10/18/2017

ODM Meeting: MDS Exception Reviews, Redeterminations, NF-LOC Rules

LeadingAge Ohio met with the Ohio Department of Medicaid (ODM) on October 12.  Key topics of discussion are highlighted below.

MDS Exception Reviews

ODM notified LeadingAge Ohio that the MDS Exception Reviews would begin on Monday October 16. ODM would provide organizations with a two (2) day notification as previously reported in the Source.  The purpose of the MDS exception reviews is to evaluate a SNF’s reported compliance through supportive documentation with the items documented on the MDS assessment.  ODM’s contractor Myers and Stauffers, LC would be auditing providers via the use of Myers and Stauffer’s SUPPORTIVE DOCUMENTATION REQUIREMENTS USER GUIDE AND EXCEPTION REVIEW OPERATIONS MANUAL (SDR).

LeadingAge Ohio emphatically expressed its concerns on the use of the Myers and Stauffer’s SDR manual for the exception reviews versus the Centers for Medicare and Medicaid Services Resident Assessment Instrument (RAI) manual that is the standard requirement, especially if done retrospectively.  LeadingAge Ohio reiterated that the question and answer document that Myers and Stauffer’s put forth still raised significant concerns. 

NOTE: On Friday, October 13 Al Dickerson, Deputy Director, Rate Setting and Cost Setting informed LeadingAge Ohio that the exception reviews scheduled for Monday, Oct 16, 2017 were being postponed.  See LeadingAge Ohio alert.  Mr. Dickerson confirmed on Tuesday, October 17 that MDS Exception Reviews are temporarily on hold pending internal Medicaid discussions.

LeadingAge Ohio is staying very close to this issue and will continue to keep its members abreast as things develop.

Please contact Nisha Hammel at nhammel@leadingageohio.org regarding advocacy on this topic and Stephanie DeWees at sdewees@leadingageohio.org regarding specifics on the content of the SDR manual and how is differs from the RAI manual.

Medicaid Redeterminations

Roberta (Birdie) Schwamberger, Eligibility Compliance Manager clarified the process of “auto disenrollment” for Medicaid beneficiaries.  Ms. Schwamberger reported that the new “passive renewal” process for redeterminations should make it easier for beneficiaries to retain their coverage.  The passive renewal process starts approximately seventy (70) days prior to the beneficiary’s redetermination date with an automated record check against the data sources available to ODM. If there is no change, the beneficiary will be automatically renewed and a letter of confirmation sent to the Medicaid beneficiary/ authorized representative noting the information used to determine eligibility and requesting follow up should the information used to determine eligibility have changed. If during the passive renewal process any information has changed, then the redetermination will fall out of the passive renewal process and a manual process which requires a manual review by the Medicaid case worker starts.  The beneficiary or authorized representative will have several contacts from the county caseworker via call and letter.  If the beneficiary does not respond to the notices, including a final notice fifteen (15) days prior to the renewal date, the beneficiary will be auto-terminated.  Ms. Schwamberger emphasized the fact that a response either written or verbal from the beneficiary regarding a response to the requested information was sufficient to stop the auto-termination process.   The auto-termination process could be stopped by a simple check of a box in the system even if the information received by the case worker had not been reviewed.  In response to questions on the ability for NF providers to have access to redetermination dates, Ms. Schwamberger stated that unless the provider was the authorized representative the provider would need to rely on the beneficiary or family to provide the redetermination date.  Ms. Schwamberger indicated that she would follow-up to confirm if the system notified all authorized representatives or just the family representative.  In addition, she will provide data on how many LTC beneficiaries have been auto disenrolled.

NF - Level of Care Rules

Tonya Hawkins, Chief, Front Door Policy Section shared that ODM is finalizing the new level of care rules.  The new level of care rules have been revised to reflect the new assessment tools (Adult Comprehensive Assessment Tool “ACAT” and Child Comprehensive Assessment Tool “CCAT”) as well as additional changes.  The NF LOC rule also incorporates language that the AAA’s can establish an effective date that is some time in the past.  The language as included in the rule 5160-3-14 B(3)is as follows, “A level of care effective date may precede the date that an ODM 10127 is submitted to the PAA.” Ms. Hawkins reported that the rules should be “original filed” in the very near future.

Post Payment Claims Audits

John Maynard, Director of Program Integrity and Mark Graves, Audit Manager stated that ICFs/IID post-payment claims audit reports for SYs 2013, 2014 and 2015 will be sent out within the next two weeks. ODM has dedicated two auditors to handle all the ICF cases to ensure continuity, other than Change of Providers (CHOPs). For SNFs, ODM expects the SY 2013 and 2014 to be sent out Spring and the SY 2015 and 2016 after the state fiscal year crossover.