Identifiers (NPIs), as long as all NPIs are using the same EVV system.

All PCS providers need to take the following actions:

Prior to January 1, 2021, all PCS providers must submit an EVV Attestation Form to MMAC by emailing it to MMAC.EVV@dss.mo.gov  Any PCS provider that will not be using an EVV system by January 1, 2021, must submit written notice to MMAC.EVV@dss.mo.gov that date. Failure to utilize EVV is a Medicaid program violation that will result in administrative sanctions. Any PCS provider that is unable to utilize their EVV system for a specific Medicaid participant(s) due to a technology issue, must submit written notice to MMAC.EVV@dss.mo.gov by January 1, 2021. DSDS will locate another PCS provider offering EVV technology that works for the participant. PCS providers must report to MMAC any Medicaid participant(s) who refuses to utilize the provider’s EVV system after January 1, 2021. The PCS provider should submit written notification to MMAC.EVV@dss.mo.gov. Medicaid claims submitted after January 1, 2021, for any participant that refuses to utilize EVV will be denied/recouped. 

PCS providers who fail to submit an EVV Attestation Form to MMAC, or fail to provide notification of one of the circumstances listed above, will be subject to one or more administrative sanctions listed in 13 CSR 70-3.030(4).

MO HealthNet has an EVV website with additional information, including EVV Fact Sheets for providers and Medicaid participants. DMH also has an EVV website with more information for providers delivering PCS to DD participants.

Providers can email questions about EVV to Ask.EVV@dss.mo.gov

Electronic Visit Verification (EVV) is a method of utilizing technology to capture point of service information related to the delivery of personal care services, including homemaker chores and respite (PCS).

Section 12006(a) of the 21st Century Cures Act (Cures Act) mandated that states implement EVV for all Medicaid personal care services by January 1, 2020. Missouri applied for and received a Good Faith Effort Exemption from the Centers for Medicare and Medicaid (CMS) to delay mandated use of EVV for one additional year.

Effective January 1, 2021, the use of EVV is mandatory for all Medicaid PCS in Missouri. This applies to PCS provided under sections 1905(a) (24), 1915(c), 1915(j), 1915(k), and Section 1115 of the Social Security Act.

Effective January 1, 2021, Medicaid participants cannot opt out of using the PCS provider’s EVV system. Providers must submit notice to MMAC of any participants who refuse to use EVV after the effective date.

Beginning January 30, 2021, Missouri Code of State Regulations (CSR) 13 70-3.320 will contain additional requirements for use of EVV for PCS services provided to Missouri Medicaid participants with a prior authorization, or care plan, as approved by the Department of Health and Senior Services (DHSS), Division of Senior and Disability Services (DSDS); or the Department of Mental Health (DMH), Division of Developmental Disabilities (DD). The new regulation will be posted in the Missouri Register on 12/15/2020.

In addition to the services authorized by DSDS and DMH, PCS authorized by the Bureau of Special Health Care Needs and the Bureau of HIV, STD and Hepatitis of DHSS must be verified through use of an EVV system in order to comply with the CURES Act.

In order to submit PCS claims, a provider’s EVV system must verify the following:

Type of PCS performed with details specific to tasks Identity of the individual receiving the service Identity of the individual providing the service Date the service was provided Time delivery of PCS began and ended Location where the service was delivered

The Missouri Medicaid Audit & Compliance (MMAC) unit has created a one page, fillable EVV Attestation Form, which is available at www.mmac.mo.gov. PCS providers can submit one form for all their enrolled National Provider Identifiers (NPIs), as long as all NPIs are using the same EVV system.

All PCS providers need to take the following actions:

Prior to January 1, 2021, all PCS providers must submit an EVV Attestation Form to MMAC by emailing it to MMAC.EVV@dss.mo.gov

Any PCS provider that will not be using an EVV system by January 1, 2021, must submit written notice to MMAC.EVV@dss.mo.gov that date. Failure to utilize EVV is a Medicaid program violation that will result in administrative sanctions.

Any PCS provider that is unable to utilize their EVV system for a specific Medicaid participant(s) due to a technology issue, must submit written notice to MMAC.EVV@dss.mo.gov by January 1, 2021. DSDS will locate another PCS provider offering EVV technology that works for the participant.

PCS providers must report to MMAC any Medicaid participant(s) who refuses to utilize the provider’s EVV system after January 1, 2021. The PCS provider should submit written notification to MMAC.EVV@dss.mo.gov. Medicaid claims submitted after January 1, 2021, for any participant that refuses to utilize EVV will be denied/recouped. 

PCS providers who fail to submit an EVV Attestation Form to MMAC, or fail to provide notification of one of the circumstances listed above, will be subject to one or more administrative sanctions listed in 13 CSR 70-3.030(4).

MO HealthNet has an EVV website with additional information, including EVV Fact Sheets for providers and Medicaid participants. DMH also has an EVV website with more information for providers delivering PCS to DD participants.

Providers can email questions about EVV to Ask.EVV@dss.mo.gov

MO HealthNet providers must retain for six years (seven years for the Nursing Home, CSTAR and Community Psychiatric Rehabilitation Programs), from the date of service, fiscal and medical records that coincide with and fully document services billed to the Missouri Medicaid program, and must furnish or make the records available for inspection or audit by the Department of Social Services, Missouri Medicaid Audit and Compliance Unit (MMAC) or its representative upon request.

Failure to furnish, reveal and retain adequate documentation for services billed to MO HealthNet may result in recovery of the payments for those services and may result in additional sanctions to the provider’s participation in the MO HealthNet program. This policy continues to apply in the event of the provider’s discontinuance as an actively participating MO HealthNet provider, change of ownership and/or management, or any other circumstance.

In addition, MMAC requests that any provider who believes their documentation in support of servicing Missouri Medicaid participants is no longer available, due to extenuating circumstances or unforeseen events, complete and submit an Attestation of Medical Record Loss or Destruction Form that can be found here:

https://mmac.mo.gov/providers/provider-enrollment/new-providers/provider-enrollment-forms

Providers who are deactivating their MO HealthNet enrollment or changing owner/managers will be asked to inform the MMAC Provider Enrollment Unit (PEU) of the physical location of their Medicaid records, along with the name and contact information for the custodian of those records.

 

Any questions should be directed to MMAC at MMAC.ProviderEnrollment@dss.mo.gov

Registration is now open for the September 17, 2020 CDS Orientation Training session. This training will be held online. To register please go to https://mmac.mo.gov/providers/hcbs-provider-certification-training/

If you had already registered for the March 26th session, you will automatically be enrolled for this session.

Registration is now open for the September 29, 2020 Designated Manager Testing session. This test will be administered online. To register please go to https://mmac.mo.gov/providers/hcbs-provider-certification-training/  

If you had already registered for the June 10th  session, you will automatically be enrolled for this session.