For home and community based providers, Missouri Medicaid Audit and Compliance (MMAC) wishes to provide the following audit guidelines. We hope this will assist you with preparation for an audit, and also help you properly retain adequate documentation and help you bill MO HealthNet properly, regardless of whether you are subject to an audit or not.
MMAC will notify you of an on-site audit prior to arrival, in most instances. Unannounced audits are rare. MMAC will accommodate your needs and schedule, within reason. We will generally provide you a partial list of participants and dates of services that are part of our review (audit.) This is so you can begin to prepare and pull records prior to our arrival. We will send this partial list to you by fax or email. We will provide the complete list upon arrival. MMAC generally needs a place for two auditors and their two laptop computers and scanners, in order to properly scan records.
The following items are typically the items MMAC will request and review:
The plan of care, or Web Tool print-out (or LTACS) for each participant being reviewed, within the review period Any and all documents that support services billed for each participant, for the dates of service within the review period. This may include timesheets, whether paper or EVV (telephony), or any other supporting documents Copies of the initial employee FCSR screenings, (for employees who are part of the review period) Copies of Good Cause Waiver requests and their outcomes (for employees who are part of the review period) Documentation to support billing for Authorized Nurse Visits MMAC may also request one complete participant file and one complete employee file while on-site
For Residential Care Facilities (RCFs):
MMAC may request service delivery logs, and/or any documents that show services provided MMAC may request census records, medication administration records, or nurse’s notes for the time period being reviewed MMAC may request evidence of employee background screening
As well, for quality assurance purposes, MMAC may request
Documentation for two employees or attendants which verifies initial and ongoing training requirements were met. This includes classroom training and on the job training. This also includes any training waivers and those supporting documents Verification of liability insurance and a dishonesty bond
For Consumer Directed Services (CDS) vendors:
A verification that the consumer was trained by the provider regarding recruiting, hiring, supervising the attendant, etc. A verification that the appropriate tax forms have been complete and are on file with the vendorMissouri Medicaid Audit and Compliance (MMAC) has been working closely with the Department of Health and Senior Services (DHSS), Division of Senior and Disability Services (DSDS), while they draft a regulation to govern the telephony requirements for In-Home and Consumer-Directed Services providers. MMAC and DSDS have been working closely with the provider associations, as well, to answer providers’ questions and provide guidance.
The Missouri Alliance for Home Care (MAHC), along with their CDS and State Programs Task Forces, created a tool for In-Home and CDS providers entitled “Questions to Ask Potential Telephony (EVV) Vendors”. This tool can be used as a resource to help providers in their decision making process
Click (here) to view the Tool.
MMAC does not approve telephony vendors; therefore, we encourage providers to become informed about the available products. Questions may be submitted to MMAC at mmac.ihscontracts@dss.mo.gov and we will assist you as you implement telephony.
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.
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.
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 and Compliance (MMAC) conducts post-payment reviews (audits) of Medicaid-enrolled providers’ billing. As a service to our enrolled providers, MMAC wishes to remind providers of several requirements, and the regulatory language that provides instruction to providers.
Reminders:
Requirements are slightly different for “individual worker delivery records” (in-home services) and “time-sheets” (Consumer Directed Services). Both are commonly referred to as time-sheets. There is no standard required time-sheet for either program, but there are certain requirements. Requirements for in-home services are found at 19 CSR 15-7.021 (24)(A) and those for CDS are found at 19 CSR 15-8. These sections cover the requirements for signatures, dates of service, in and out times, and documenting tasks performed.
13 CSR 70-91.010 covers the requirements for Separately Authorized Nurses Visits, and the required documentation. The authorized nurse visit services must include one or more specified services, and the documentation shall include written notes and observations.
13 CSR 70-3.030 contains valuable information that can assist providers with their billing procedures. The regulation reminds providers to take reasonable measures to review claims for payment for accuracy, duplication, or other errors caused or committed by employees when the failure allows material errors in billing to occur (13 CSR 70-030(3)(A)(31).
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 (4) (A) 4 and 19 CSR 15-7.021 (19) (G) and for CDS attendants, they are found at 19 CSR 15-8.400 (4) (A) 1.
In 2010, the Missouri Department of Health and Senior Services established a pilot project for In-Home Services and Consumer Directed Services providers to test the implementation of electronic telephone tracking systems, also known as “telephony”. Participation in this pilot project was voluntary. Therefore, some providers are currently utilizing telephony, but many are not.
Missouri law states that all providers, by July 1, 2015, shall have, maintain, and use a telephone tracking system for the purpose of reporting and verifying the delivery of services. (See Statute 660, section 660.023 for In-Home Services and Statute 208, sections 208.909 and 208.918 for Consumer Directed Services.) In anticipation of the upcoming telephony mandate, MMAC has compiled information for providers who are still researching the implementation of a telephone tracking system (“telephony”).
These statutes define specific requirements that a telephony system must meet, in order to be implemented by an IHS or CDS provider. They say, at a minimum, the telephone tracking system shall:
Record the exact date services are delivered. Record the exact time the services begin and the exact time the services end. Verify the telephone number from which the services were registered. Verify that the number from which the call is placed is a telephone number unique to the client. Require a personal identification number unique to each personal care attendant. Be capable of producing reports of services delivered, tasks performed, client identity, beginning and ending times of service, and date of service in summary fashion that constitute adequate documentation of service.
The Department of Health and Senior Services’ pilot project also included the following requirements:
All calls made from each client’s telephone must be made at no cost to the client. The system must accommodate both rotary and touch tone telephone instruments. For clients with rotary telephones, the system must be capable of accepting voice activation to capture the required information.
Once the change request is submitted and processed by MMAC, the provider will receive a contract addendum by postal mail that authorizes the use of an approved telephony system. No system should be implemented prior to the submission of a change request and approval of the request by MMAC.
Providers must obtain written permission from each client for the use of his or her telephone, and must adhere to all requirements of adequate documentation with the exception of client signature. Providers must use paper timesheets for clients that do not have phones. Paper timesheets still require adequate documentation including client signature.
To add telephony to your current contract, submit a change request form, found at https://mmac.mo.gov/providers/provider-enrollment/home-and-community-based-services/provider-contracts-forms/ ,to MMAC Provider Contracts.
A link to the list of approved Telephone Tracking System (“Telephony”) vendors can be found on
the Home and Community Based Services page.
UPDATE: (JULY 6, 2015) THE POST ABOVE APPLIED ONLY TO THE DEPARTMENT OF HEALTH AND SENIOR SERVICES PILOT PROJECT. THE PILOT PROJECT HAS CONCLUDED AND IS NO LONGER IN EFFECT. THEREFORE, DO NOT SUBMIT CHANGE REQUESTS TO MMAC FOR TELEPHONY SYSTEM AUTHORIZATION. FOR THE LATEST INFORMATION CLICK HERE.
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