Preschool / School Supportive Health Services Program (SSHSP)

1. Preschool / School Supportive Health Services Program (SSHSP) SSHSP Fundamentals and 2013 Program Update Revision Date: June 5, 2013

2. Training Agenda • Section 1 • SSHSP Compliance History • SSHSP Training Recap • SSHSP Audit Findings • Section 2 • Review of Selected 2012-2013 Medicaid Alerts • Program Review • Program Updates • Section 3 • Certified Public Expenditures (CPEs) • Medicaid Administrative Claiming (MAC)

3. Section 1 Compliance History Training Recap Audit Findings

4. Three year Compliance Agreement between the federal government and NYS began in 2009 Compliance Agreement has been extended and will be in effect until NYS has met all requirements Elements of the Compliance Agreement include: NYS SSHSP Compliance Policy NYS Confidential Disclosure Policy NYS Compliance Officer/Compliance Committee OMIG Audit Requirements Independent Audits NYS Annual Written Reports Relevant Employee Compliance Training (Phase I, II & III) Implementation of State Plan Amendment (SPA) #09-61 SSHSP Compliance History

5. OMIG Compliance Program • Social Services Law §363-d • 18 NYCRR Part 521 • Medicaid providers must establish checks and balances to detect and prevent inaccurate billing and inappropriate practices in the Medicaid program • Is required for all persons, providers or affiliates claiming, ordering or receiving payments in excess of $500,000 (gross) from the NYS Medicaid program • Compliance programs do not need to be approved by OMIG, but must be annually recertified by person, provider or affiliate • Do you know the elements of a compliance program? • Do you know what your school district/county/affiliate compliance program entails?

6. Training Recap What was learned over the past 3 years? How would your school district/county fare in an OMIG/CMS audit today? What policies are in place in your school district/county to help avoid audit disallowances? Does your school district/county have a Compliance Officer? Do your relevant employees know who your compliance officer is and how to reach him or her? Is your school district/county only billing for services that are included in the IEP? Are your service practitioners appropriately credentialed? Handout 1 – Provider Qualifications and Documentation Requirements Do you have the appropriate documentation to support your SSHSP claims?

7. Training Recap It is the school district/county responsibility to ensure their relevant employees, including contracted personnel, are aware of and adhere to SSHSP billing requirements, compliance policies and all updates. Service(s) must be provided by a Medicaid qualified practitioner(s) Required documentation to support Medicaid claims must be retained Confidential disclosure policy must be displayed Topic specific training modules will be available on the Medicaid-in-Education website at www.oms.nysed.gov/medicaid once approved and/or updated.

8. OMIG Audit Findings for 2010 – 2012 Dates of Payment OMIG initiated 152 audits in the last 3 years.Findings include lacking or inappropriate documentation to support SSHSP claims: Written orders/referrals Missing date Dated after start of treatment “Under the Direction of”/”Under the Supervision of” (see Handout 2) No documentation of face-to-face meetings with student No documentation of the required meetings with practitioners Final OMIG audits can be found at: http://www.omig.ny.gov/audit/final-audit-reports Audit Findings

9. Regional Information Center (RIC)Documentation Reviews (Site Visits) • RICs will be conducting select documentation reviews of school districts/counties in their regions • Used as a tool to assist the school district/county in maintaining proper documentation to support Medicaid billing under the SSHSP • Are NOT audits • Listing of RICs and their contact information: http://www.oms.nysed.gov/medicaid/contacts/ric_contacts.html

10. Section 2 2012-2013 Medicaid Alerts Program Review Program Updates

11. Medicaid Alerts All Medicaid Alerts can be found at: http://www.oms.nysed.gov/medicaid/medicaid_alerts/home.html

12. Medicaid Alert #12-11 (issued 12/10/2012) Medicaid Policy Regarding Written Orders/Referrals All written orders/referrals completed on or after January 1, 2013 must either contain the frequency and duration of the service(s) to be furnished or must adopt - by explicit reference to the IEP - the frequency and duration of the ordered service(s) in the IEP. December 2012 Medicaid Alert

13. February 2013 Medicaid Alert Medicaid Alert # 13-01, (issued 2/6/2013) Medicaid Administrative Claiming Informs school districts about the Medicaid Administrative Claiming (MAC) program for the School Supportive Health Services Program. Additional federal funds under Medicaid may be available for the cost of administrative activities that directly support efforts to identify and enroll students who are potentially eligible for Medicaid into the Medicaid program, as well as those administrative activities that directly support the provision of medical services covered under the state Medicaid plan.

