School-based Medicaid Claiming: IEP and MAC

Transcription

1 School-based Medicaid Claiming: IEP and MAC ICASE February 2012 Indiana Department of Education School-based Medicaid contacts: Tracy Brunner, School-based Medicaid Specialist Office of Special Education John Hill, Medicaid Liaison Office of Special Education Special Ed Division Toll Free Line:

2 Two Different Types of Claiming WHAT does each reimburse? MAC: reimburses for ADMINISTRATIVE ACTIVITIES (NOT medical services) that serve all (not solely Special Ed) students IEP Services: reimburses for HEALTH- RELATED SERVICES in a Special Education student s IEP Whether it s claiming reimbursement for Medicaid-covered IEP services or for Medicaid-related administrative activities, Indiana public school corporations, charters and state schools participate in Medicaid claiming on a strictly voluntary basis. Because these two different claiming methods cover entirely different things, using totally separate reimbursement methodologies, schools may choose to participate in either or both. The State s new electronic IEP offers system support for each of these; however, districts do NOT have to use IndianaIEP in order to participate in either type of schoolbased Medicaid claiming.

3 Two Different Types of Claiming HOW are schools claims paid? MAC: based on total statewide random moment time study results, LEAs receive a % of their costs for allowable activities IEP Services: Student-specific IEP services are reimbursed based on the established fee schedule for health services District specific costs, student Medicaid eligibility rates and unrestricted indirect cost rates are applied to the results of the statewide random moment time study to determine the amount of federal dollars returned to each MAC-participating district. To claim Medicaid reimbursement for IEP services school districts must enroll as Indiana Medicaid health service providers and ensure their staff who provide Medicaid services meet Medicaid-qualified provider criteria. Medicaid pays schools the same rates as all other community providers of OT, PT, Speech, Psych, Audiology, Nursing and specialized Transportation services.

4 Two Different Types of Claiming WHAT documentation is required? MAC: required documentation includes results of quarterly statewide random moment time studies and LEA cost data IEP Services: Student-specific service records and related documentation required Documentation requirements differ for each of these claiming methods. District-specific direct and indirect costs plus staff responses to statewide time study samples are required to support IndianaMAC claims. For IEP service claims, documentation requirements include student-specific IEP service logs, student and staff attendance records and copies of staff licensure/credentials.

5 How Many Bill for IEP Services? Up 55% from the previous year, participation in Medicaid claiming for IEP services rose to 110 LEAs in State Fiscal Year Total reimbursements claimed that year were just under $4 million. Last year a total of124 LEAs claimed nearly $5.5 million in Medicaid reimbursements for IEP services. At 2011 federal matching rates, this represented $4 million in new, unrestricted federal funds to the participating LEAs.

6 Which Districts Bill for IEP Services? This report, available on IDOE s School-based Medicaid Web page, shows in black font the Indiana LEAs that claim Medicaid reimbursements for IEP services. It can be a helpful tool for identifying experienced colleagues to contact about the benefits and hassles of Medicaid claiming for IEP services. IDOE updates this report twice a year. To access the latest copy, go to the Schoolbased Medicaid page at and click the link under General Information near the top of the screen.

7 What IEP Services are Covered? Audiology Nursing Occupational Therapy Physical Therapy Psychological/Behavioral Health Speech-Language Pathology Specialized Transportation on a day when the student receives another covered IEP service The Medicaid Program s unique provider qualifications, service definitions and reimbursement limitations for each type of covered IEP service are described in the Medicaid Billing Tool Kit on IDOE s public Web site: Because Medicaid and Special Ed laws differ, schools sometimes find they can t bill for every IEP service they provide. For example, Medicaid requires a written order or referral for all except transportation services; and staff licensed to perform services in schools may not meet Medicaid s qualified provider criteria.

8 What Do Schools Typically Bill? State Fiscal Year 2011 OT/PT $845,246 SPCH-LANG/HEARING $4,295,007 Historically, the majority of schools Medicaid reimbursements are for Speech-language and Hearing services. Examples of reimbursement rates for covered IEP services include: Individual Speech Therapy $23.85 Group Speech Therapy $12.25 Physical Therapy Evaluation $44.33 Occupational Therapy Activity $18.97 Psychiatric Diagnostic Interview $80.90 Group Psychotherapy $19.23 Nursing-per 15 minute unit of service $ 9.97 Non-Emerg Transportation-per trip $ 9.00 Transport attendant with student-per trip $ 4.50

9 Added Effective Indiana Medicaid now reimburses schools for IEP nursing services provided by an R.N. and IEP-required specialized transportation services provided on a day when the student receives another covered IEP service. As of Dec 31, 2011 (halfway through the current State Fiscal Year), Indiana Medicaid has paid participating districts $12,000 for covered nursing services and nearly $40,000 for IEP-required transportation. [Note: IDOE was recently made aware that Medicaid will have to adjust some school transportation claims due to a processing error. Per Indiana Medicaid policy, mileage is reimbursed at $1.13 per mile excluding the first 10 miles per trip, and Medicaid s system has not been calculating mileage reimbursement for school claims based on this policy.]

