KALAMAZOO COMMUNITY MENTAL HEALTH AND SUBSTANCE ABUSE SERVICES ADMINISTRATIVE PROCEDURE 08.08

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KALAMAZOO COMMUNITY MENTAL HEALTH AND SUBSTANCE ABUSE SERVICES ADMINISTRATIVE PROCEDURE 08.08 Subject: Claims Management Section: Financial Management Applies To: Page: KCMHSAS Staff KCMHSAS Contract Providers 1 of 7 Approved: (Jeff Patton, Chief Executive Officer) Revised: Supersedes: First Effective: 01/16/2014 01/24/2013 04/11/2001 PURPOSE This policy and procedure outlines elements of the Kalamazoo Community Mental Health and Substance Abuse Services (KCMHSAS) claims management processes. Claims management includes processing, adjudicating and payment or denial of claims. DEFINITIONS Adjudication Report The report that provides details of recently submitted and/or clean claims and their payment status for a specific claims processing period. Claims Adjustment Segment (CAS) Segment of an 837 Claim that reveals payment activity of other payers. Claims Processing The function of claims submission, claims processing and payment for authorized services. Claims Remittance Advice Report (RA) The report that provides details of service activity and payment for a claims processing period. Claims Summary Year to Date The aggregate report of service activity and payment summary by fiscal year.

SUBJECT: Claims Management PAGE 2 OF 7 Clean Claim A clean claim is a valid claim completed in the format and time frames specified by the PIHP and/or CMHSP and that can be processed without obtaining additional information from the provider of service or a third party. It does not include a claim from a provider who is under investigation for fraud or abuse, or a claim under review for medical necessity. A valid claim is a claim for supports and services that the PIHP or CMHSP is responsible for under contract with MDCH. Covered Service Services identified in the provider agreement (contract). Healthcare Insurance and Portability and Accountability Act (HIPAA) A federal law that allows persons to qualify immediately for comparable health insurance coverage when they change their employment relationships. Additionally, it gives the Department of Health and Human Services (DHS) the authority to mandate the use of standards for the electronic exchange of health care data, requires the use of national identification systems for health care consumers, providers, payers (or plans) and employers (or sponsors); and to specify the types of measures required to protect the security and privacy of personally identifiable information. The transmission of information between two parties to carry out financial or administrative activities related to health care is referred to as a transaction. Transactions include data standards that are code sets and unique identifiers established for claims. Pended Claim A claim that must be held due to incorrect or incomplete information. This may include: 1. Authorization dates or units that do not match services. 2. Eligibility must be checked or updated. 3. Claim is absent mandated information. 4. Explanation of Benefits form has not been received. Primary Provider The provider who has assumed the lead for consumer care. This position would typically fall to the support coordinator, wrap-around coordinator or the case manager. If an individual isn't receiving one of the fore-mentioned services, the clinician providing such services will be determined to be the primary provider. The Primary Provider is assigned through Access and the Person-Centered Planning process. Receipt of a Claim A claim will be classified as received when the claim is adjudicated in the KCMHSAS IS system. Third Party Liability (TPL) TPL refers to any other health insurance plan or carrier (e.g., individual, group, employer-related, self-insured or self-funded plan or commercial carrier, automobile insurance and worker's compensation) or program (e.g., Medicaid, Medicare) that has liability for all or part of a recipient s covered benefit.

