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Frequently Asked Questions

Frequently Asked Questions are used to provide additional information and/or statutory guidance not found in State Medicaid Director Letters, State Health Official Letters, or CMCS Informational Bulletins. The different sets of FAQs as originally released can be accessed below.

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We understand that Deloitte (Center for Medicare & Medicaid Services contractor) will be calculating the average GPCI values across counties for each state to use in paying primary care providers under CMS 2370-F. When can we expect those values to be disseminated? Will the formula weight each county equally, or will some alternative weight be used based on county population or some other factor?

The Center for Medicare & Medicaid Services (CMS) disseminated the Deloitte fee for service tool to states through the CMS Regional Offices in early January. It permits states to develop rates for each code based on the decisions it makes about site of service and geographic adjustments. The formula used to develop the rate weights each county equally and does not incorporate a weighting factor for population. Using a rate weighted by population is not an option for states to use in developing their fee schedules.

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FAQ ID:94156

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We received the Deloitte Excel model but have been unable to open some of the files. Can you help?

CMS can produce the fee schedules for states that are unable to run the program. States should contact Christopher Thompson at Christopher.thompson@cms.hhs.gov.

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FAQ ID:94161

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Community clinics in my state (clinics other than Federally Qualified Health Center and Rural Health Clinic are reimbursed at the same rate as a physician. They do not receive a bundled or encounter rate. Are they eligible for the higher payment under CMS 2370-F? Would they have to attest that 60 percent of the services provided in the clinic are within the qualifying Evaluation & Management (E&M) codes? Are they required to pass through any increased payments in the form of higher wages for the health care professionals they employ?

Higher payment made under the requirements of the regulation is for physicians reimbursed pursuant to a physician fee schedule. Physicians working in a clinic and reimbursed through a physician fee schedule could qualify for higher payments if they are appropriately Board certified or if 60 percent of the services that he or she provides is for the specified primary care services. Since the clinic itself is not eligible, this percentage of services threshold cannot be based on the aggregate of all services provided by all practitioners within the facility, only on services the individual physicians.

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FAQ ID:94171

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For physicians in neighboring states, can we require them to self-attest under CMS 2370-F using our state's protocol, rather than relying on the determination made by the home state's Medicaid program?

Yes.

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FAQ ID:94176

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What federal match rate is available to the states for administrative costs incurred from implementation of the CMS 2370-F rule?

The regular administrative federal match rate is applicable to administrative costs associated with implementation of this rule. Section 1905(dd) of the Social Security Act (the Act) authorizes increased Federal Medical Assistance Percentage (FMAP) only for eligible services provided by eligible providers pursuant to section 1902(a)(13)(C) of the Act

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FAQ ID:94226

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Are bonus payments and other incentive arrangements for health plans included in the CMS 2370-F methodology for determining the rate differential that is eligible for 100 percent (Federal Financial Plan) FFP?

We addressed the treatment of bonus payments and other incentive arrangements in terms of identifying the 2009 base rate in the final rule and take this opportunity to clarify that such arrangements are similarly excluded from the methodology for determining the rate differential.

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FAQ ID:94236

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Will Medicaid health plans be required to pay eligible providers the higher rate prior to receiving payment from the State for the higher rate?

While some plans may be able to pay the higher rate prior to receiving state funds, the final rule does not obligate a health plan to pay eligible providers the higher rate until they have been provided the funds to do so.

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FAQ ID:94251

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May providers self-attest through the use of a claims modifier to qualify for CMS 2370-F?

The State will issue a communication instructing providers that only those who are board-certified in a specified specialty/subspecialty or who meet the 60 percent threshold of appropriate claims history are eligible to receive the rate increase.

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FAQ ID:94271

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Can a state review providers whose claims meet the 60 percent threshold and assume that those providers would be automatically eligible?

Each physician must self-attest to being a qualified provider. It is not appropriate for a state to rely on a modifier to a claim for the initial self-attestation. Under the final rule, states are not required to independently verify the eligibility of each and every physician who might qualify for higher payment. Therefore, it is important that documentation exist that the physicians themselves supplied a proper attestation. That attestation has two parts. Physicians must attest to an appropriate specialty designation and also must further attest to whether that status is based on either being Board certified or to having the proper claims history. Once the signed self-attestation is in the hands of the Medicaid agency, claims may be identified for higher payment through the use of a modifier.

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FAQ ID:94276

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CMS clarified in the final rule for CMS 2370-F that, for out of state providers, the beneficiary's home state (e.g., state A) may defer to the determination of the physician's home state (e.g., state B) with respect to eligibility for higher payment. However, if states A and B receive different Medicare locality adjustments, which locality rate must be paid?

As with all Medicaid services, the state in which the beneficiary is determined eligible (state A) sets the payment rate for services. Therefore, state A would be responsible for paying using the methodology it had chosen with respect to determining the appropriate Medicare rate and would not be required to pay the rate the physician would receive from state B.

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FAQ ID:94361

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