Washtenaw Intermediate School District. Medicaid Quality Assurance Plan

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1 Washtenaw Intermediate School District Medicaid Quality Assurance Plan This plan has been developed by the WISD School Based Service Program (SBS) to meet the requirements of the Michigan Department of Community Health s Medicaid Provider Manual dated April 1, 2012 as indicated in the following Quality Assurance Policy: SBS providers must have a written quality assurance plan on file. SBS costs will be reviewed or audited by the MDCH for determination of medical necessity and to verify that all services were billed and paid appropriately. The purpose of the quality assurance plan is to establish and maintain a process for monitoring and evaluating the quality and documentation of covered services, and the impact of Medicaid enrollment on the school environment. An acceptable quality assurance plan must address each of the following quality assurance standards: Covered services are medically necessary, as determined and documented through appropriate and objective testing, evaluation and diagnosis. The IEP/IFSP treatment plan identifies which covered services are to be provided and the service frequency, duration, goals and objectives. A monitoring program exists to ensure that services are appropriate, effective and delivered in a cost effective manner consistent with the reduction of physical or mental disabilities and assisting the beneficiary to benefit from special education. Billings are reviewed for accuracy. Staff qualifications meet current license, certification and program requirements. Established coordination and collaboration exists to develop plans of care with all other providers, (i.e., Public Health, Department of Human Services (DHS), Community Mental Health Services Programs (CMHSPs), Medicaid Health Plans (MHPs), Hearing Centers, Outpatient Hospitals, etc.). Parent/guardian and beneficiary participation exists outside of the IEP/IFSP team process in evaluating the impact of the SBS program on the educational setting, service quality and outcomes.

2 Ann Arbor Public Schools 2555 S. State Street Ann Arbor, MI Chelsea School District 500 Washington Street Chelsea, MI Dexter Community School 7714 Ann Arbor Street Dexter, MI Lincoln Consolidated Schools 8970 Whittaker Road Ypsilanti, MI Manchester Community Schools 410 City Road Manchester, MI Milan Area Schools 100 Big Red Drive Milan, Michigan Saline Area Schools 200 North Ann Arbor Street Saline, MI Whitmore Lake Public Schools 8845 Main Street Whitmore Lake, Michigan Willow Run Community Schools 235 Spencer Lane, Ypsilanti, MI Ypsilanti Public Schools 1885 Packard Road Ypsilanti, MI Local Washtenaw County School Districts Participating in the School Based Services Program Washtenaw Intermediate School District 1819 South Wagner Rd., P.O. Box 1406 Ann Arbor, MI 48106

3 Quality Assurance Standards: Washtenaw Intermediate School District I. Covered services are medically necessary, as determined and documented through appropriate and objective testing, evaluation and diagnosis. A. Services are provides in accordance with each student s Individualized Education Plan (IEP), developed by the IEP team which includes medical professionals in the school setting. B. Evaluations are conducted by the Multidisciplinary Team (MET). When the initial evaluation is completed, the evaluation team develops a written MET report with an eligibility recommendation. An IEP meeting is conducted in which the IEP team reviews the MET report and determines whether or not student is eligible for special education services, including medically related services. C. The medical necessity of services, such as speech, occupational therapy, and orientation and mobility services are determined by a physician contracted by the WISD. The IEP and other relevant evaluation information for students to assist the physician in determining medical necessity is available for review by the physician. i. Speech and Language Services Referral: At each IEP, the speech and language pathologist completes a referral for all students with active speech services listed on the current IEP. The referrals are forwarded to the WISD Medicaid Program by the local district special education office, Medicaid eligible student referrals are forwarded to the WISD contracted physician. ii. Occupational Therapy Authorizations: At each IEP, the occupational therapist completes a request for authorization for all students with active occupational therapy services listed on the current IEP. The authorization requests are forwarded to the WISD Medicaid Program by the local district special education office, Medicaid eligible student referrals are forwarded to the WISD contracted physician. iii. Orientation and Mobility Authorization: At each IEP, the orientation and mobility specialist completes a request for all students with active orientation and mobility services listed on the current IEP. The authorization requests are forwarded to the WISD Medicaid Program by the local district special education office, Medicaid eligible student authorizations are forwarded to the WISD contracted physician.

