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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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Should I include discharges resulting in readmission to the institution in the Long Term Services and Supports (LTSS) Minimizing Institutional Length of Stay and LTSS Successful Transition after Long-Term Institutional Stay measure numerator?

No, discharges that result in readmission to the institution within 60 days of discharge from the institution do not meet the LTSS Minimizing Institutional Length of Stay and LTSS Successful Transition after Long-Term Institutional Stay measure numerator criteria.

FAQ ID:91146

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When counting the duration of a member's stay for the long term services and supports (LTSS) Minimizing Institutional Length of Stay and LTSS Successful Transition after Long-Term Institutional Stay measure numerator calculation, should I include the day of discharge?

Do not count the day of discharge unless the member’s admission and discharge occurred on the same day. If the admission and discharge occurred on the same day, the number of days in the stay is equal to one.

FAQ ID:91156

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If there is no discharge, how should I calculate the length of stay for the long term services and supports (LTSS) Minimizing Institutional Length of Stay and LTSS Successful Transition after Long-Term Institutional Stay measure numerator?

If there is no discharge, calculate the length of stay as the date of the last day of the measurement year minus the institutional facility admission date.

FAQ ID:91166

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Are the long term services and supports (LTSS) Minimizing Institutional Length of Stay and LTSS Successful Transition after Long-Term Institutional Stay measures risk-adjusted?

Yes, the LTSS Minimizing Institutional Length of Stay and LTSS Successful Transition after Long- Term Institutional Stay measures are risk-adjusted based on the members’ dual eligibility status, age and gender, diagnoses from the institutional facility admission, and number of hospital stays and months of enrollment in the classification period. See the risk adjustment weights needed for these measures are in the risk adjustment tables (XLSX, 59.69 KB).

FAQ ID:91171

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Should a member's admission be included in the Long Term Services and Supports (LTSS) Successful Transition after Long-Term Institutional Stay measure denominator if it was a direct transfer from another institution?

No, do not include these admissions in the LTSS Successful Transition after Long-Term Institutional Stay measure denominator.

FAQ ID:91176

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Would an admission to an institutional facility following a discharge from another facility two days prior be considered a direct transfer?

No, these would be two distinct institutional stays; do not remove this admission from the Long Term Services and Supports Successful Transition after Long-Term Institutional Stay measure denominator.

FAQ ID:91186

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How should I account for a member's death when calculating the Long Term Services and Supports Successful Transition after Long-Term Institutional Stay member's numerator and denominator?

If the member died in the institution or within one day of discharge from the institution, do not include their admission in the denominator. Members who died one day after discharge are excluded because of the high number of deaths the day after discharge observed while testing this measure; such members are unlikely to have been discharged alive. If the member died between day 2 and day 60 during the 60 days following discharge from the long-term institutional stay, do not include their discharge in the numerator.

FAQ ID:91191

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Please clarify that state flexibility to reimburse in the aggregate extends to reimbursement rates for I/T/U pharmacies and FSS drugs, and that states can establish rates that are based on a variety of data sources, which may include FSS prices, national and State price surveys, AMP data, and other price benchmarks.

The new AAC requirements were designed to more accurately reflect the pharmacy providers' actual prices paid to acquire drugs and the professional services required to fill a prescription. We agree that each state is able to establish rates that satisfy (or are consistent with) AAC and may be based on a variety of data sources, which may include FSS prices, and other pricing benchmarks.

FAQ ID:95111

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If a state can prove that they are under the aggregate limits of AAC and PDF and have strong participation by pharmacies, are they required to adopt the AAC and PDF reimbursement methodology at the individual claim level?

All states are required to adopt the AAC and professional dispensing fee methodology; however, it is not required to be adopted at the individual claim level, but in the aggregate. In accordance with the regulatory requirements at 42 CFR 447.512(b), the state is responsible for establishing a payment methodology, that must not exceed, in the aggregate, payment levels that the agency has determined by applying the lower of the AAC plus a professional dispensing fee or the providers' usual and customary charges to the general public. In conjunction with this the state is also responsible to ensure that pharmacy reimbursement is consistent

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with the requirements of section 1902(a)(30)(A) of the Act, which specify that provider reimbursement rates should be consistent with efficiency, economy, and quality of care while assuring sufficient beneficiary access.

FAQ ID:94691

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If a state is already using actual acquisition cost (AAC) as their reimbursement methodology, does the state need to file a State Plan Amendment (SPA) or provide assurances that the current formula meets requirements established in the final rule? Is there a requirement for such states to file a SPA to provide assurance that the state's current dispensing fee amount meets the requirements of the final rule?

If a state is already making payment for prescription drugs under its state plan based on AAC, it may continue to use that methodology. However, if a state decides to change its AAC model of reimbursement, (e.g., the state decides to use the National Average Drug Acquisition Cost (NADAC) instead of a state survey to implement a payment methodology based on AAC), the state must submit a new SPA through the formal SPA process for review.

Additionally, the state should review its currently approved professional dispensing fee (PDF) to determine if, in light of the regulation (42 CFR 447.518), the PDF needs to be revised and a SPA needs to be submitted. The state does not have to submit a new SPA to provide assurance that its dispensing fee is reasonable.

Furthermore, we expect that all states, even those currently operating under an AAC reimbursement methodology, will evaluate their current state plans to determine if a SPA will be required to comply with the reimbursement requirements (including, but not limited to, AAC, PDF, 340B and the federal upper limits (FULs)).

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FAQ ID:94671

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