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
Both the State Medicaid Director Letter describing the Substance Use Disorder (SUD) section 1115 demonstration opportunity and the Centers for Medicare & Medicaid Services (CMS) SUD Implementation Plan template, reference needs assessment tools and program standards established by the American Society for Addiction Medicine (ASAM). Is a state required to reference or rely on the ASAM Criteria in implementing an SUD section 1115 demonstration?
No, a state is not required to reference or rely on the ASAM Criteria however, states should use guidelines/patient placement tools that are comparable to ASAM criteria. The State Medicaid Director Letter describing the SUD section 1115 demonstration opportunity references the ASAM Criteria as a recognized standard and an example of a patient placement assessment tool that states could use. Participating states are expected to ensure that providers use an SUD-specific, multi-dimensional assessment tool in determining the types of treatments and level of care a beneficiary with an SUD may need. The ASAM Criteria is referenced as a representative example of such an assessment tool.
Some states proposed alternative needs assessment tools. CMS reviews each alternative proposal on an individual basis, and CMS has so far determined that those alternatives are comparable to the ASAM Criteria and meet the expectations for this demonstration initiative. In addition, participating states are expected to implement provider qualifications for residential treatment providers that reflect well-established standards for these treatment settings. Again, the ASAM Criteria is referenced as an example of a resource that states may use for determining those standards.
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.
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.