NEMTP resentation DSSI nstitute102711

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					NC Department of Health and Human Services   north carolina
                                                 medicaid


          N0N-EMERGENCY MEDICAL
              TRANSPORTATION

                  October 27, 2011

                   Sheila Platts
                 Sharon McDougal
                Carolyn McClanahan

                                                              DMA
 north carolina
     medicaid

     Current Medicaid Transportation Policy
• Title XIX of the Social Security Act does not
  specifically mandate provision of transportation as a
  Medicaid service.
• Authorizes states to cover transportation as either an
  optional service and/or as an administrative service.
• Administrative service reimbursement for
  transportation arranged.
• Paid by the county department of social services
  (DSS) acting as an agent for the state.



                                                     DMA
 north carolina
     medicaid

     Current Medicaid Transportation Policy
• Pays for transportation if the recipient receives a
  Medicaid covered service provided by an enrolled
  qualified Medicaid provider.
• Pays for the least expensive means suitable to the
  recipient’s needs.
• County DSS must arrange for or provide
  transportation to Medicaid covered services for
  authorized recipients
   – if the recipient is unable to arrange and/or pay for
     transportation.


                                                            DMA
 north carolina
     medicaid

     Current Medicaid Transportation Policy
• Must meet the recipient’s needs.
• Must be aware of available transportation sources in
  the county and locality where the recipient lives.
• Must make use of the most appropriate and cost-
  effective method.
   – including free transportation




                                                    DMA
 north carolina
     medicaid

     Current Medicaid Transportation Policy
• Documentation must support expenditures and
  requests for reimbursement.
• DSS may maintain the documentation in:
   – Income Maintenance case record
   – Transportation record for the recipient
   – A centralized system.




                                                DMA
 north carolina
     medicaid

     Current Medicaid Transportation Policy
• Reimburses the county for the Federal and State
  share of certain transportation costs.
• Must complete forms for reimbursement
   – DMA-2055 Reimbursement Request Form
   – DMA-2056 Medicaid Transportation Log




                                                    DMA
    north carolina
        medicaid

                     Current Structure
•     On-site Transportation Coordinators.
•     Written transportation plans.
•     Contracts with transportation providers.
•     Various ‘No Show’ policies
       – some do not have a “no show” policy.




                                                 DMA
 north carolina
     medicaid

                   Medicaid Transportation Costs
• Approximately $43M for State Fiscal Year 2010

• Overall Medicaid Budget $9,450,000,000
• Required Budget Reductions
   – $356,151,356 (state)
              •   2% rate reduction
              •   Reductions in utilization of services – limits on services
              •   $90 m thru CCNC
              •   Increased PI recoupments
              •   Assessments
              •   More Prior authorization
• Must meet budget targets or additional cuts will occur such as
   – Additional rate cuts
   – Elimination of services


                                                                               DMA
 north carolina
     medicaid

      2007 Quality Assurance Audit Findings
• The Medicaid Quality Assurance Section of the
  Division of Medical Assistance conducted a review of
  county reimbursements for Medicaid transportation
  costs.
• The focus of the review was to verify that recipients
  were authorized for Medicaid on the dates
  transportation services were provided and to verify
  that recipients received Medicaid covered services on
  the dates of the Medicaid transportation.
• The findings of the audit were published in DMA-
  Administrative Letter 04-07, Qualify Assurance
  Transportation Audit Results.

                                                    DMA
 north carolina
     medicaid

      2007 Quality Assurance Audit Findings
• The Qualify Assurance Section reviewed 15,843 claims statewide
  with Medicaid reimbursements totaling $397,892.52.

• They found that 1,567 claims totaling $38,379.59 did not meet the
  criteria required by policy to claim reimbursement.

• This resulted in an overall error rate of 9.89% based on the
  number of ineligible claims and a payment error rate of 9.65%
  based on the dollar amount of ineligible claims.

• The individual counties payment error rates ranged from 0% to
  41.41%.


                                                               DMA
 north carolina
     medicaid

      2007 Quality Assurance Audit Findings
• 1068 incidents of No evidence that a medical service
  was received on the date of transport.
• 164 - Transportation provided to non-allowable
  services such as WIC voucher pick up, after school
  care and employment.
• 113 - Recipient was not authorized for Medicaid on
  the date transportation was provided.




                                                    DMA
 north carolina
     medicaid

      2007 Quality Assurance Audit Findings
• 91 Reimbursements claimed for transportation
  provided for MQB and NC Health Choice recipients.
• 77 Reimbursements claimed when recipient failed to
  keep transportation appointment or cancelled
  medical appointment.
• 16 Transportation reimbursements claimed for
  lunches on trips that did not include an overnight
  stay.




                                                  DMA
 north carolina
     medicaid

      2007 Quality Assurance Audit Findings
• 14 - Transportation was provided for Special
  Assistance recipients not participating in the SA In
  Home Program.

• 13 -Transportation claimed when the only medical
  service provided was received at the recipient’s home
  as home health or personal care services.

• 3 - Transportation was billed twice for same trip.



                                                         DMA
 north carolina
     medicaid

      2007 Quality Assurance Audit Findings
• 2 - Medicaid identification number (MID) and
  corresponding recipient name did not match. Unable
  to determine if valid claim existed.