SUBJECT: Claims Management PAGE 3 OF 7 POLICY I. KCMHSAS shall make timely payments to all providers for clean claims for services covered in the provider contract. This includes payment at 90% or higher of all clean claims from KCMHSAS provider network sub-contractors within 30 days of receipt, and at least 99% of all clean claims within 90 days of receipt, except services rendered under a sub-contract in which other timeliness standards have been specified and agreed to by both parties. II. KCMHSAS shall have an effective provider appeal process to promptly and fairly resolve provider billing disputes. STANDARDS I. All payments for covered services will be reimbursed at the contractual rate or the rate submitted, whichever is less. A. New providers will not be reimbursed until KCMHSAS is in receipt of a signed agreement. B. Existing providers that have been provided with a mutually agreed upon successor agreement or amendment will be reimbursed at the rate(s) contained in the successor agreement or amendment according to the effective date(s) outlined in the documents provided. Failure to return either the successor agreement or amendment within 60 days will result in cessation of reimbursement until such time as the signed documents are received. C. This requirement may be waived in unique situations. Waivers must be requested in writing. KCMHSAS will provide a written decision within 20 business days. II. III. IV. Payment for claims is net of first and third party fees, when applicable. All claims must be received by KCMHSAS within 60 days of the date of service (except Borgess [365 days] and other hospitals [180 days]) in order to be considered for payment, unless otherwise noted on your specific contract. This expectation also applies to any claim needing coordination of benefits information to process. Claims that are series billed must be received within 60 days (except Borgess [365 days] and other hospitals [180 days]) from the start day of claim line, not the end date of the claim. Claims received after this timeframe will not be considered for payment. Claims received within the 60-day (except Borgess [365 days] and other hospitals [180 days]) deadline and pended will be considered for payment for 365 days from the date of service. After the 365 days have passed, the service will be permanently denied and not available for correction or an appeal. All providers have the right to appeal denied/rejected claims. Denied claims can be reconsidered by initiating the Provider Grievance and Appeals procedure (see KCMHSAS policy 02.02 [Provider Grievance and Appeals (non-clinical)].

SUBJECT: Claims Management PAGE 4 OF 7 V. Claims cannot be submitted prior to date of service. VI. VII. Coordination of Benefits is the responsibility of the KCMHSAS provider. Explanation of Benefits will be generated and mailed to a minimum of 5% of consumers. PROCEDURE I. CLAIMS PROCESSING OF MENTAL HEALTH CLAIMS A. All provider claims will be filed electronically using the current KCMHSAS data layout and in accordance with HIPAA transaction standards. This requirement may be waived in unique situations. Waivers must be requested in writing to and approved by the KCMHSAS Claims Manager. When this requirement is waived, the claims will be subject to a $2.00 per claim processing fee. State inpatient, foster care settings and certain hospitals are exempt from this requirement. B. KCMHSAS will confirm receipt of all electronically submitted claims by sending a confirming email to your registered email account. This confirmation will be sent within 48 hours of claim receipt. If you don't receive a confirmation email please contact the IS department immediately to verify the status of your transmission. The emails should be compared to the transmission they reference so you can verify KCMHSAS received the number of claims you submitted. This email will also clearly document the status of each of the claims sent. Each claim line will have a descriptor that will identify whether the claim has been accepted, pended or denied. Pended and denied claims will have descriptions as to why they were either pended or denied. C. The claims runs are scheduled for the second and fourth Monday of each month. The deadline for claims submission is by noon the Thursday prior to the claims run. If the regularly scheduled claims run falls on a holiday the claims will be processed on the next business day. A claims run is finalized with the release of payment, either electronically or by check, on the Friday of the week following a claims run. For example, if the second Monday of April was April 10 th, a claims run would occur and the payment would be released to the providers on April 25 th. D. A remittance advice report will accompany all manual payments. If the provider chooses EFT payment they can choose to receive a HIPAA compliant 835 electronic remittance advice or they can access their electronic data interchange (EDI) account for the remittance advice. II. CLAIMS PROCESSING OF SUBSTANCE ABUSE CLAIMS A. Net cost contract providers are to provide a Financial Status Report (FSR) for each program element, such as Women's Specialty or Prevention, on a monthly basis.

