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School Medi-Cal Administrative Activities

Backcasting – Disallowed claims and apportionment for one-time funds (Prop. 98)

In October 2014, the Department of Health Care Services (DHCS) reached a settlement agreement with the Centers for Medicare and Medicaid Services (CMS) for payment of invoices submitted during the time that the School-Based Medi-Cal Administrative Activities (SMAA) program was in deferral.

Part of this agreement included the requirement that LEAs participate in backcasting, a process that compares the SMAA claiming results under the old methodology (i.e., time logs) to the claiming results under the new methodology (Random Moment Time Survey or RMTS). If the backcasted invoice resulted in a claimable amount that was less than the interim payment received by the LEA, the LEA will be required to pay back the “overpayment” to DHCS.

Now that all three groups of backcasting invoices have been submitted to DHCS (Group 1 – 09/10 Q1 thru 10/11 Q4, Group 2 – 11/12 Q1 thru 12/13 Q4, and Group 3 – 13/14 Q1 thru 14/15 Q2), many LEAs owe money as a result. To recoup these overpayments from LEAs, language was written into the 2018 Budget that allows the DOF to take the amount owed directly from an LEA’s Prop. 98 one-time discretionary funding apportionment.

The CDE released a letter to county superintendents dated December 31, 2018, regarding the first apportionment for one-time funds for mandate claims. The letter indicated that “If a school district is required to repay claims disallowed under the SMAA program … the State Controller shall, upon notification from the Department of Finance (DOF), withhold the specified amounts owed from the allocations made to those school districts.”

On February 4, 2019 the CDE sent out an email titled “Update: First Apportionment for One-Time Funds for Outstanding Mandate Claims, Fiscal Year 2018-19” in which it reported that the funds owed back to the state were actually not withheld from this first apportionment. It went on to say that “The withholdings for the SMAA claims may be applied by the State Controller against the second apportionment on one-time funds scheduled to be apportioned in June 2019.”

Of concern to the LECs and CCSESA is whether the June 2019 apportionment will be sufficient to cover the total funds owed back due to backcasting. If the funds are not sufficient to cover the liability, it is unclear how DHCS will handle any outstanding balances due.

 

Random Moment Time Survey (RMTS) Integration with LEA Billing

Since 2015, the DHCS has been working on a state plan amendment to integrate the LEA Billing Option Program into the RMTS methodology currently in use with the SMAA program. DHCS is planning for this integration to occur with the 2019-20 school year.  School districts will need to work with their local LEC or LGA to ensure continued participation in both programs.

 

Office of Inspector General (OIG) December 2018 Report

In December 2018 the Office of Inspector General (OIG) with the Department of Health and Human Services issued a report summarizing reviews performed of 10 state Medicaid agencies from July 2003 through June 2015. The report identifies vulnerabilities in the use of RMTS and opportunities for CMS to improve its oversight. Please see the following link for the full report: https://oig.hhs.gov/oas/reports/region7/71804107.pdf. DHCS is in the process of creating a workgroup to review the report and address any areas of concern for California.

 

2018 Governor’s Budget Proposes Prop 98 withhold to cover Backcasting losses

Education Coalition Response – Ed Coalition Oppose ltr & Fact sheet

 

LEA Billing Option Program to Integrate into RMTS Process

LEC/CCSESA Proposed Timeline – LBO RMTS Implementation Timeline FINAL

 

AB 3192 – Would to require DHCS to create an Audit Guide for LEA Billing Option Program

Ed Coalition Response – Attachment 2- Coalition Letter

 

SMAA Stakeholders Meeting – February 6, 2018    10 am – 12 pm

Sacramento County Office of Education

10474 Mather Blvd.

Mather, CA 95655                    Map to Sac COE

CMS Proposing New RMTS Notification Timelines – Zero Notification/2-day Response

Letter to Jennifer Kent – RMTS notification chg ltr 1-2018

 

SMAA Stakeholders Meeting – October 5, 2017    9 am – 12 pm

California Endowment Building

1414 K Street, Suite 100

Sacramento, CA 95814

 

Revised SMAA Manual Approved by CMS – Effective January 1, 2015!

DHCS announced on November 1, 2016 that CMS has approved the revised SMAA Manual and new RMTS invoice template.  This is a retroactive approval with an effective date of January 1, 2015.