10 How do IEP reimbursements work? Medicaid payments for IEP services are a mix of state and federal dollars. Currently, about 67% of every Medicaid payment for IEP services is new, unrestricted federal funding to the Local Educational Agency (school corporation, charter or state school). The state dollars (about 33%) constitute a small advance payment of a portion of the LEA s tuition support. For school business managers and others interested in the details, IDOE s Office of School Financial Management created a video demonstrating that districts receive and retain their entire tuition support allocation in addition to the federal funds recovered for IEP services. To access the video on IDOE s site, choose site map at the bottom of the DOE Home Page and click Podcasts / Videos under Other IDOE Services on the Find It Fast menu. From the Podcasts and Videos page, scroll down then click the VIDEO VAULT icon. This Step-by-Step Look at the Medicaid Adjustment on the DOE 54 report is listed under FINANCE at the bottom left of the screen. Video link:

11 What IEP Service documentation is required? Documentation that a direct medical service was provided to an eligible Special Education student e.g., paper or electronic Service Log; Student Record Medical Necessity Documentation e.g., order or referral; assessments; treatment plan/iep General School Corporation Records e.g., financial; attendance (student & staff); staff licensure Details online: Medicaid Billing Tool Kit Chapter 2 of the Medicaid Billing Tool Kit for IEP Services discusses documentation requirements applicable to all Medicaid-reimbursed IEP services. Chapters 3 through 9 include requirements specific to each type of IEP service commonly billed by Indiana School Corporations.

12 Medicaid Billing Tool Kit Chapter 10 includes sample documentation checklists and selfauditing ideas specific to each type of Medicaid-covered IEP service. Conducting periodic self audits is a good way for Medicaid-participating LEAs to monitor building-, district- and Special Ed Cooperative-level compliance with billing and documentation requirements for each category of IEP service they choose to bill.

13 IndianaMAC: Another Way Schools Claim for Work Staff Routinely Perform This April 2011 memo announced the State s implementation of the statewide schoolbased Medicaid Administrative Claiming program known as IndianaMAC. A copy is available in the Superintendent s Mail Community on Learning Connection.

14 How Many Participate in MAC? IndianaMAC Quarter 1 (Oct-Dec 2011): 74 LEAs IndianaMAC Quarter 2 (Jan-March 2012): 81 LEAs IndianaMAC Quarter 3 (Apr-June 2012):????????? Deadline to Sign Up for Quarter 3 = March 2, 2012 Approximately 21% of all public school corporations and charters participated during the initial quarter of IndianaMAC program implementation. Participation increased in Quarter 2, and judging from the number of inquiries DOE received, we anticipate that additional districts will sign up for participation in Quarter 3.

15 IndianaMAC Participants : [e.g., Indpls Public Schools, Fort Wayne] [e.g., 11 Charters, Liberty-Perry, Milan] [e.g., Evansville-Vanderburgh, School City of Mishawaka] [e.g., West Noble, South Ripley] Among the 74 LEAs that participated in Quarter 1, there was a diverse mix of large, small, rural and urban school corporations and charter schools from across the entire state. The Indiana School for the Deaf, the Indiana School for the Blind and Visually Impaired, a charter school, and 4 more districts joined their ranks in Quarter 2.

16 How does MAC reimbursement work? Based on Statewide Time Study Results (% of all school staff time on MAC activities) and LEA-specific: costs unrestricted indirect cost rate Student Medicaid Eligibility Rate The federal match rate varies from 50%-75% per activity; some subject to LEA s MER Quarter One IndianaMAC Time Study Results indicate that staff among all IndianaMACparticipating LEAs spent approximately 3.5% of their total school day on Medicaid reimbursable administrative activities. These time study results will be used to calculate the quarterly claim for each participating LEA, based on its % of Medicaid-eligible students and allowable costs (participating staff s salaries & benefits funded with state/local dollars plus a portion of related indirect costs). We anticipate that Quarter 1 MAC reimbursements will be disbursed sometime this summer.

