Many of us have recently experienced desk reviews by PCG. The process is quite….cumbersome to say the least. However, with an open mind to continuously improving documentation and data collection not only for the IDEA requirements of compliance but also the maximization of resources for Medicaid reimbursable activities, such desk top audits can be helpful.

Tips as local directors we should take in to account when training and supervising personnel as well as working with local administrators and private day school partners on Medicaid include:

1. When a student has a Medicaid reimbursable activity (e.g. nursing or health aide services) that is required for daily administration, transportation as a related services is also a daily billable allowable expense. If a student only receives related services (e.g. speech, OT, PT) on an intermittent basis as opposed to daily, transportation is not a reimbursable expense on days the related services are not provided.
2. When a qualified provider cannot attend the IEP meeting but provides consultative services to the IEP Team for Medicaid reimbursable activities, make sure the qualified provider signs the IEP in blue ink before or after the IEP meeting and puts (consulted) next to their signature along with their credentials.
3. ICD10 is effective October 1, 2015. If a service falls on or after October 1st then an ICD10 code must be used. If the service is delivered on 09/30 and prior, then an ICD9 code must be used. PCG requests that claims for ICD9 and ICD10 are sent in separate files for processing. A single claim may not contain ICD9 and ICD10 codes and/or dates of service on the same claim, the result will be a denial of services.
4. LEAs must meet the minimum 85% compliance return rate for RMTS moments, however, all LEAs should strive for 100% compliance quarterly. LEAs that do not reach 85% compliance will be required to complete a Corrective Action Plan (CAP) detailing strategies to reach compliance for the upcoming quarter. Three consecutive quarters of non-compliance can result in potential discontinuation from the program. Work with LEA personnel as well as private day partners and come up with a communication plan that will ensure RMTS’ are completed in time as it is not just the LEA that is impacted but the entire State of Arizona with regards to the revenues received if we drop below the compliance return.
5. Districts must provide detailed Purchased Professional Staff (PPS) documentation or invoices from their vendors to help determine costs paid to each individual provider. Per Medicaid School Based Claiming (MSBC) program requirements, all costs must be supported by detailed invoices reflecting salaries paid to specific participants as listed on the staff pool list. Follow Chandler USD’s lead by attaching the following statement to all Medicaid vendor Purchase Orders (PO) as well as a sample invoice to support their request: “When billing (District Name), the invoice must be received within 30 days of service and contain the following: Healthcare provider’s name, provider’s specialty category, dates of service, number of hours providing service, daily/hourly rate, where services were provided, total amount of services, and purchase order number. Healthcare services must be separated from tuition costs.
   NOTE: (District Name) can deny payment if the invoice does not meet the guidelines as stated above.”
6. On January 16, 2014, the Centers for Medicare and Medicaid Services (CMS) released final rules regarding requirements for home and community based services (HCBS) operated under section 1915 of the Social Security Act (HCBS Rules). In Arizona, these requirements impact the Arizona Long Term Care Services (ALTCS) program members receiving services in the following residential and non-residential settings:

• Assisted Living Facilities
• Group Homes
• Adult and Child Development Homes
• Behavioral Health Residential Facilities Non-Residential
• Adult Day Health Programs
• Day Treatment and Training Programs
• Center-Based Employment Programs
• Group-Supported Employment Program