14. February 2013 Medicaid Alert Medicaid Alert # 13-02, (issued 2/7/2013) Psychological Evaluation and Counseling CPT Code Changes – Interim Process The NYS Department of Health (DOH) has been notified of changes made by the American Medical Association (AMA) to the psychotherapy CPT codes as of January 1, 2013. The AMA has issued several new codes with descriptors, discontinued some codes, and maintained some existing codes for psychological evaluations and counseling services. DOH is in the process of making the necessary system changes to accommodate these new CPT codes. A Medicaid Alert will be issued when servicing practitioners may use the new CPT codes. Continue using the existing CPT codes until further notice (see Handout 5)

15. March 2013 Medicaid Alert Medicaid Alert # 13-04, (Issued 4/4/2013) Requirement to Report Ordering/Referring Provider’s National Provider Identifier (NPI) on SSHSP Medicaid Claims • School Districts and counties are required to report the NPI of the ordering/referring provider on all Medicaid claims beginning with claims submitted for dates of service on and after May 1, 2013. • Psychological evaluations or psychological counseling services referred by an appropriate school official must use the school district or county billing provider NPI in place of the ordering/referring provider NPI on claims for services rendered on and after May 1, 2013. • School districts and counties must use the school district or county billing provider NPI in place of the ordering/referring provider NPI on claims for special transportation provided on and after May 1, 2013. 15

16. June 2013 Medicaid Alert Medicaid Alert # 13-05, (issued 6/5/2013) Timely Submission of SSHSP Medicaid Claims Effective December 1, 2013, SSHSP providers must: Submit Medicaid claims to eMedNY within 12 months after the date of service (DOS). Claims must be submitted to CNYRIC no later than 11.5 months after the date of service. This differs from the previous policy allowing the submission of claims to CNYRIC up to 22 months from the DOS. See the Medicaid-in-Education SSHSP revised 2013 Monthly Claiming/ Billing Calendar.

17. National Provider Identifier (NPI) • eMedNY-Affiliation Process for Attending Providers’ NPI: • Attending providers (employed and contracted) must report their NPI to the appropriate SSHSP billing providers (school districts and counties) • Billing providers must then affiliate the attending providers’ NPI to the school district/county SSHSP Medicaid provider number via eMedNY prior to submission of claims for dates of service on and after January 1, 2012 • See Medicaid Alerts #11-03 and #12-02 for additional information

18. International Classification of Diseases,9th Revision, Clinical Modification (ICD-9-CM) ICD-9-CM is a set of HIPAA translation codes used by health care providers to indicate diagnosis for all patient (student) encounters. Effective September 1, 2012 Medicaid claims must include a valid ICD-9 code that represents: A main condition or symptom that is the reason the service is being provided. The diagnosis or the reason/need for a medically necessary service included on the written order/referral for the SSHSP service can be used on claims for the ordered services. A resulting diagnosis from an evaluation could be used on the claim for the evaluation and the claims for ongoing services that were recommended as a result of the evaluation. See Medicaid Alert 12-04 for additional information.

19. School districts and counties must report the most specific ICD-9 code available. They must report a: three-digit code if there are no four-digit codes within the category, or four-digit code if there are no five-digit codes within the category, or five-digit code (fifth sub classification codes) for those categories where they are available. International Classification of Diseases,9th Revision, Clinical Modification (ICD-9-CM)

20. EXAMPLE: 314 Hyperkinetic syndrome of childhood 314.0 Attention deficit disorder 314.00 Without mention of hyperactivity 314.01 With hyperactivity 314.1 Hyperkinesis with developmental delay 314.2 Hyperkinetic conduct disorder 314.8 Other specified manifestations of hyperkinetic syndrome 314.9 Unspecified hyperkinetic syndrome International Classification of Diseases,9th Revision, Clinical Modification (ICD-9-CM) 3-digit code 4-digit code 5-digit code

