PCG POST. Public Consulting Group, Inc.

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1 May 2015 Brought Brought to to you you by: by: Public Focus. Proven Results. General Compliance Review FAQ How many reviews are conducted by PCG a year? PCG conducts approximately forty (40) comprehensive compliance reviews (MAC, DSC, and Annual) annually. Every LEA can expect to participate in a comprehensive compliance review at minimum once every three years. Do FTP documents need to be password protected? No. Documents shared via the FTP site are shared securely. Direct Service Claiming (DSC) Compliance Review FAQ Do credentials need to be listed with signatures on IEP/ progress notes? No. Credentials are not required next to signatures. Are Licensed Practical Nurse costs associated with services rendered to a student during transport to and from school considered allowable? Yes, however services cannot exceed a typical school day (7 hours) and should be prescribed in the IEP with the appropriate scope, frequency, and duration. Can a therapist make-up for service time missed by student absence? Yes, however; the therapist cannot bill for services if they exceed the prescription. Are paraprofessionals and health aides considered personal care providers? Those are all examples of internal job titles that could be considered personal care providers if their primary job function includes rendering Activities of Daily Living (ADL) services. Pg 1

2 Brought to you by: Direct Service Claiming (DSC) Compliance Review FAQ (Continued) Can the Speech Language Pathologist (SLP) who signs and dates the IEP be different than the SLP that renders the service? Yes. The SLP who signs and dates the IEP must be appropriately licensed and considered a Qualified Medical Provider (QMP) to prescribe speech services under the Medicaid School Based Claiming program, but does not have to be the one to render services. Does a QMP need to sign and date the IEP in order to indicate a Y in the IEP reimbursable related service column when completing the 10/1 student rosters? Yes. In order to indicate that the student has an appropriately prescribed MSBC program reimbursable related service, it must be prescribed by a QMP as considered for this program. How can you estimate the number of minutes required for nursing services that occur only when needed like seizure monitoring? You can use a range of moments to capture services that may occur at different frequency, or not at all, on some days. Billed services cannot exceed the prescribed amount of time but the prescribed amount of time is not required to be met. Can health aides bill for nursing services? No. All billed services must be appropriate by rendering provider type as outlined in the AHCCCS Medical Policy Manual (AMPM). Is catheterization considered a health aide service? No. Catheterization is a nursing service. Do you need a QMP signature on addendums? Yes. All changes are effective the date of the addendum and QMP signature and date. Do you review benchmarks as part of the goal standard? No. PCG will only look at benchmarks to satisfy the requirement that goals be measurable if there is no other measurement indicator within the goal. Pg 2

3 Brought to you by: Direct Service Claiming (DSC) Compliance Review FAQ (Continued) Can you use a signature stamp? No. Signature stamps, computer generated signatures, and/ or computer generated dates are all unacceptable. All signatures on the IEP must be handwritten and fully executed to include a handwritten date indicating the date the document was signed. Other program documentation like clinical notes and progress reports may be electronically signed if the system meets electronic signature requirements. Are evacuation drills reimbursable for transportation? No. Only two trips a day (to and from school) are reimbursable for transportation. Is a school psychologist a QMP? No. School-based psychologists and guidance counselors are not considered QMPs. How are claim samples determined when a LEA is selected for a comprehensive compliance review? DSC claim sample sizes are based on thresholds of claiming activity. The claims are directly proportional to the LEA claiming activity by CPT code. Compliance Review Cost Reporting FAQ Does PCG outline in detail what is needed for PPS invoices at the exit meeting for compliance reviews? Yes. Documentation including invoice requirements are included on quarterly compliance review trainings, outlined in the engagements letter, explained during the entrance meeting, and discussed during the exit meeting. Would crossing guard duties be included in salaries reported? No. Only costs associated with primary job function should be included on costs reports. For example, coaching, after-school care, homework help, etc. would not be reported. Is it compliant to add PPS costs alongside salaries/benefits for a full-time/part-time employee? Yes. If a full-time/part-time employee also has contractual costs, costs may be reported accordingly under salaries and benefits as well as under PPS costs. An edit will be triggered to allow you to explain the reasoning for PPS costs being reported for a full-time/part-time employee. Pg 3

4 Compliance Review Cost Reporting FAQ (Continued) What is the appropriate methodology to report costs for a direct replacement when looking at either MAC and or Annual? If a full-time/part-time employee or PPS contractor has been terminated and has a direct replacement, report any incurred costs for the terminated employee as well as any incurred costs for the direct replacement under terminated employee s name for the appropriate reporting period. Please be sure to keep detailed notes including termination and start dates as well as clear totals associated with each employee for audit purposes. It is important to remember to remove the terminated employee from future Staff Pool Lists (SPL) and add the direct replacement on the future SPL as well. Should salaries and benefits funded from a non-allowable function be reported? Yes. All costs, including those associated with non-allowable functions and federal funds should be reported under the salaries, benefits, or PPS cost columns accordingly and then should also be reported under the column labeled federal compensation revenues to be subtracted from the total allowable costs. Is CPR training reimbursable? Yes. Costs associated with training for primary job functions funded by the LEA are considered reimbursable and should be reported, within the applicable reporting period, within MCRCS. Is fund 290 allowable and should it be reported as a federal revenue? All costs associated with funds 290, 291, or 292 should be reported under the salaries, benefits, or PPS cost columns accordingly and DOES NOT need be reported under the column labeled federal compensation revenues because they are allowable costs. Quarterly Cost Reporting FAQ Why do quarterly costs include both direct AND administrative providers? The quarterly costs reported result in the Medicaid Administrative Claim (MAC) which reimburses LEAs a portion of the costs based on the amount of time is spent performing administrative and outreach activities for the MSBC program based on Random Moment Time Study (RMTS) results for both the administrative and direct service providers. If an employee is paid for services rendered March 15 th through March 31 st on April 6 th, what quarter can their costs be reported? For quarterly cost reporting, the costs referenced above would be reported in the April June quarter of the applicable year since quarterly costs are reported under a cash-based accounting methodology. they are reported within the quarter that they are paid, regardless of when services are rendered. Pg 4

5 Annual Cost Reporting FAQ Are personal care providers only included on the annual cost report? Yes. Personal care provider s costs are only reported on the annual cost report and is used to determine LEA s cost to provide direct services to Medicaid eligible students which is then compared to interim payments to calculate cost settlement determination. Transportation Related FAQ Would an air conditioner on a bus or fixing it be able to be included in transportation other costs? Yes. Given the climate of Arizona, an air conditioner is necessary and can be included in transportation other costs. If a bus transported all special education students with transportation prescribed within their Individualized Education plan (IEP) but one student only had a 504 plan, could you report the bus costs as specialized? No. In order for costs to be considered specialized, all students need to have transportation prescribed within their IEP. In this case, because one student without an IEP is transported on the bus, costs associated with this bus would be reported as generalized. Are GPS systems for buses considered allowable? No. GPS systems do not help make the bus go and are not considered reimbursable. Who decides what is considered allowable and not allowable for transportation costs? Directive and approval is given by Center for Medicare and Medicaid Services to the State of Arizona regarding all MSBC program requirements. Why aren t bus monitor costs reimbursable? Bus monitors are not providing medical services covered under the MSBC program. Pg 5

6 Health Aide Prepayment Review FAW What are system holds? System holds occur when students are ineligible for AHCCCS coverage at some point during the duration requested. System holds are not denials but rather conditional approvals meaning that the student has been approved for a portion of the time requested. Please contact AHCCCS to determine exact eligibility time frames. Pg 6