2018 Individualized Education Program ( IEP) Fall Training … · 2020-01-05 · • IEP Brochure for Parents: DHS-3456 ... Medicaid Services (CMS) developed and then in 2011 implemented

Special Education and Medical Assistance Billing

2018 Individualized Education Program (IEP) Fall Training presented by

Julie Neururer, Jenny Roth and Jesusa Williams

2018 Fall Training – A.M. Agenda

• 8:30 – 9 a.m.: Registration and Refreshments

• 9 – 9:15 a.m.: Welcome

• 9:15 – 10:15 a.m.: Communications and Outreach **Forum April 18, 2019**

• 10:15 – 10:30 a.m.: Break

• 10:30 – 11:15 a.m.: Third Party Billing and Federal Regulations

• 11:15 – 12 noon: Consent and Private Insurance

• 12 – 12:30 p.m.: Working Lunch

9/21/2018 Minnesota Department of Human Services | mn.gov/dhs 2

2018 Fall Training – P.M. Agenda

• 12:30 – 12:45 p.m.: IEP Evaluation Documentation

• 12:45 – 1 p.m.: ICD-10

• 1 – 2 p.m.: IEP Documentation

• 2 – 2:15 p.m.: Break

• 2:15 – 2:30 p.m.: Remittance Advice (RA)

• 2:30 – 3 p.m.: Rates

• 3 – 3:30 p.m.: Open mic


Communications and Outreach Plan


Julie Neururer – Minnesota Department of Education (MDE)and Jenny Roth – Department of Human Services (DHS)

9/21/2018 Optio 5

Results from Training Survey

9/21/2018 6Optional Tagline Goes Here | mn.gov/websiteurl

Updates – What’s New

• DHS• Retrospective Review coming late October• Minnesota Provider Screening and Enrollment Portal• Special Transportation overpayment and modifiers• Personal Care Assistance (PCA) IEP/Plan of Care with example• New Modifiers 76 and 77 going away. Replaced by XE and XP• Children’s Therapeutic Services and Supports (CTSS) Opt #1 changes• IEP/Individual Family Support Plan (IFSP) checklist and service log• IEP Brochure for Parents: DHS-3456 (https://edocs.dhs.state.mn.us/lfserver/Public/DHS-3456-ENG)

• MDE• Third party state networking group• New third party web page/third party funding reference guide

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https://edocs.dhs.state.mn.us/lfserver/Public/DHS-3456-ENG

Provider News - Retrospective Review

• Schools are on the list of provider to take part in a retrospective review of theirdocumentation in late October.

• Reviews are being conducted on a quarterly basis. With a target of reviewing 1000claims per provider type.

• The review is to verify that accuracy of documentation, processes and billing.

• DHS is not looking for monetary recovery, but to ensure that the directions andinformation that is provided to schools is being used, or if there is a need forimprovement.

** See Provider News Notice: Individualized Education Program (IEP) retrospective review

https://mn.gov/dhs/partners-and-providers/news-initiatives-reports-workgroups/minnesota-health-care-programs/provider-news/

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Provider News – Provider Portal

The Minnesota Provider Screening and Enrollment (MPSE) portal is the new web-based application providers will use to submit and manage their enrollment records and requestsThe portal can only be access through MN-ITS

• Check to make sure the staff you have that are responsible for MHCP enrollment have assess to MN-ITS.

• Users will have to provide the Federal Employee Identification Number (FEIN) or Social Security Number (SSN) on the provider file for access approval.

• All documents submitted through the portal must be a PDF.

** See Provider News Notice: Online Provider Screening and Enrollment (MPSE) portal coming soonhttps://mn.gov/dhs/partners-and-providers/news-initiatives-reports-workgroups/minnesota-health-care-programs/provider-news/

Also, watch for updates about this process at the Minnesota Provider Screening and Enrollment (MPSE) Portal webpagehttps://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/provider/mpse/

Check The MHCP Provider Screening and Enrollment page for training dates and locations.https://mn.gov/dhs/partners-and-providers/training-conferences/minnesota-health-care-programs/provider-training/mpse-portal-training.jsp

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https://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/provider/mpse/

https://mn.gov/dhs/partners-and-providers/training-conferences/minnesota-health-care-programs/provider-training/mpse-portal-training.jsp

Procedure Codes and Modifiers

• In 2010 as part of the Affordable Care Act, the Centers for Medicare and Medicaid Services (CMS) developed and then in 2011 implemented the National Correct Coding initiative (NCCI or CCI) to promote correct coding methodologies and control inappropriate payments.

• In the 2015-16 and 2016-17 school years there were $250,000 worth of transportation claims that were paid incorrectly because of billing errors.

• Encourage your schools to:• Check with their software vendors if to determine if there is an issue

• Check their data and their remits

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Provider News – Modifier Change

CMS updated the definition of two of the modifiers, we asked school to use in situation where without further explanation would appear to be duplicative. Currently we use:

• Modifier 76 (each additional transport trip per day). Effective Nov. 1, 2018 use modifier XE• Modifier 77 (same service different provider) Effective Nov. 1, 2018 use modifier XP

This is a coding change, it will not effect coverage or payment when used as directed.

