HBS Topics of the Week

The Ohio Department of Medicaid (ODM) is requesting that those who have contact with families with Medicaid insurance pass on an important message to the parents, which is:

**Make sure that your address and email is up to date and current with your County Department of Jobs and Family Services.**

Since March 2020, and as part of the Covid-19 Public Health Emergency (PHE), States have been prohibited from disenrolling members from Medicaid, even if they were found no longer to be eligible. Effective February 1, 2023, ODM has resumed routine Medicaid eligibility requirements. ODM will begin sending out termination letters to those members who no longer qualified for Medicaid but were allowed to remain on Medicaid due to the PHE. This process is called “Medicaid Unwinding”. Medicaid Renewal Packets and Request for Information will also be sent to all Medicaid recipients via US Mail. 

A big concern is that if a family has moved since March 2020, and did not change their mailing address with their County Department of Jobs and Family Services, this important Medicaid reenrollment information will not be received by the family and will result in a discontinuation of Medicaid benefits for the family. Members who do not respond will have their coverage discontinued and will then have 90 days to reenroll in Medicaid without needing to submit a new application, but they could be totally unaware, due to an incorrect address or email, that their coverage was terminated.

**Renewal Packets and Information Requests going to the wrong address will result in termination of Medicaid coverage.**

In anticipation of the return to routine eligibility and enrollment operations, ODM created a toolkit as a resource for those who interact with families on Medicaid. “This includes healthcare providers, teachers, advocates, elected officials, professional associations, community organizations, day care facilities, schools, churches, retail locations, and others.” This toolkit includes templates and materials you can use to inform Medicaid members about steps they need to take to renew their coverage or transition to other coverage if they’re no longer eligible for Medicaid.

The full tool kit is available for download here.

ODM suggests the following methods of informing parents to “Keep your address and phone number up to date with Medicaid”, and has examples included in the toolkit.

• Drop-In Articles – brief stories suitable for use on websites and in newsletters and bulletins

• Flyers – printable flyers, great for posting in your business location or distributing by including it in packaging (such as attached to prescription medicine bags) or as a handout

• Social Media – graphic posts that can be used on your own social media accounts

• Text Messages – short reminder messages to encourage updating contact information

• Medicaid Member Mailers – direct messaging that is suitable in an email or U.S. postal format

• On-Hold Messages – messaging to be provided to Medicaid members when on hold about the impending end of the continuous coverage provision and ways they can best be prepared

• Rack Card – printable rack card in the standard size (4×9 inches)

I suggest the following flyer from the attached ODM toolkit be sent out to all IEP students and perhaps all students. I would also suggest that this flyer be posted in a prominent location on your districts’ website.

Here are additional reminders and text message examples from the toolkit that can be sent out at various times throughout the remainder of the school year also.

HBS will be posting this material on our website and our online Medicaid Documentation System so therapists are aware of this issue. The next computation of MER will be in October 2023, so it would be beneficial to get this information out to parents during the remainder of this school year, but also at the beginning of next year. Once again, it’s just one simple message:

**Make sure that your mailing address and/or email address is up to date with your “County Department of Jobs and Family Services.**

Being proactive now will help ensure maximum Medicaid reimbursement when the SFY2024 MSP Cost Report is completed and filed on December 31, 2025. Please let me know your thoughts and additional suggestions.

Thanks,
Dan Thomas
Healthcare Billing Services, Inc.

Medicaid School Program – Eligible Services

There still seems to be a lot of misinformation regarding the services that are currently reimbursable in the Ohio Medicaid School Program (MSP). In the attached February 3, 2016 memo from Dr. Sue Zake and Mark Smith, the Ohio Department of Education (ODE) clarified that “There is no change in the services provider districts can claim”. The eligible services include:

• Audiology
• Counseling
• Nursing
• Occupational Therapy
• Physical Therapy
• Psychology
• Social Work
• Speech-Language Pathology
• Targeted Case Management
• Transportation

This misinformation relates to Delegated Nursing and Personal Care Services, which are not currently reimbursable in Ohio. Some districts are being advised to document for these two services because there will be retroactive billing at a later date. In the attached email, ODE makes it very clear that “there will be no retroactive claims for services not yet available for reimbursement”. There was retroactive billing allowed during the initial startup of the MSP, but that was a result of the CAFS lawsuit settlement. The effective date for any new services will be based on the date that Ohio submits its “State Plan Amendment” (SPA) to the Centers for Medicare and Medicaid Services (CMS). “The Ohio Department of Education will notify provider districts about allowed additional eligible services.”

