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 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 the completion of a Managed Long Term Services and Supports (MLTSS) comprehensive care plan take place in the home?
No, for the LTSS Comprehensive Care Plan and Update measure, the care plan does not have to take place in the member’s home. However, it must be done face-to-face unless certain exceptions are met. These exceptions include circumstances in which:
- The member was offered a face-to-face discussion and refused (either refused a face-to-face encounter or requested a telephone discussion instead of a face-to-face discussion).
- The state policy, regulation, or other state guidance excludes the member from a requirement for face-to-face discussion of a care plan.
What if there are multiple Managed Long Term Services and Supports (MLTSS) LTSS Comprehensive Care Plan and Update care plans documented during the measurement period?
Use the most recently updated care plan.
How should a Managed Long Term Services and Supports (MLTSS) member's refusal to sign an LTSS Comprehensive Care Plan and Update plan be documented?
To meet the LTSS Comprehensive Care Plan and Update measure numerator, the care plan must be signed by the member, unless the care plan is under appeal in the specified timeframe, and there is documentation that the care plan was in appeal. There is an exclusion for members who refuse to take part in care planning. This exclusion is reported with the measure rate, so the overall measure rate can be interpreted correctly. For example, a plan that is not successful at engaging members in care planning, indicated by a high exclusion rate, would suggest the overall rate on the measure should be interpreted with caution.
What if a Managed Long Term Services and Supports (MLTSS) member could not be reached for the LTSS Comprehensive Care Plan and Update?
There must be documentation that at least three attempts were made to reach the member, and they could not be reached. The rate of exclusion due to inability to reach a member should also be reported along with the measure performance rate.
What if a Managed Long Term Services and Supports (MLTSS) member either does not have a caregiver involved or does not want their caregiver involved in the LTSS Comprehensive Care Plan and Update? What if a member's caregiver declines to participate in care planning?
In these circumstances, MLTSS plan records should clearly document that no caregiver was involved to satisfy the measure criteria. For example, there are situations in which it may not be appropriate to engage the caregiver, including cases in which the member refused to involve the caregiver, or the invited caregiver declined to participate. Reasons for lack of caregiver involvement are not required; documentation that a caregiver was not involved suffices.
If no deficit is identified for one of the core elements required for the care plan (for example, functional needs), what should the care plan contain?
For certain elements of the care plan, documentation of no deficit suffices to receive credit for the elements (for example, functional needs, medical needs, cognitive impairment needs). Other elements in the core and supplemental rates of the Managed Long Term Services and Supports (MLTSS) LTSS Comprehensive Care Plan and Update measure require documentation regardless of whether a deficit is identified (for example, individualized member goal, plan for follow-up and communication, plan for emergency). Refer to the details in the measure specification to identify where documentation of no deficit meets the element definition.
How will the Centers for Medicare & Medicaid Services (CMS) disseminate the list of Healthcare Common Procedure Coding System (HCPCS) codes subject to the federal financial participation (FFP) limit each year?
Annually, CMS will request a list of covered durable medical equipment HCPCS codes from the Medicare Pricing, Data Analysis and Coding Contractor. Once the list is received, CMS will distribute the list through the CMS Regional Office Associate Regional Administrator.
States have raised concerns around the federal financial participation (FFP) limit demonstration due date because they may not have received all durable medical equipment (DME) claims from providers at the point demonstrations are due. How may a state ensure compliance with the FFP limit without allowing for a claims run-out period.
To address claims run-out and ensure compliance with the FFP limit, we recommend states with these concerns conduct interim FFP limit demonstrations for DME no later than three months after the end of the calendar year for the previous calendar year (that is, January 1-December 31). The interim DME FFP limit demonstration will be due by March 31 of each calendar year and will contain data for the period of January 1 to December 31 of the preceding year. The final demonstration would be due one year later on March 31 and include all claims received during the run-out period dates of service within the interim demonstration period. The interim demonstration process should provide states with an understanding of potential violations of the FFP to make any necessary budgeting and rate changes. This method is being used to allow provide for a reasonable claims run out period as allowed under 42 CFR 424.44, which states that claims must be filed no later than one calendar year after the date of service.
When is the federal financial participation (FFP) limit demonstration due? And for what period of time? Why is the Centers for Medicare & Medicaid Services using calendar year for this demonstration?
Federal financial participation (FFP) limit demonstrations for durable medical equipment (DME) will be due 3 months after the end of the calendar year for the previous calendar year (i.e., January 1-December 31). The first DME FFP limit demonstration will be due by March 31, 2019 and will contain data for the period of January 1, 2018 to December 31, 2018. This reporting period was selected to coincide with the effective date of the statute (January 1, 2018).
Can you clarify that for each Healthcare Common Procedure Coding System code, a state should use the state-specific rate, which is adjusted by Medicare based on state specific geographic adjustors, and not the floor rate, which is Medicare's national rate for each specific code?
The statute does not compel states to set their payment rates for durable medical equipment (DME) at specific Medicare rates for each specific item. Instead, the statute applies a limit on available federal financial participation (FFP) for state aggregate expenditures. States have the flexibility to set their own rates for DME in the Medicaid program. If a state decides to set their Medicaid payment rates at or below Medicare rates in the state plan, the state should be specific about the fee schedule the state will use and be prepared to demonstrate that their rates do not exceed the amount Medicare would have paid in the aggregate, in order to avoid the annual FFP limit demonstration of aggregate expenditures. For the demonstration, the Centers for Medicare & Medicaid Services (CMS) will be using state-specific Medicare payment rates. With this limit of available FFP for the aggregate amount of DME, CMS will use either the Medicare rates specific to an area of the state for the services rendered in those areas, or the lowest of a state’s Medicare rates for comparison to the aggregate limit of FFP.