You can access a copy of the approval letter below:

CMS SMAA Manual approval letter Oct. 31, 2016

MAA Invoice Due Dates per DHCS:

2014/2015 Quarter 3 Invoice Submission Due Date

The due date for the submission of SMAA invoices for fiscal year (FY) 2014/15 Q3 has been extended to Friday, December 30, 2016 close of business.  DHCS must receive completed invoices by this date in order to be processed prior to the end of the 2-year claiming period which ends on March 31, 2017.

2014/2015 Quarter 3 Invoice Submission Due Date

The due date for the submission of SMAA invoices for fiscal year (FY) 2014/15 Q3 has been extended to Friday, December 30, 2016 close of business.  DHCS must receive completed invoices by this date in order to be processed prior to the end of the 2-year claiming period which ends on March 31, 2017.

2014/2015 Quarter 4 Invoice Submission Due Date

The due date for the submission of SMAA invoices for FY 2014/15 Q4 has been extended to Tuesday, February 28, 2017 close of business.  DHCS must receive completed invoices by this date in order to be processed prior to the end of the 2-year claiming period which ends on June 30, 2017.

Time Study Participant (TSP) List Submission Dates

As per the 2014 SMAA Manual, Section 6-9: “The TSP Universe document must be submitted, or made available electronically, to DHCS no later than 14 working days before the quarter begins.” Please contact your LEC Coordinator for regional-specific deadlines.

SMAA Program To Be Represented at CASBO 2016 Annual Conference!

For the second year in a row, SMAA program LEC representatives will be on hand during the Biz Table Talk portion of the conference on Thursday, April 14 at 11:15 am to provide program details and answer any questions you may have.  Please join us!

New DHCS SMAA Marketing Brochure Available!

The California Department of Health Care Service (DHCS) has created a SMAA marketing brochure to provide information to local educational agencies about the SMAA program and how they can participate.  To view or print the brochure click the link below:

DHCS SMAA Brochure

Deferred Claims Resolution !

The Department of Health Care Services (DHCS) accepted the Centers for Medicare and Medicaid Services (CMS) School-Based Medi-Cal Administrative Activities (SMAA) Deferred Claim resolution on October 14, 2014. Based on that approval, the SMAA Unit will begin to release claims to the DHCS Accounting Section starting on November 7. The initial claims represent those where the amounts are below $25,000. The remainder of the claims currently in hand will flow on a staggered basis throughout the rest of November and into early December. DHCS anticipates that the payments will begin to be released by the end of December 2014.

Links to view the settlement letter and DHCS’s response to the settlement offer:

CMS Settlement Offer Letter

 

 

 

 

Common Message – February 2014

School-Based Medi-Cal Administrative Activities (SMAA or MAA)

Local Educational Consortium Advisory Committee

(LEC Advisory Committee)

SMAA Program Update

 

2013/2014 Interim Claiming Process

  • The 2013/14 Q3 time survey period begins on 3/24/14.  All Participant Universe GRIDs (and supporting documentation) for Q3 must be submitted to DHCS by 2/24/14.
  • The 2013/14 Q4 time survey period begins on April 28, 2014.  All Participant Universe GRIDs will be due to DHCS on 3/28/14.
    • Universe GRIDs are conditionally approved by DHCS upon receipt.  However, DHCS will review each MAA Universe GRID submission and may ask for additional information from LEAs before final approval is made.
    • If a participant was (for some reason) not included on the GRID (before the time survey period), that person may still time survey, but a “revised” GRID and explanations/supplemental documentation may be required at some time during the MAA invoice process.
    • LECs/LGAs will receive written notification (from DHCS) of final approval or disapproval of the GRIDs.

 

Status of New Implementation Plan

DHCS responded to the request for additional information from the Centers from Medicare & Medicaid Services (CMS), federal oversight agency, relative to the New SMAA State Plan on 1/24/14.  DHCS also submitted a revised milestones timeline to CMS.  These documents are available on the DHCS SMAA Website:  http://www.dhcs.ca.gov/provgovpart/Pages/SMAAWhatsNew.aspx)

DHCS received additional questions (about the new plan) from CMS on 2/4/14 and they will be responding quickly to move the implementation plan closer to final approval.

The new implementation plan requires one software platform for RMTS methodology for the LECs and one software platform for RMTS methodology for the LGAs.  Both the LECs and LGAs are currently soliciting Requests for Proposal (RFP) to procure the required software platforms.      