If and when new services are added to the MSP, all billing vendors will work with their client districts to identify, train, and implement the new services based on the specific rules established by the Ohio Department of Medicaid (ODM) and approved by CMS. Documenting any new services prior to the SPA date will not generate any additional MSP reimbursement. I do not like to see districts go through the effort and expense of documenting services that will not result in Medicaid reimbursement. Please let us know if you have any questions regarding billable MSP services, or “Send questions regarding the content of the ODE memo to SchoolMedicaid@education.ohio.gov.”

Healthcare Billing Services, Inc.

www.Teamhbs.com

2016-2-MSP-Eligible-Services-Memo

MSP Contract Procurement

On April 13th, I participated in a presentation at the OASBO conference regarding the Medicaid School Program (MSP) and the Agreed Upon Procedures (AUP) review. I had the pleasure of presenting with Ken Richards of Kennedy Cottrell Richards (KCR) and Zac Morris with Rea and Associates. We had a lot of information to cover in just one hour of time. As we discussed, the costliest area of exposure in the AUP review relates to “Contract Procurement”. Below is a summary of the Related Service Procurement Requirements for the upcoming 2016/17 school year. Please note these requirements as you are entering into 2016/17 service contracts for MSP therapy services (OT, PT, Speech, Psychology, Social Work, and Nursing).

Contracts over $150,000

• Must be awarded through full and open competition.
• Contract file must state rationale for vendor selection. (Cost/Price Analysis)
• If competition is limited, document your efforts and rationale. (Sole Source Vendor)

Contracts under $150,000, but over the district’s procurement threshold.

• Documentation must exist that show at least 2 price comparisons, which can be obtained through written, verbal, catalog pricing, internet or from other sources. (Cost/Price Analysis)

Competitive Bidding or Price Analysis are not required for contracts less than the micro purchase limit ($3,000).

Sole Source Vendor

• Competitive Bidding and/or Price Comparisons are not required if you can justify and you document that there is only one vendor in your area that can meet your service needs. You must document your efforts in determining that the services are “available only from a single source”.

Contracts with ESC’s

• MSP service contracts with ESC’s can also be designated as a Sole Source Vendor and/or a Shared Services Contract. 45 CFR 92.36 (b)(5) encourages “State and Local intergovernmental agreements for the procurement or use of common goods and services”.

Note, when you contract with two separate vendors for the same service, it is hard to justify that either vendor is a Sole Source Vendor.

Therapy contracts must include the following three statements:

1. Vendor to comply with the requirements of 45 CFR 164.504(e) (1) for safeguarding and limiting access to information concerning beneficiaries.
2. The representative of the U.S. Department of Human Services, ODM, ODE or their respective designee will have access to the subcontractor’s books, documents and records.
3. Vendor acknowledges that they or their principles are not suspended or debarred.

All vendor invoices are required to provide a listing of students served. (It is extremely important that your therapy vendor provide this information for every invoice)

 Summary

Contracts over $150,000 require Competitive Bidding, unless the contract is with an ESC, or you can justify Sole Source Vendor designation.

Contracts under $150,000 require Price Comparisons, unless ESC contract, Sole Source Vendor, under district’s procurement threshold, or under the Micro Purchase limit.

Include the three statements on therapy contracts.

Require all vendors to provide “Students Served” listing with each invoice.

See Attachment “Medicaid School Program – Contract Procurement Checklist”

Healthcare Billing Services, Inc.

www.TeamHBS.com

MSPContractProcurementChecklist