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.
Frequently Asked Questions
Must a Managed Long Term Services and Supports (MLTSS) member have a documented care plan to be eligible for the LTSS Shared Care Plan with Primary Care Practitioner (PCP) measure?
Yes, the denominator for this measure includes all MLTSS members with a care plan meeting the criteria outlined in the LTSS Comprehensive Care Plan and Update measure core rate.
Who is considered a primary care practitioner (PCP) for the purpose of calculating the LTSS Shared Care Plan with Primary Care Practitioner (PCP) measure?
A PCP is a physician, non-physician (for example, nurse practitioner, physician assistant), or group of providers who offers primary care medical services. However, a care plan can be shared with a medical care practitioner other than the PCP if the practitioner is identified by the member as the primary point of contact for their medical care. Therefore, any medical care practitioner identified by the member as the primary point of contact for their medical care is considered their PCP for the purpose of calculating the measure.
Why is the care plan shared just with the primary care practitioner (PCP) or other documented medical care practitioner identified by the Managed Long Term Services and Supports (MLTSS) member?
The care plan is shared with the PCP to promote coordination of medical and LTSS services.
What are some acceptable ways to share the care plan with the primary care practitioner (PCP)? What if the Managed Long Term Services and Supports (MLTSS) participant refuses to share it?
The measure specifications allow sharing the care plan by mail, fax, secure email, or mutual access to an electronic portal or Electronic Health Record. Members who refuse to share their care plan are excluded from the measure denominator, but there must be documentation in the record that the member refused to share the care plan (noting verbal refusal suffices). The rate of exclusion due to a member refusing to share their care plan with the PCP should also be reported along with the measure performance rate.
Does the full Managed Long Term Services and Supports (MLTSS) care plan need to be shared with the primary care practitioner (PCP) to meet the numerator criteria for the LTSS Shared Care Plan with Primary Care Practitioner (PCP) measure?
No. MLTSS plans are not required to share the full care plan with the PCP or other documented medical care practitioner. MLTSS plans may choose which parts of the care plan are most relevant to the practitioner.
Is the provider's signature on the shared Managed Long Term Services and Supports (MLTSS) care plan required?
No, the LTSS Shared Care Plan with Primary Care Practitioner (PCP) measure only looks to see that a care plan was sent to a primary care practitioner (PCP) by the MLTSS plan. No signature from the PCP is necessary to count towards the numerator of this measure.
Do plans need to get a release of information from the Managed Long Term Services and Supports (MLTSS) member to share the care plan with the primary care practitioner (PCP)?
There is no need for a release of information. If a member gives the plan the contact information for their PCP, the plan can share information with that PCP. Plans or other providers of LTSS should try to coordinate LTSS services with medical services, even if they are not the primary payer for medical services for the member. Plans that do not know the member’s PCP can/should ask the member to identify their PCP and request their contact information. The measure is intended to determine whether plans tried to connect with the medical care provider. There is an exclusion in this measure for members who refuse to have their care plan shared with the PCP, so if the member refuses, this should be documented, and such members are excluded from the measure rate.
When a facility has been in operation for the dates of service covered by the Upper Payment Limit (UPL) demonstration, can a state demonstrate the UPL by using less than 12 months of data?
In accordance with Medicare cost reporting, the state must use 12 months of cost data reported by each facility. With regard to payment data, the state should use actual amounts, to the extent available, then calculate a claims completion factor based on historic utilization. The state’s UPL submission must include an explanation of its methodology to estimate payments. The use of a claims completion factor provides a reasonable estimate of the amount that Medicare would pay for these services, consistent with the UPL as defined at 42 CFR 447.272.
What data should my state provide to the Centers for Medicare & Medicaid Services (CMS) for the annual Upper Payment Limit demonstrations?
Effective state fiscal year 2020, each state must submit a complete data set of payments to Medicaid providers, including providers paid at cost, as well as critical access hospitals. This would require states to submit cost and payment data to CMS that previously was not requested.
Can you explain the difference between a prospective Upper Payment Limit (UPL) and a retrospective UPL?
The difference between a prospective and retrospective UPL is in the relationship between the UPL demonstration period and the date when the UPL is submitted. For a UPL demonstration period of 7/1/2018 to 6/30/2019, a UPL is considered retrospective when it is submitted on or after the start of the demonstration period (on or after 7/1/2018). Using the same UPL demonstration period (7/1/2018 to 6/30/2019), a UPL is considered prospective if it is submitted prior to 7/1/2018.