• 2 - Transportation was provided for recipient residing
  in skilled nursing facility.

• 2 - Medicaid reimbursement claimed when
  transportation provider was unable to transport
  recipient.


                                                     DMA
 north carolina
     medicaid

      2007 Quality Assurance Audit Findings
• 1 - County paid provider directly for ambulance
  transportation rather than requiring ambulance
  provider to bill Claims Contractor.
• 1 - County paid for attendant‘s “wait time”.
• DMA did not recoup for claims paid in error resulting
  from this audit, but used the audit as an educational
  tool for additional training and policy development.




                                                     DMA
 north carolina
     medicaid

                  CMS Compliance Review Process
In addition to internal Quality Assurance Audits, the
   Centers for Medicare and Medicaid Services (CMS)
   conduct periodic comprehensive program integrity
   reviews of the Medicaid Program.
The CMS compliance review process focuses on the
   following objectives:
• Determine compliance with Federal program integrity
   laws and regulations;




                                                  DMA
 north carolina
     medicaid

                  CMS Compliance Review Process
• Identify program vulnerabilities and effective
  practices;
• Help States improve its overall program integrity
  efforts; and
• Consider opportunities for future technical
  assistance.




                                                      DMA
 north carolina
     medicaid

              Feb 2008 CMS Compliance Review
• DMA cited for not adequately conducting oversight of
  the NEMT program
• Placed under corrective action plan
• Recommendations: Provide consistent oversight of
  NEMT; issue guidance to counties on obtaining
  Provider disclosures; check for excluded Providers;
  and verify the delivery of services billed.




                                                   DMA
 north carolina
     medicaid

                  Quality Assurance 2011
Trends
• Not a Medicaid covered service
• No Medicaid Authorization
• No medical service received
• No assessment
• No approval letter
• No valid vehicle insurance




                                           DMA
 north carolina
     medicaid

                  Quality Assurance 2011
• No valid vehicle registration
• No valid driver’s license
• Reimbursements for no shows
• Incorrect program/Class
• Not a Medicaid enrolled provider
• Medical necessity not verified




                                           DMA
 north carolina
     medicaid

                  Public Meeting
• July 14, 2011
• DMA held a Public Meeting to discuss NEMT.
• Representatives from county DSS, transportation
  Providers, other state agencies and the general
  public attended.




                                                    DMA
 north carolina
     medicaid

                  Public Meeting
• The general response to the public meeting was to
  give the DSS agencies and the transportation
  Providers a chance to fix the problems with NEMT.
• It was recommended that a Stakeholder Group be
  formed to develop ways to cut transportation costs
  and reduce error rates.




                                                   DMA
    north carolina
        medicaid

                        Stakeholder Group
A Stakeholder Group was formed with its members representing the
   county DSS agencies, transportation providers, county managers,
   county commissioners, and other state agencies.

The Stakeholder Group objective was to:

•     Develop and write a comprehensive statewide Transportation Plan, to
      be provided to DMA no later than October 15, 2011. Transportation
      Plan will use existing DMA Transportation policy as the baseline.
      Transportation Plan will define how DSS and Transportation Providers
      will work together to achieve expected outcomes.

•     The Plan will set measurable parameters for reducing costs such as
      determining $amount of budget reductions to be achieved; will
      establish a timeline for reducing costs this FY; and will establish
      consequences for failing to reduce costs.

                                                                            DMA
 north carolina
     medicaid

                  Stakeholder Group
• The Plan will set measurable parameters for reducing
  the error rate such as requiring %reduction of error
  rates; will establish a timeline for reducing the error
  rate this FY; and will establish resulting
  consequences for failure to reduce errors.

• The Plan will set uniform standards and requirements
  for Transportation Providers to use in claiming
  reimbursement including the use of standard logs,
  established codes, rates and provider requirements;
  and will establish consequences for failure to follow
  uniform standards and requirements.

                                                      DMA
 north carolina
     medicaid

                  Stakeholder Group
• The Plan will establish reporting requirements and
  performance posting of quality indicators for DSS
  and Transportation Providers.

• Establish a Medicaid Transportation Training and
  Communication Plan for county DSS that will address
  current policy requirements and provide State
  direction, oversight and expectations. The training
  plan will utilize the findings of audits to drive the
  curriculum content.


                                                       DMA
 north carolina
     medicaid

                  Policy Revisions
• Revisions have been made to MA-2910 and MA-3550.
• Policy revisions are effective January 1, 2012.




                                                DMA
 north carolina
     medicaid

                  Statewide NEMT Training
• Training on the revised NEMT policy will be provided
  statewide in November and December 2012.
• Consistent training will be provided with the same
  trainers delivering the training at each session.




                                                    DMA
 north carolina
     medicaid

                          Next Steps
• The Stakeholder Group will meet to finalize the statewide
  comprehensive Medical Transportation Plan on November 3,
  2011.

• Beginning in November 2011, NEMT Compliance reviews will be
  conducted in each of the 100 county DSS agencies by a private
  firm the State is contracting with.

• Based on the results of the compliance reviews, there will be
  recoupment of funds claimed for reimbursement in error.

• Training on the revised policy will be provided in November and
  December 2011.

• New policy will be implemented effective January 1, 2012.


                                                                  DMA
north carolina
    medicaid

                 Questions?




                              DMA

				
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