1. Claims Compliance Analysis Amy Kanter, SBS Auditor Michigan Department of Health and Human Services 2015 SBS Conference – Traverse City, MI August 17 & 18, 2015 1

2. Background (MI Medicaid Provider Manual) The Centers for Medicare & Medicaid Services (CMS) require Michigan SBS providers to submit procedure specific fee for service claims for all Medicaid allowable services These claims do not generate a payment but are required by CMS in order to monitor the services provided, the eligibility of the recipient, and provide an audit trail If the claim volume decreases significantly or drops to zero in any two consecutive months, all interim payments will be held until the provider is contacted and the issue resolved MDHHS will monitor provider claim volume to make sure that this mandate is followed

3. Background cont. (MI Medicaid Provider Manual) It is the intent of the State of pursue, when necessary, remedial action or implement a Corrective Plan if the ISDs or their vendors are not in compliance with Medicaid policy and procedures. If these actions are not successful, a payment freeze will be implemented and sanctions put in place until the matter is resolved. ISDs are responsible for the actions of their vendors

4. Historical Trends

5. Monthly Claims Comparison Process Queries are run to pull the claims Information is compiled into a spreadsheet and a rolling average is calculated  Can track long term trends rather than short term billing variances Percentages are identified Letters/Information Sheets are issued Response letters are issued for the documentation provided

6. Claims Pull Process Claims are pulled with the following criteria  By NPI number  Pulled by date of service  Claim type G- School Based Services  Limited to a paid date of the 18 th of each month

7. SBS Procedure Codes - Medical

8. SBS Procedure Codes - Speech

9. SBS Procedure Codes- Psych

10. SBS Procedure Codes- Trans

11. Psych, Speech, & Transportation Psych has been removed due to prior controversy Speech has been removed due to recent changes in the licensure Transportation is redundant as there are supposed to be medical services on the same day and would be counted in the Medical portion Our goal is to compare the numbers as equally across the ISD’s as possible

12. Claim Process Steps Information is input into a spreadsheet Calculate rolling averages Calculate a lag time in claims submissions to determine an average for a look back period to allow time for claims to be paid after submitted Calculate percentages

13. Letters Issued Letter 1- Warning Letter Letter 2- 30 Day Letter Letter 3- Suspension Letter In response to all required documentation- a response letter is issued to the ISD Information sheets are also provided to reflect the trends of the claims

14. Sample Warning Letter

15. Sample 30 Day Notice Letter

16. Sample Payment Suspension Letter

17. Sample Response Letter

18. Information Sheet Provided First page shows the actual claims that were paid by month Graph reflects the rolling averages and trends that may help identify problems Second portion shows the 12 month rolling average calculated Last section reflects the percentages calculated by dividing the current 12 month rolling average by the prior 12 month rolling average period

19. Sample Information Sheet 19

20. Sample Information Sheet Continued

22. Required Documentation Communication is important!! Documentation requires detail the reason for the drop in claims Documentation required the details on the corrective measures that will be put in place Documentation requires a date of which the corrective measure will start taking place and claim volumes should start to rise

23. Effects of Non-Compliance Interim payments can be suspended until the 85% level is reached If an ISD comes into compliance at any time during this process, the process stops and missed monthly payments can be made up if requested in writing Risks of non-compliance on the part of MDHHS  CMS sanctions  Possible loss of the program

24. Reasons Behind Drop In Claims Parental consent changes CHAMPS edit issues Reduction in staff and students Changes in federally funded employees Changes in who does the billing Other issues specifically within the ISD ** Reasons require specific detailed information

25. Claim Resolution Steps Determine if the problem lies within the claim being paid. We can provide assistance to help determine the cause of the denials Identify where the issues lie and possibly using the information sheet to provide trending information over the years Conference calls

26. Proactive Steps – ISD Staff training and follow up Regular evaluation of the RA to stay on top of denials and their reason Review the internal processes Know program changes Know procedure code changes Identify claim denials and causes

27. Questions? Contact Information – Email: kantera@michigan.gov Phone: 517-373-4522 Fax: 517-241-7408 27