21. International Classification of Diseases,9th Revision, Clinical Modification (ICD-9-CM) Claims are being denied because the most specific ICD-9 code is not being used on the electronic Medicaid claim. See your CNYRIC “Pre-adjudication” web report – Reason 254 invalid ICD-9 code. • Example: • 299.0 Autism Disorder (not a billable code) • 299.00 and 299.01 (are both billable and more specific) 21

22. International Classification of Diseases,9th Revision, Clinical Modification (ICD-9-CM) Q. What if the coding professional cannot assign a 4-digit or 5-digit code from the reason/need on the written order because the reason/need is not that specific? A. Suggest that the ordering/referring provider be contacted for clarification. Create and maintain detailed documentation of correspondence with ordering practitioner for the record (this documentation will be proof of the reason why the diagnosis on the order may not exactly match the diagnosis code used on claims).

23. American Physical Therapy Association (APTA) http://www.apta.org/ American Occupational Therapy Association (AOTA) http://www.aota.org/ American Speech-Language-Hearing Association (ASHA) http://www.asha.org/ American Psychological Association (APA) http://www.apa.org/ American Medical Association (AMA) http://www.ama-assn.org/ama The Centers for Medicare and Medicaid Services (CMS) http://www.cms.gov/Medicare/Coding/ICD9ProviderDiagnosticCodes/index.html The Centers for Disease Control and Prevention (CDC) http://www.cdc.gov/nchs/icd.htm International Classification of Diseases,9th Revision, Clinical Modification (ICD-9-CM) Coding guidance for professionals: 23

24. Business Office Reminder Electronic Transmitter Identification Number (ETIN) Involves the SSHSP billing provider giving approval to the Central New York Regional Information Center (CNYRIC) to receive their electronic remittance (payment) files for posting to the billing provider’s web reports and MedWeb system for downloading. ETIN certification statements must be renewed annually. Failure to renew will result in the inability to submit claims and receive payments (claims pended at CNYRIC). Renewal notices are sent to billing providers by Computer Science Corporation (CSC). Pre-printed forms must be signed and notarized. A copy of the recertification statement should be sent to your local Regional Information Center (RIC). Medicaid SSHSP Update

25. Edit Code #22 ‘Covered by Another Payer’ – Past Denials Business Office Reminder The implementation of HIPAA 5010 system changes caused many SSHSP claims to be denied by Computer Sciences Corporation (CSC) with the edit code #22, “Covered by Another Payer”. This issue was corrected as of 10/20/2012 processing. • Resulting Action for SSHSP edit #22 - past denials: • The edit #22 denied claims with a date of service (DOS) of 1/1/12 forward were reprocessed by CSC and paid in Cycle 1838 (DOH Check Date 11/12/2012). • The edit #22 denied claims with a DOS 12/1/10-12/31/11 were reprocessed by CSC and paid in Cycle 1854 (DOH Check Date 3/4/2013) and Cycle 1855 (DOH Check Date 3/11/2013). 25

26. Medicaid SSHSP Update Parental Consent On February 14, 2013, the Federal Department of Education published in the Federal Register IDEA Part B final regulations that the requirements in 34 CFR 300.154(d) related to parental consent to access public benefits or insurance (e.g., Medicaid) be amended. These final regulations, which take effect on March 18, 2013, will make it easier for school districts and counties to access public benefits while still protecting family rights. Specifically, these final regulations require that public agencies (school districts and counties): obtain a one-time written consent from the parent, after providing written notification . . . before accessing the child’s or the parent’s benefits or insurance for the first time . . . provide written notification to child’s parents before accessing the child’s or the parent’s public benefits or insurance for the first time and prior to obtaining the one-time parental consent and annually thereafter . . .