17 What MAC documentation is required? PCG system retains LEA s required documentation Staff responses to random moment time study Who was with you? What were you doing? Why were you doing it? Did you provide a medical service (Yes/No)? If yes, was the service in a student s IEP? Financial data Staff /contractor salary/benefits funded with state/local dollars Because Indiana uses one statewide claiming methodology and one system to support its statewide random moment time study, IDOE s contractor, PCG, retains all the required documentation to support school-based Medicaid Administrative Claiming. To achieve statistical validity there must be a statewide time study response rate of at least 85%. For Quarter 1, the statewide compliance rate exceeded 93%. Thus far compliance with the financial data submission requirement is not as good. With one week left before the financial data submission deadline, 36 of 75 participating LEAs had not yet begun entering the required cost data; another 6 had started but not completed this required data submission.

18 March 2 Sign Up Deadline for Quarter 3 Interested LEAs will have the opportunity to sign up for IndianaMAC participation prior to the start of each calendar quarter. Contact Indiana Dept of Ed s contractor, PCG (Public Consulting Group) or IDOE s Medicaid specialists to learn more. Note: PCG is the designated vendor to provide systems and technical support for the IndianaMAC statewide Random Moment Sample Time Study methodology that simplifies MAC participation for LEAs that wish to claim federal Medicaid Administrative funds. LEAs not using the electronic IIEP operated by PCG can participate in IndianaMAC via an alternate web-based portal.

19 What resources are available? Manuals: IEP Services and IndianaMAC Newsletter and Presentation Archives School Corp IEP Reimbursements Report Parent Information Brochure Form Templates (service log, parental consent to bill Medicaid, service referrals) The IDOE School-based Medicaid Web page offers manuals, reports, archived newsletters and presentations (such as this one), brochures and other useful resources for anyone interested in Medicaid claiming for school-based services and administrative activities.

20 The Department s Web site has a new look and format but the address remains the same: To get from the DOE Home Page to this School-based Medicaid page, choose Special Education from the Individualized Learners drop down choices under Support for Students. Then click the School-based Medicaid link [ near the bottom of the Special Ed Office page.

21 Quarterly Newsletters IDOE s public site also offers an archive of all quarterly Medicaid in Schools newsletters. The archive includes search tips to help readers find specific topics or facts in recent editions.

22 Learning Connection Community The IDOE Learning Connection offers additional resources not available on the public web site. Anyone with a Learning Connection account can become a member of the Medicaid in Schools Community to access the announcements, events calendar, forum discussions, file folders and web links posted there.

23 Although not specifically targeted to Schools, the IndianaMedicaid.com site is accessible to all Medicaid service providers and offers additional resources for districts that bill for IEP services. Additionally, the online Medicaid Provider search function is a useful tool for IndianaMAC-participating LEAs and all other schools that help students and their families find local health care providers who accept Medicaid patients.

24 Integrate Existing Forms, Processes and Systems Participating LEAs can simplify their business operations by incorporating Medicaid into daily routines rather than adding separate Medicaid forms, systems and processes. Consistency and attention to detail are key factors to success, not only in billing accurately and passing muster in an audit situation, but also in facilitating program administration for LEA staff at all levels.

25 National Resources on Schoolbased Medicaid Services In addition to resources available from our state Education and Medicaid agencies, there are also national-level resources for those interested in Medicaid claiming for school-based services. LEAnet is a national network of Local Educational Agencies and advocates for continued funding of effective school-based Medicaid programs by educating public policymakers about these programs benefits for schools, students and families. NAME (the National Alliance for Medicaid in Education) is a non-profit organization that focuses on information sharing and collaboration among all stakeholders not on taking positions or lobbying.

26 Parental Consent to Bill Medicaid 34 CFR (d)(2)(iv) 2004 IDEA Reauthorization no reference! 2006 Regulations Published consent each time! 7 Meetings with USDOE July 2007 to February 2012 FIGURE IT OUT THIS NEEDS TO BE ADDRESSED

27 Parental Consent to Bill Medicaid PROPOSED REGULATION Published September 28, 2011 Comment Period Ended December 12, 2011 Approximately 450 Official Written Comments OSERS Completed Review of the Comments N E X T S T E P S

28 Parental Consent to Bill Medicaid N E X T S T E P S Written Responses to Each of the Comments Drafting Final Rule OMB 90 Day Review Period Publish Final Regulation in the Federal Register Estimated Date??? T H A N K Y O U!!!

29 Contact John Hill or Tracy Brunner in the Indiana Department of Education s Special Ed office any time you have a question, want additional information or need technical assistance related to Medicaid claiming for school-based services and administrative activities. Thanks for your time!