MAA: MAKING THE RIGHT CHOICE ACC or CWA? Direct Charge or Time Survey? Gretchen Schroeder HealthReach LGA Annual Conference 1

Making the Right Choice Actual Client Count (ACC) or County Wide Average (CWA) for the CMAA Medi-Cal Percentage? 2016 LGA Annual Conference 2

What is the Medi-Cal Percentage? When an activity is directed towards a group of people that is comprised of both Medi-Cal and non-Medi-Cal eligibles, the cost must be allocated to both groups. (Implementation Plan, page 50) CMS only wants to reimburse for the portion of time focused on Medi-Cal enrolled individuals The costs allocated to the Medi-Cal eligible portion of the group is known as the proportional Medi-Cal share or Medi-Cal percentage. Medi-Cal eligible = able to receive Medi-Cal benefits 2016 LGA Annual Conference 3

CMAA Medi-Cal Discount Methodology The proportional Medi-Cal share or Medi-Cal percentage is only applied to discounted codes. Discounted codes are also called Proportional codes in the Implementation plan (page 8) The Medi-Cal percentage is used for the following discounted codes: Code 6 Referral, Coordination & Monitoring Code 10 Arranging and/or Providing Non-Emergency, Non-Medical Transportation Code 13 Contract Administration Codes 17 & 18 Program Planning and Policy Development 2016 LGA Annual Conference 4

CMAA Medi-Cal Discount Methodology There are two allowable methodologies for establishing the Medi-Cal percentage used for discounting Actual Client Count (ACC) County-Wide Average (CWA) The Medi-Cal percentage should reflect the population being served by the claiming unit 2016 LGA Annual Conference 5

Actual Client Count The percentage is calculated by the number of Medi-Cal enrolled individuals your organization serves out of the total population your organization serves. ACC = Number of Medi-Cal Enrolled Served Number of Total Population Served 2016 LGA Annual Conference 6

Developing the ACC The ACC needs to be calculated quarterly Track the individuals served by the claiming unit for one month each quarter Should be the same month each quarter (1 st, 2 nd, or 3 rd ) Unduplicated client count Determine Medi-Cal status of all individuals served during that one month each quarter 2016 LGA Annual Conference 7

ACC Challenges Defining the population served Identifying the Medi-Cal status of each client Claiming units must be able to track the individuals they serve and gather enough information on them to look up their Medi-Cal status Claiming units need to find a mechanism to look up client Medi-Cal status MEDS Billing records Cannot use self-certification 2016 LGA Annual Conference 8

ACC Audit Requirements ACC must be computed quarterly Backup documentation must show: Client identifier, Medi-Cal status, Medi-Cal ID for those enrolled, and date of service Document method used for Medi-Cal status determination In the case of an audit, must be able to provide county, state, federal auditors the names of all served and the Medi-Cal numbers for those enrolled 2016 LGA Annual Conference 9

CWA Used for claiming units or MAA codes when: The population being served includes the entire county The claiming unit is not able to accurately track who they serve The claiming unit does not have a mechanism to verify Medi-Cal status The CWA is based on state published percentages Issued as a Policy and Procedure Letter (PPL) CWA = County Medi-Cal Enrolled Total County Population 2016 LGA Annual Conference 10

CWA Challenges To use the CWA, LGAs must submit a justification letter on LGA letter head to DHCS requesting authorization to use the CWA instead of the ACC (Implementation Plan, page 51, PPL ) MC% is generally much lower than the MC% of the population being served CWA PPL is generally not released until November of the following fiscal year, potentially delaying submission of invoices 2016 LGA Annual Conference 11

ACC or CWA? ACC DHCS preferred method Generally higher % Challenge to verify MC status of all clients served each quarter Requires strong audit documentation CWA Must submit a justification letter to DHCS Generally lower % Potential delay in invoice submission No backup required Less work 2016 LGA Annual Conference 12

Impact of Medi-Cal Discount Methodology on MAA Reimbursement ACC = 60% CWA of 28% $100,000 in discounted activity code costs for the quarter Using the ACC $100,000 *.60 = $60,000 $60,000 *.50 (FFP) = $30,000 MAA reimbursement = $30,000 Using the CWA $100,000 *.28 = $28,000 $28,000 *.50 (FFP) = $14,000 MAA reimbursement = $14, LGA Annual Conference 13

Multiple Medi-Cal Discount Percentages Claiming units can use different Medi-Cal discount percentages for different discounted activity codes Claiming units can use different ACC percentages for different discounted activity codes For example, a claiming unit could use an ACC for Code 6, Referral/Coordination & Monitoring, and the CWA for Code 17, Program Planning and Policy Development 2016 LGA Annual Conference 14