** See Provider News Notice:Special education: Individualized Education Program Or Individualized Family Service Plan (IFSP)


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Third Party Billing and Data

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Julie Neururer - MDE

Third Party State and Federal Regulation

• Schools are obligated to provide specialized instruction and related services at no costto families, but not prohibited from charging others (P.L. 94-142 / 1975)

• May use whatever state, local, federal and private sources are available (34 CFR §300.103(a))

• Financial responsibility of State Medicaid Agency precedes that of local educationagency (34 CFR §300.154(a)(1))

• Beginning July 1, 2000, districts shall seek reimbursement from third parties(Minn. Stat. §125A.21, subd.2)

• If a public agency other than an educational agency fails to provide or pay for specialeducation and related services, the local education agency (LEA) must provide or payfor these services to the child in a timely manner.

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Eligible Providers

• To bill Medical Assistance (MA) for the federal share of IEP health relatedservices, districts and tribal schools must enroll with Minnesota Health CarePrograms (MHCP) as a health care provider.

• It is the responsibility of the districts to ensure the individuals performing IEPhealth related services are qualified, properly trained, licensed, certified and areworking within their scope of practice.

9/21/2018 14Minnesota Department of

IEP Services

• Mental health - CTSS

• Nursing Services

• Occupational Therapy (OT)

• Physical Therapy (PT)

• Speech Language Pathology andaudiology service

• Personal Care Assistance

• Assistive technology devices

• Specialized Transportation

• Interpreter services


Student Data

Our children count…

• 600,139 children ages 0-21 were enrolled in Minnesota Health Care Programs (MHCP)

• 35,214 children enrolled in MHCP in fiscal year (FY) 16 received IEP services.

• 52,500,000 MA revenue FY16

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Minnesota School District Revenue from Third Party Reimbursement

9/21/2018 17Minnesota Department of Human Services | mn.gov/dhs

Minnesota Special Education Child Count - Ages 0-21

Third Party Funding Reference Guide

Now to include…

• Rate setting MDE data

• Special Education Data Reporting Application (SEDRA) coding examples

• Reporting Revenue

• Maintenance of Effort

• District Use of Third Party Revenue

• Administrative Costs of Third Party Reimbursement

• Training and Technical Assistance

• Benefits to Studentshttps://education.mn.gov/MDE/dse/schfin/sped/guide/

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https://education.mn.gov/MDE/dse/schfin/sped/guide/

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Health Related Services Page

• Formally known as “Third Party Billing Reimbursement”, now to include…

• Third Party Billing Reimbursement

• Nursing resources

• Mental Health resources

https://education.mn.gov/MDE/dse/sped/third/

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Third Party Networking Group

Goal…

Through stakeholder engagement and the development of evidence based procedures and practices the Third Party Coordinators group can assist schools in generating additional resources to create wellness and inclusion of our students with disabilities.

Objectives…

• Establish a collective group to formalize communication,

• Create workgroups to address billing issues and

• Organize and execute a Third Party Billing forum.

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Questions ?

Can you tell me…

What If…

Consents

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Julie Neururer - MDE

Parental Consent

• For children with disabilities covered by public benefits or insurance….

• School districts must always obtain parental consent before submitting bills toMA for special education services. School districts may obtain parent consent intwo ways:

1) with school district consent forms (e.g. the MDE recommended form); and

2) the Minnesota Health Care Programs (MHCP) application.

Federal regulations require school districts to provide specific information to parents before obtaining their consent to bill Medical Assistance and submitting bills, and annually thereafter in the district’s Procedural Safeguards document.

34 CFR §300.154(d)(2)(iv)(A

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Informed Consent

Informed consent means:

• The parent has been fully informed of all information relevant to the activity for whichconsent is sought, in his or her native language, or other mode of communication

34 CFR §300.9(a

• The parent understands and agrees in writing to the carrying out of the activity for which hisor her consent is sought, and the consent describes that activity and lists the records (if any)that will be released and to whom 34 CFR §300.9(b

• Consent means that:

• The parent understands that the granting of consent is voluntary on the part of the parent andmay be revoked at anytime.

• If the parent revokes consent, that revocation is not retroactive 34 CFR §300.9(c)

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Part C Consent

Parental consent must be obtained to share information with the Minnesota Department of Human Services (DHS), the agency that administers MA and MinnesotaCare, for billing purposes and before disclosing your child’s personally identifiable information. This consent is only required one time.

• MCHP application can not be used as a signed informed consent under Part C

Written Annual Notice Related to Third Party Billing for IFSP Health Related Services.https://education.mn.gov/mdeprod/idcplg?IdcService=GET_FILE&dDocName=059954&RevisionSelectionMethod=latestReleased&Rendition=primary


https://education.mn.gov/mdeprod/idcplg?IdcService=GET_FILE&dDocName=059954&RevisionSelectionMethod=latestReleased&Rendition=primary

Limitations of Consent

A school district may not:

• Require parents to sign up for or enroll in public benefits or insurance programs inorder for their child to receive free appropriate public education (FAPE).CFR §300.154(d)(2)(i)

• Require parents to incur an out-of-pocket expense such as the payment of adeductible or co-pay amount incurred in filing a claim for services….but may pay the cost that the parents otherwise would be required to pay.