4 D. Physical therapy prescriptions are obtained by the physical therapist prior to providing physical therapy services. The physical therapy prescription will be forwarded to the WISD Medicaid Program. E. Medical authorization for nursing services is the responsibility of the registered nurse providing services for the students with active nursing services listed on the student s IEP. Authorization must be renewed annually. The nurse is responsible for maintaining documentation for auditing purposes. F. Personal care services are authorized by the appropriate practitioner; registered nurse, occupational therapist, physical therapists, or speech and language pathologist, in accordance with personal care services listed on the student s IEP. Personal care services are renewed annually. II. Monitoring of appropriate services and quality review The Quality Assurance Committee comprised of staff member(s) from each of the following disciplines: Speech, Occupational Therapy, Physical Therapy, School Social Work, and Nursing and members of the Medicaid Office will conduct reviews of Medicaid documentation. These reviews will include documentation for students throughout the Intermediate School District and will occur three times during the school year. A. A four to six month sampling of the School Based Services Medicaid documentation, from the previous twelve months, will be selected and examined for randomly selected students. The documentation will include: i. The students corresponding Individualized Education Plans, which will be reviewed for services, frequency, duration and goals and objectives. ii. The current prescriptions for speech, occupational therapy and physical therapy, if applicable. iii. The attendance reports for the students during the audit period. iv. The attendance reports for the staff who performed services during the audit period. B. The itinerant committee staff members will review this random selection of their peers Medicaid documentation, from their discipline. i. Staff from the Medicaid Office will review Medicaid Documentation for Targeted Case Management from the local districts as well as within Washtenaw Intermediate School District. The Medicaid Office will also check certification for the staff providers included in the review. ii. Randomly selected claims will periodically be traced back to the Business Office to review backup for costs submitted to the program under the costbased rate methodology.

5 C. Problems that are identified during this Committee review will be moved to the Audit component of our Quality Assurance Plan for a more in depth analysis. D. Records from the Quality Assurance Committee Meetings will be kept on file in the Medicaid Office. E. Internal Audits i. Internal audits will be conducted by the Medicaid Office on an as needed basis, depending on the findings of the Quality Assurance Committee. ii. Staff members will be notified of the results of each audit, and individual and group feedback will be used to correct any problems that are found. III. Staff Training Washtenaw Intermediate School District staff training for Medicaid School Based Services claiming will be provided on an annual basis using a group setting at the start of each new school year or as requested by the local school district. This training will be provided by the WISD Medicaid Office, and will be based on the information put forth in the Medicaid Provider Manual by the Department of Community Health. All local school districts will be encouraged to schedule a training session with the Medicaid Office for their case managers once per year. A. Training will also be available for new local school district staff members throughout the year. B. Individual trainings for problems or questions will be provided on an as needed basis. C. Staff trainings will cover detailed and timely completion of Random Moment in Time Studies. D. An Open Lab staffed by WISD Medicaid Office staff is scheduled for 3 hours twice monthly during the school year to provide support for county providers. E. A WISD School Based Services Medicaid Manual containing WISD Medicaid procedures is posted on the WISD website. Additionally, Provider Tip Sheets and RMTS Instruction Sheets are posted on the website. IV. Accuracy of Billing A. The WISD uses the computer software billing program Excent Tera and the GET (Global Education Technologies) Medicaid Module is used to submit claims to the Department of Community Mental Health through the CHAMPS Medicaid Program. Claims are submitted monthly at the beginning of each month. B. Prior to a submission of a claim, the GET program will screen Medicaid claims for the following criteria: i. Annual parent consent on file

6 ii. Designated case management missing direct related services iii. Annual prescriptions or referrals on file for occupational therapy, physical therapy, speech and language services, orientation and mobility service authorization, nursing services and personal care services iv. Duplicate services billed v. Annual Individualized Education Plan/or annual Individualized Family Service Plan on file vi. Encounters correctly completed for Medicaid eligible students vii. Age validation check for students age 21 years and older. C. Transportation: At this time the WISD does not submit transportation claims D. Incorrect Claims For claims identified as submitted incorrectly i. A claim is voided electronically ii. Replace a claim electronically allowing for WISD to pay back charges within a claim E. Reports Several reports have been developed for Excent Tera which allow for monitoring of successful claims, encounters logged by provider, parent consent, referrals and authorizations, etc. V. Ensure current staff qualifications meet licensure, certification, and program requirements The WISD Medicaid Office will maintain a file of staff certification for those members listed on Direct Service and Case Management Staff Pool Lists. Only staff members with state approved certification will be listed on the Medicaid Staff Pool Lists. Staff Pool list participant credentials will be reviewed quarterly prior to certification of the county staff pool lists. VI. Collaboration with Other Providers The Individualized Education Plan Form/Procedure provides an opportunity for parent input as to other community services that the child receives. Coordination and/or collaboration will be available if requested of our therapists. If a student is receiving services in the school setting and an outpatient or community setting, providers are required to collaboration to coordinate treatment and prevent duplication of services. The collaboration may be by phone calls, written communication logs, or participation in team meetings such as the IEP/IFSP meeting.