27. Medicaid SSHSP Update Parental Consent The written notice must explain all the of the protections available to parents under Part B of IDEA to ensure parents are fully informed of their rights The written notice must be written in language understandable to the general public and in the native language of the parent . . . unless it is clearly not feasible to do so. The NYS Office of Special Education Services has issued guidance on the implementation of these regulations: http://www.p12.nysed.gov/specialed/publications/parentconsent-publicbenefits.htm

28. Medicaid SSHSP Update Parental Consent Link to memorandum from the NYSED P-12 Office of Special Education: http://www.p12.nysed.gov/specialed/publications/parentconsent-publicbenefits.htm Link to the federal Office of Special Education & Rehabilitative Services (OSERS):  http://www2.ed.gov/policy/speced/reg/idea/part-b/part-b-parental-consent.html The federal link includes: An unofficial copy of the revised regulations A one-page summary of what the changes mean A Q&A to explain what the revisions mean to schools across the United States.

29. Medicaid billing providers are required to check the following exclusion lists: NYS Exclusion List http://www.omig.ny.gov/index.php/fraud/medicaid-terminations-and-exclusions Federal Exclusion List http://oig.hhs.gov/exclusions/index.asp School districts/countiesare no longer required to check the www.epls.com website (which is inactive) or the SAM website (which is where users are being directed to register) NYS/Federal Exclusion Lists UPDATE

30. Section 3 Certified Public Expenditures (CPEs) Medicaid Administrative Claiming (MAC) 30

31. Public Consulting Group, Inc. (PCG) Is a contractor of the New York State Department of Health and is assisting with the implementation of both CPEs and MAC. http://www.oms.nysed.gov/medicaid/CPEs/home.html Certified Public Expenditures (CPEs) Quarterly Random Moment Time Study (RMTS) Annual Cost Report Fee-for-Service, Cost Settlement Medicaid Administrative Claiming (MAC) Quarterly Random Moment Time Study (RMTS) Quarterly MAC Claim No Fee-for-Service, No Cost Settlement CPEs and MAC 31

32. Federal Medicaid law and regulation authorize the use of Certified Public Expenditures (CPEs), an annual cost reconciled and settled reimbursement methodology. The CPE methodology will allow additional federal funding for SSHSP direct service costs that are not covered by fee-for-service Medicaid reimbursement. The components of CPEs include: Random Moment Time Study (RMTS) Annual Cost Report Cost Settlement Process Certified Public Expenditures (CPEs)

33. Certified Public Expenditures (CPEs) Random Moment Time Study (RMTS) • For a school district or county to participate in the SSHSP (fee-for-service), they must participate in the RMTS • Measures the work effort of a group of providers involved in the SSHSP by sampling and analyzing the work efforts of a randomly selected cross-section of the group • RMTS coordinators provide rosters, on a quarterly basis, of eligible employees (do not include contracted practitioners) • Determines the percentage of time participants spend on direct medical services, administrative, and other activities • Used in both the CPE process and Medicaid Administrative Claiming (MAC) RMTS user guide: http://www.oms.nysed.gov/medicaid/CPEs/rmts_training_MarApr12.ppt

34. Certified Public Expenditures (CPEs) Random Moment Time Study (RMTS) • New York State must meet a 90% response rate • Participants are contacted via e-mail • If a participant is randomly selected, a response is required in the web-based RMTS system • Participants are notified 5 days in advance of moment and then again 24 hours prior to moment • Participants and Coordinators receive reminder notifications for moments without a response at 24 and 72 hours after the moment • Each moment needs to be completed within 5 days • Potential negative statewide impact if moments are not responded to

35. Certified Public Expenditures (CPEs) Annual Cost Report – due December 31 of each year • Cost based reconciliation process for direct medical services delivered by school districts and counties • The annual cost report will be used in conjunction with the quarterly random moment time study process to determine the school district/county cost basis • The annual cost report is completed electronically via the Medicaid Cost Reporting and Claiming System (MCRCS) • School districts and counties billing Medicaid under SSHSP (fee-for-service) are required to participate in the annual direct service cost reporting process.