CMS must approve the new plan which will be implemented in the 2014/15 year.  The draft RMTS plan can be viewed in the 2014/15 DRAFT SMAA Manual (section 6).  (http://www.dhcs.ca.gov/provgovpart/Pages/SMAAManual.aspx)

 

Deferred Invoices and Reasonableness Test Criteria (RTC)

  • All RTC certification forms and associated documentation for initially “deferred” invoices must be submitted to DHCS by 4/30/2014.  Any RTC compliance packages (from the initially deferred invoice group) received after 4/30/14 will not be approved and the LEA will forfeit their MAA reimbursement.
  • Claiming units will be required to submit RTC documentation for all 09/10 (if applicable), 10/11 and 11/12 MAA invoices.  The claiming units that were cleared during the original certification process will begin the RTC process with their first “unpaid” MAA invoice.
  • All 2012/13 MAA invoices will be subject to the RTC process.
  • 2012/13 Q1 invoices are due to DHCS by 3/31/14.
  • 2012/13 Q2 invoices are due to DHCS by 5/31/14.
  • DHCS is committed to processing RTC documentation in a timely manner and will make every effort to have MAA funds released (as quickly as possible) to claiming units, once approved.

 

DHCS SMAA Program Updates

To address SMAA Program changes and RMTS implementation, DHCS hosted a “Stakeholder Forum” (and Webinar) on 2/12/14.  DHCS plans to continue hosting these forums in the future to allow all SMAA Program stakeholders to voice their comments and/or concerns about the SMAA Program.

DHCS announced that CMS would like to see the State of California using the RMTS methodology for both the SMAA Program and the Direct Billing Option Program by 2015/16.

DHCS announced that they support community college participation in the SMAA Program.  Community colleges will be bound by the SMAA rules, including the provision of a defensible participant universe for pre-approval by DHCS.

The Department of Health Care Services posts SMAA program updates on the State website.  The DHCS SMAA What’s New Page is available through the following link:

http://www.dhcs.ca.gov/provgovpart/Pages/SMAAWhatsNew.aspx

 

SMAA Stakeholders’ Meeting 2/12/2014

DHCS held the first MAA stakeholders’ meeting on February 12, 2014.  The stakeholders group included LECs, LGAs, LEAs, vendors and other interested parties.  The Department of Health Care Services (DHCS) hosted the meeting and plans to continue meeting every other month.  Once the meetings are scheduled, a notice will be posted on the californiamaa.org website or you can subscribe to the list serve for DHCS at:  http://apps.dhcs.ca.gov/listsubscribe/default.aspx?list=DHCSSMAA

 Here is a summary of the major points discussed:

  • The Reasonable Test Criteria (RTC) process (and the burden it is to LEAs) was discussed.  The RTC is being mandated by the federal oversight agency, Centers for Medicare and Medicaid Services (CMS) and must be followed in order for deferred invoice reimbursements to be paid.
  • DHCS will be adopting an appeal process for LEAs to address concerns LEAs may have with decisions made by their LEC or LGA.  This process will allow LEAs direct contact with DHCS regarding policy issues.
  • The interim claiming process was also discussed.  Justifications for an unauthorized position will only have to be submitted the first time the position is included on a universe grid.
  • CMS has expressed their desire to have the LEA Medi-Cal Billing program (LBO) also move to an RMTS methodology in the near future.  This may combine the MAA and LBO program together.  It is too early to discuss any details of this request.
  • LAUSD, Sacramento City School District and Teachers for Healthy Kids are advocating for DHCS to further delay the implementation of RMTS due to concerns on how the new plan has been drafted.  Although it is important that all voices be heard, there are strong concerns that further delay could prevent California from having the new methodology (RMTS) operational on July 1, 2014.  It is very possible that if RMTS is not put into place by July 1, 2014, CMS could pull the plug on the MAA program in California which would result in not only no future participation but all unpaid (deferred) invoices and the invoices from the interim claiming years (12/13 and 13/14) could be forfeited.  The group (of attendees) trying to delay implementation has concerns about how RMTS would impact school districts.  These districts have contacted the California State Assembly- Committee on Health and the California Department of Education, Federal Policy Liaison.
  • If you have any questions regarding the implementation of the new methodology for the MAA program, please do not hesitate to contact your LEC or LGA or send your comments to DHCS  smaa@dhcs.ca.gov. 

 

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