7 The WISD recognizes that the goals and treatment for the outpatient and school setting are required to have distinct goals and objectives. School based services are provided to assist the student with a disability to benefit from special education, while outpatient services are provided to optimize the student s functional performance in relationship to needs in the home or community setting. VII. Collaboration Evaluation Of Medicaid School Based Services Program A Parent/Family Survey Practice will be implemented that asks for feedback on the effectiveness of the School Based Services Medicaid Program.

8 RATE METHODOLOGY PROCEDURES I. Staff Pool Lists The WISD Medicaid office will provide training and support for the LEA Staff Pool Contact: A. The following will be considered when reviewing the quarterly WISD LEA staff pool lists for outreach, case management, direct service and personal care providers: i. New staff hires, deleted employees ii. Employee leaves iii. Staff certification iv. Staff job duties v. Federal funding levels B. The WISD Medicaid Office will provide support for LEA s to compile and certify case management, AOP, and Direct Service staff pool participants for their districts using the PCG on-line staff pool list program. C. The WISD Medicaid Coordinator will be responsible for certifying the quarterly finalized staff pool list data for WISD and all LEA s, in a timely manner using the PCG on line staff pool list program. II. Random Moment in Time Studies Time study distribution and reminders to staff will be a joint responsibility between the WISD Medicaid Office and LEA Medicaid Contact. All staff will receive an notice of their selection for the time study. Follow up will be done to be sure all time studies are completed in a timely manner by both WISD and LEA staff. Time Studies which have not been completed in a timely manner will be referred to the appropriate special education administrator for follow-up with the delinquent participant. III. Submission of Quarterly Financial Data A. All WISD financial data related to cost reporting for the Medicaid Program will be submitted to PCG (Public Consulting Group) in a timely

9 manner by the Business Office. The data will be reviewed for reasonableness before submission. B. Each LEA district will submit their own quarterly cost financial data directly to PCG at but will copy WISD on their submission. i. Quarterly financial cost data must not be estimated or calculated with formulas in the PCG spreadsheet. The cost data is subject to audit based on payroll reports. ii. Each LEA will submit a signed quarterly Cost Certification Expenditure Form to with a copy sent to the WISD Business Office. iii. LEA quarterly financial data will be reviewed for reasonableness by the WISD Medicaid financial contact. iv. Amended quarterly cost reports will follow the guidelines as provided by PCG at v. LEA claims submissions will be monitored by the WISD Medicaid office at each quarterly submission, to make sure that the LEA staff members reported in the cost reports are submitting claims. IV. Reconciliation Process The Medicaid Allowable Expense Reporting (MAER) Process will begin with review of the Yearly Summary Staff Pool List that is provided to each ISD by the state. A. WISD Responsibilities for this process: i. The Summary Staff Pool List will be sorted to identify all Direct Service providers. ii. The Direct Service providers will be entered into the WISD Discipline Specific Cost Report Spreadsheet iii. The Business Office will use the WISD payroll and financial database to supply needed salary and benefit cost reports to complete the data in the Discipline Specific Cost Report Spreadsheet. iv. The Discipline Specific Cost Report Spreadsheet data will be used to complete the MAER Medical Staff Costs. B. Local Education Association Responsibilities for this process: i. All Local Education Associations (LEAs) will report their Medical Staff Costs and Transportation Costs using the MAER form. ii. LEAs will submit their MAER data files to WISD via .

10 iii. LEAs will submit a signed Cost Certification Expenditure Form to WISD for the reconciliation. iv. WISD will review all local MAER data for reasonableness of figures, and compare local SE-4096 and SE-4094 data to reported MAER costs. v. Amended MAER cost reports will follow the guidelines as provided by PCG at C. WISD will store all WISD and Local MAER data in a file containing the MAER template for viewing. The Business Office and Medicaid Coordinator will have access to the file. V. Reconciliation Summary Software A. The Medicaid Summary Software will be downloaded from the State of Michigan secure site and stored on the WISD Financial Contact computer by the WISD Financial Contact. B. The WISD Financial Contact will complete the yearly reconciliation process for WISD and its LEAs and submit the data to the state in a timely manner. VI. Communication Procedures The Washtenaw Intermediate School District will work to share Medicaid School Based Services Program updates and information with all concerned parties. A. Michigan Administrative Outreach Program newsletters will be shared with all Staff Pool List Contacts. B. State Implementer Meetings will be attended by at least one representative of the WISD Medicaid Team C. The Medicaid Coordinator will be available to attend LEA Business Manager Meetings, when there is a need to share information. D. WISD will communicate program updates and requirements with the Local Education Associations.

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