36. Certified Public Expenditures (CPEs) Annual Cost Report – due December 31 of each year (continued) • Can only include salaries of those school district/county employed practitioners on the RMTS rosters. • Include contracted practitioners (non-tuition-based) on Supplemental Form. • Include contract practitioner costs and tuition costs on respective schedules of cost report • Contracted practitioners for whom costs are included on contractor page must be identified on Supplemental form • Cost reporting user guide: http://www.oms.nysed.gov/medicaid/CPEs/cost_reporting_guide.pdf

37. Certified Public Expenditures (CPEs) Cost Settlement (Direct Medical Services) • Annual cost report of SSHSP related direct services expenditures • Each school district’s/county’s cost report will be compared to their fee-for-service SSHSP billing • The resulting difference is the cost settlement • Three quarterly random moment time studies used in the cost settlement process

38. Medicaid Administrative Claiming (MAC) Federal reimbursement for administrative costs associated with the implementation of the SSHSP • Facilitating Medicaid Outreach • Facilitating Medicaid Eligibility Determination • Translation Related to Medicaid Services • Program Planning, Policy Development, and Interagency Coordination • Medicaid Related Training • Referral, Coordination and Monitoring of Medicaid Services

39. Medicaid Administrative Claiming (MAC) Two ways Medicaid Administration is claimed: Quarterly Cost Reports and Quarterly Administrative RMTS Via the Direct Cost Report and Quarterly Direct Service RMTS MAC is available to school districts participating in cost settlement process At this time, MAC is not being implemented for counties School districts may choose to participate at the beginning of any quarter MAC costs do not include the costs of developing an IEP See Medicaid Alert #13-01 MAC User Guide: http://www.oms.nysed.gov/medicaid/CPEs/MAC_Presentation_0213.ppt

40. Contact Information and Resources

41. Local Regional Information Center (RIC) Contacts <RIC – please enter your contact information as appropriate>

42. NYS SSHSP Contacts - SED Mailbox: medined@mail.nysed.gov NameTelephoneE-mail Region Steven Wright 518-486-4887 swright2@mail.nysed.gov NYC Kelly Gicobbi 518-486-7828 kgicobbi@mail.nysed.gov Broome/Mohawk Jeff Foley 518-402-5121 jfoley@mail.nysed.gov Nassau/Suffolk /Northeast Paula Cooper 518-402-5218 pcooper@mail.nysed.gov Mid Hudson/ Westchester/ Northeast Sheila Costa 518-474-4178 scosta@mail.nysed.gov Western/Southern Tier Kelly Mason 518-486-2287 kmason2@mail.nysed.gov Monroe/ Central/Finger Lakes

43. NYS SSHSP Contacts - DOH NameTelephoneE-mail Connie Donohue 518-473-2160 cld03@health.state.ny.us Cristin Carter 518-473-2160 cmc10@health.state.ny.us Melissa Kinnicutt 518-473-2160 mak16@health.state.ny.us

44. Listserv Medicaid Listserv To subscribe, please send an e-mail message to: LISTSERV@LISTSERV.NYSED.GOV Subject = Subscribe The body of the message must read: SUBSCRIBE MEDINED firstname lastname Complete instructions for subscribing/unsubscribing at http://www.oms.nysed.gov/medicaid/listserv_registration.html

45. Medicaid Resources NYSED Medicaid-in-Education Website http://www.oms.nysed.gov/medicaid/ • Medicaid-in-Education Handbook • Medicaid-in-Education Questions & Answers • Medicaid Alerts • Claiming and Billing Calendar • Training Calendar NYSED Office of Professions http://www.op.nysed.gov NYS Department of Health http://www.health.state.ny.us/health_care/medicaid National Alliance for Medicaid in Education (NAME) http://www.medicaidforeducation.org/

46. Public Consulting Group, Inc. Hotline: 866-912-2974 E-mail: NYSSHSP@pcgus.com

47. OMIG Contact Information E-mail for compliance questions: compliance@omig.ny.gov Website: www.omig.ny.gov OMIG ListServ Subscriptions: http://www.omig.ny.gov/omig-email-list-subscriptions ComplianceExclusion Lists Dedicated Line Sean Parker Bureau of Compliance 518-402-1816 518-408-0401

48. Thank you!