Multiple Medi-Cal Discount Percentages DHCS is developing a process to facilitate approval of multiple Medi-Cal discount percentages. Proposals include: Identifying on the CUFG the use of multiple Medi- Cal discount percentages to serve different populations Updating activity sheets to clearly identify methodology used Justification letter to explain use of multiple Medi-Cal discount percentages and process for developing the different percentages 2016 LGA Annual Conference 15

How Do You Decide? Determine % of time in discounted codes Define population “served” Review data collected on the population served Name DOB SSN Ability to access mechanism to verify Medi-Cal status Ability to meet audit file requirements LGA Annual Conference

Making the Right Choice Direct Charge Or Time Survey? 2016 LGA Annual Conference 17

Direct Charge or Time Survey? Direct Charge Staff Costs Non-salary or overhead costs Time Survey Staff Costs 2016 LGA Annual Conference 18

Direct Charge – Staff Costs Direct charge expenditures = staff costs that are 100% attributable to a single Medi-Cal eligible activity. CMAA Implementation Plan, Page 49 For staff that: Perform reimbursable activities 100 % of the time, or In distinct and documented blocks of time CMAA Implementation Plan, Page LGA Annual Conference 19

MAA Activities Commonly Direct Charged Code 8 - Facilitating Medi-Cal Application Code 10 - Arranging and/or Providing Non- Emergency, Non-Medical Transportation to a Medi-Cal Covered Service Code 19 - MAA/TCM Coordination and Claims Administration 2016 LGA Annual Conference 20

Direct Charging PP&PD According to MAC agreement, Program Planning & Policy Development can be direct charged when it is: Performed full time by a unit of one or more LGA employees whose tasks officially involve program planning and policy development 2016 LGA Annual Conference 21

Direct Charge – Staff Costs Must document the time spent on these activities in a log Must complete a “Staff Certification of Direct Charge Time” To certify that the percentage of claimable direct charge time is accurate, true, and correct. LGAs may also utilize the staff classification and payroll coding documents to verify the reimbursable costs for staff that perform Medi-Cal eligible services and/or activities 100 percent of the time LGA Annual Conference 22

Direct Charge Log Date activity was performed Amount of time spent Total hours paid for day, month or quarter Activity description 2016 LGA Annual Conference 23

Sample Direct Charge Log LGA: Claiming Unit: Code Name: (Full-time Employee) July Note: Total Paid Hours should match time card. DateMAA Activity Description TOTAL PAID HOURS MAA Coord/Claims Admin Direct Charge General Admin. Paid Time Off Other Programs 7/1 Reviewed time surveys /2 Attended MAA invoice training /3 Worked on MAA invoices / LGA Annual Conference 24

Staff Certification of Direct Charge Time 2016 LGA Annual Conference 25

Direct Charging Contractors Contract can be direct charged if: Describes the claimable activities to be performed Specifies the dollar amount for each claimable activity Contingency fees cannot be direct charged 2016 LGA Annual Conference 26

Direct Charge on CUFG Name of LGA Submittal Date Name of Claiming Unit Number of Staff Address Contact Person Phone Number Description of Claiming Unit Functions NUMBER OF STAFF MEDI-CAL ADMINISTRATIVE ACTIVITY CODE (ENTER NUMBER OF STAFF UNDER EACH ACTIVITY) STAFF JOB CLASSIFICATIONS SPMP NON- SPMP DIRECT CHARGE MAA Coordinator 1 1 Subcontract - HealthReach X X 2016 LGA Annual Conference 27

Direct Charging – Staff Costs Staff or contractor must be listed on the CUFG Staff must be trained Staff must sign a duty statement 2016 LGA Annual Conference 28

Direct Charge or Time Survey? Direct Charge Only document time spent on reimbursable activity Great for individuals who perform an activity in a block of time Good option for some contractors, when contract clearly describes activity and cost for that activity Time Survey Does not require a log of activities Allows for multiple codes to be claimed during the same encounter 2016 LGA Annual Conference 29

Direct Charge – Non-Salary Costs Non-salary and/or overhead costs associated with MAA specific reimbursable activities (designated as ‘non-salary costs’): Travel Training Printing Computer, or other equipment costs LGA’s must provide supporting documentation to substantiate any non-salary and/or overhead direct charges. (Implementation Plan, page 28) 2016 LGA Annual Conference 30

Direct Charge – Non-Salary Costs Transportation Costs for Medi-Cal enrolled individuals to a Medi-Cal covered service Need to track: Client name Client Medi-Cal ID Date of service Type of Medi-Cal covered service/provider Mileage, van operating costs, insurance, driver, etc. Bus tokens, taxi vouchers, etc LGA Annual Conference 31

Thank you for attending! 2016 LGA Annual Conference 32