CMAA: Medi-Cal % - ACC and/or CWA LGA Consortium Conference April 19, 2017

AGENDA Define the terms Why is a Medi-Cal % necessary? Discounted Activity Codes Pros and Cons Reminders

Medi-Cal Percentage The Medi-Cal Percentage is quite simply the percentage of a population that is composed of individuals enrolled in Medi-Cal. The crucial aspect of the definition is, how do you define the population? Is it the population of an entire county? Is it the population served by a claiming unit?

County Wide Average (CWA) The County Wide Average (CWA) is calculated quarterly by taking the total population of a county (denominator) and dividing it by those individuals within the county who were enrolled in Medi-Cal. DHCS releases a PPL once a year with the CWA calculated for all 4 quartrers of a fiscal year.

County Wide Average (CWA) CWAs vary greatly from county to county. According to PPL 16-017, in FY 15/16 Q4, Tulare County had the highest CWA in California – 55.27% According to PPL 16-017, in FY 15/16 Q4, Placer County had the lowest CWA in California – 17.06%

Actual Client Count (ACC) The first step taken when calculating an ACC is to define the population that is “served”. Now, do you have a way of checking the Medi- Cal status quarterly for all the member of the defined population?

Actual Client Count (ACC) If you have the defined the population served and have performed a Medi-Cal look up for all the individuals in the population, you have arrived at an ACC. Medi-Cal Enrollees Total Population Served

ACC – Best Practices Make sure to keep your calculation worksheet and supporting documentation in your audit file. Make sure to clearly define the population served in the Activity Sheets for your discounted activity codes. Be prepared for questions from DHCS on specifics regarding your ACC calculation.

Purpose of the Medi-Cal % The Medi-Cal % is applied to specific CMAA activity codes on the CMAA invoice; these codes are referred to as “discounted codes”. Centers for Medicare and Medicaid Services (CMS) only will reimburse that portion of the discounted activity code that applies to Medi- Cal enrollees.

Discounted Activity Codes Referral, Coordination & Monitoring of Medi-Cal Covered Services Arranging and/or Providing Non-Emergency, Non- Medical Transportation to a Medi-Cal Covered Service Contract Administration for Medi-Cal Covered Services specific to Medi-Cal and Non-Medi-Cal populations

Discounted Activity Codes Program Planning and Policy Development (B) (Non-Enhanced) for Medi-Cal Covered Services for Medi-Cal and Non-Medi-Cal clients Program Planning and Policy Development (SPMP) (B) (Non-Enhanced) for Medi-Cal Covered Services for Medi-Cal and Non-Medi-Cal clients

ACC vs. CWA The ACC is the default methodology for a claiming unit’s Medi-Cal %. If you elect to use the CWA instead of the ACC, then you must request authorization from DHCS. DHCS’s position is that if a claiming unit wishes to use the CWA the request for authorization must be made annually, preferably at the beginning of the fiscal year (July 1).

ACC vs. CWA When utilizing the CWA, you are at the mercy of DHCS as to when they will release the annual CWA PPL. Your claiming unit won’t be able to complete their quarterly invoice(s) without the PPL. Since the CWA includes the entire population of a county as its denominator, it is typically lower and in some cases much lower than the ACC methodology. Individuals served by most county departments are much more likely to be on Medi-Cal than the general population of a county. The CWA PPL for FY 15/16 wasn’t released until November 4, 2016.

ACC vs. CWA The ACC requires that your claiming unit keep more detailed backup information in the audit file than the CWA. DHCS is beginning to question if a claiming unit can accurately use 1 ACC for all of its discounted activity codes. As an example, should the same ACC methodology be used to calculate the Medi-Cal % for Referral, Coordination & Monitoring as is used for Program Planning & Policy Development?

Reminders If opting for the CWA, make sure and seek out annual approval from DHCS in writing. If opting for the ACC, make sure to keep sufficient back up in your audit file to support your calculation. The Medi-Cal % is very important and can have a sizeable impact on your CMAA invoice. The higher the Medi-Cal %, the higher the CMAA invoice.

On the Horizion DHCS is reviewing the Medi-Cal % policy and is in communication with CMS on potential changes that may ultimately be included in the implementation plan. We are likely to see changes made to Medi-Cal % requirements in the not so distant future.

Potential Changes DHCS may look to do the following: Emphasize that 1 ACC should, in general, not be applied to all discounted codes in a claiming unit. You may have to provide a detailed explanation if you want to use only 1 methodology for all of your discounted codes. Expect that claiming units seek out regular (perhaps annual) DHCS approval for using a hybrid approach to Medi-Cal % (ACC for some discounted codes, CWA for others).

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