SUBJECT: Claims Management PAGE 5 OF 7 The FSR must be submitted to the financial analyst monthly by the fifteenth (15 th ) for the previous month s activity. The FSR's will be processed within thirty (30) days of receipt. B. Claims must be submitted through the Provider Connect automated claims processing system. This system has the required fields of: 1. Consumer identification number 2. Dates of service 3. Procedure codes and modifiers 4. Provider of service C. Claims received by Wednesday will be processed and payment will be released on Friday of the same week. D. If requested, a provider can obtain a paper remittance advice, otherwise this information is included in the claim detail of the Provider Connect system. III. CLAIMS RECONSIDERATION The mental health provider will, upon receipt of the claims adjudication results, review the reasons for the pended status. The provider will resolve any errors or omissions by sending a replacement claim using the existing claim number noted on the adjudication results. Do not submit an existing claim as a new claim; it will be rejected as a duplicate. IV. CONSUMER FEES A. Determination of financial liability for each person served will be made using the KCMHSAS/Michigan Department of Community Health (MDCH) policies and procedures. No individual will be refused mental health services because of an inability to pay. B. The primary providers are responsible for determining financial liability, the completion of the annual Ability to Pay (ATP) form and the collection of applicable fees. Mental health related fees determined to be the responsibility of the person served would be automatically deducted from the first claims reimbursement due the provider until the monthly determined ATP is met. The substance abuse providers are responsible for the collection of the service-related co-pays. These co-pays will be automatically adjusted against each claim. Providers who are providing services to co-occurring individuals will follow the policies and procedures established for persons receiving mental health services. C. KCMHSAS may retroactively adjust paid claims in the event a Fee Determination containing 1 st party liability is completed and submitted by the provider. D. The mental health primary provider is responsible for updating an individual s ATP annually. If this isn't done within 60 days from the ATP expiration date,

SUBJECT: Claims Management PAGE 6 OF 7 KCMHSAS will assume the individual has a full ability to pay and will withhold all payments for services provided to that individual by the primary provider only. If the primary provider gets an ATP signed later than 60 days claims assessed at a full ability to pay will be re-assessed according to the new ATP. E. Whenever an ATP is completed, a copy will be provided to the individual served. F. All mental health ancillary providers are responsible for obtaining current ATP's from the primary provider. The substance abuse providers are responsible for updating and maintaining accuracy of financial information on all individuals receiving services in Provider Connect while the individual is receiving their services. V. COORDINATION OF BENEFITS A. The provider must reference the ATP and comply with all TPL requirements before KCMHSAS can remit payment. Denial by the TPL due to non-compliance will result in a denial from KCMHSAS. B. Claims paid by KCMHSAS and later determined to be covered by a TPL will be adjusted to reflect either the TPL payment or to retroactively pend a claim for a TPL payment. C. Mental health providers must electronically submit the Explanation of Benefit (EOB) decision from the individual s insurance regardless of decision in order to adjudicate claims where the TPL has been determined. All electronically submitted EOB's must be kept on file and accessible for review during an audit. D. KCMHSAS payment liability for beneficiaries with private commercial insurance is the lesser of the beneficiary's liability (including co-insurance, co-payments, or deductibles), the provider's charge or the maximum fee screens, minus the insurance payments and contractual adjustments (a contractual adjustment is the amount established in an agreement with a TPL to accept payment for less than the charge amount). E. Providers may enter into agreements with other insurers to accept payment that is less than their usual and customary fees. Known as "Preferred Provider" or "Participating Provider" Agreements, these arrangements are considered payment in full for services rendered. Neither the person receiving services nor KCMHSAS has any financial liability in these situations. REFERENCES - Southwest Michigan Behavioral Health Policy 9.1 (Claims Adjudication) 9.2 (Claims Overpayment and Refunds)

SUBJECT: Claims Management PAGE 7 OF 7 9.3 (Electronic Claims Submission) 9.4 (Provider Communication Claims) 9.5 (Provider Claims and Grievances and Appeals) 9.6 (State Regulations) 9.7 (Paper Claims Control)