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Limitations of Billing

For children with disabilities covered by public benefits or private insurance….

• May not use a child's benefits under a public benefits or insurance program if that use would -• Decrease available lifetime coverage or any other insured benefit;

• Result in the family paying for services that would otherwise be covered by the public benefits or insurance programand that are required for the child outside of the time the child is in school;

• Increase premiums or lead to the discontinuation of benefits or insurance; or

• Risk loss of eligibility for home and community-based waivers, based on aggregate health-related expenditures34 CFR §300.154(d)(2)(iii)

• Payments to districts do not count toward monthly, annual, or lifetime thresholds for other MA orwaivered services (Minn. Stat. §256B.0625, subd. 26)

• Payments to districts by MA are not applied to MA parental fees or have any copays attached(Minn.. Stat. §256B.0625, subd.26)

• New DHS form link (https://edocs.dhs.state.mn.us/lfserver/Public/DHS-3456-ENG)29

https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=bf5b0caf7a40c6a0ce527503829df14e&term_occur=1&term_src=Title:34:Subtitle:B:Chapter:III:Part:300:Subpart:B:Subjgrp:48:300.154


Requesting initial informed written parental consent to share student and IEP information with Department of Human

Services in submitted claims.

Parent has received Notice of Procedural Safegaurds

Parent signs informed consent to share information with MHCP and

private insurance if necessary.

Proceed to bill. Then annual written notice of intention to bill

unless consent revoked.

Obtaining permission to share student and IEP information using MHCP application

Parent has received Notice of Procedural Safegaurds

Parent signs MHCP application allowing schools to share information with the Department of Human Services and

private insurance if neccessary.

MHCP application option requires a waiting period after receiving the Procedural Safeguards, up to one year. Then annualy written notice of intention to bill

unless consent revoked.*DHS will consider claims recevied up to 1 year from

the date of service.

Medical Assistance Billing Information and Consent Policy Revision• https://education.mn.gov/mdeprod/idcplg?IdcService=GET_FILE&dDocName=050970&RevisionSelectionMethod=latestReleased&Rendition=primary• Sharepoint (Shared Documents, Insurance denials, Announcements and Frequently Asked Questions)

MNsure paper application DHS-6696 (PDF).• https://edocs.dhs.state.mn.us/lfserver/Public/DHS-6696-ENG

Consent for Sharing of Medical Information • In your application for Minnesota Health Care Program coverage, you have given your written and signed consent to the following agencies and people

to share between them medical information about you only for the limited purposes indicated:• Health providers, including health plans, insurance agencies, MA or MinnesotaCare, county advocates, school districts, your county or state case

workers, and their contractors and subcontractors, for these purposes:• To determine who should pay for your health care• To provide, manage and coordinate health care services• All other agencies or people listed on this Notice of Privacy Practices and Notice of Rights and Responsibilities, for this purpose:• To administer Minnesota Health Care Programs, pay for services, and conduct research and investigations

https://education.mn.gov/mdeprod/idcplg?IdcService=GET_FILE&dDocName=050970&RevisionSelectionMethod=latestReleased&Rendition=primary


31

Common Consent Q & A

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Questions ?

Can you tell me…

What If…

Private InsuranceJulie Neururer - MDE

Reimbursement from PRIVATE INSURERS

1) Student has IEP with health related services.

2) Family has health insurance from both private insurer and Medical Assistance

First, review SharePoint (MDE makes the request on behalf of local school districts /charter schools)to determine if the private insurance pays for IEP health related services.

9/21/2018 35

Private Insurance Denial

Second, You can contact the MDE contracted representative to purse the

denial. If you can not determine, refer to the DHS IEP provider manual forbilling requirements. Minnesota Statute, section 125A.21

34 CFR §300.154 (The Individuals with Disabilities Education Act - IDEA)

*If you need access to SharePoint contact Julie Neururer (MDE)

*Private insurance does not pay for PCA or Special Transportation services no denialis needed.

9/21/2018 36

Questions ?

Can you tell me…

What If…

Evaluation and Assessments


Julie Neururer MDE

Evaluation Coverage Criteria

Effective August 2017 Medical Assistance will reimburse the federal share of the cost of covered health-related evaluations and assessments under the Individuals with Disabilities Education Act (IDEA) when conducted for the sole purpose of identifying the health related needs for a child’s IEP or IFSP.

MA will cover the time spent performing that evaluation or assessment even if the service does not get added to the IEP or IFSP or result in an IEP or IFSP.

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Changes for the School CTSS Application

Coming this fall:

• Option 1 will be separate from the Primary School CTSS Certification ApplicationProcess and will send a letter of intent (rather than the old option 1 application)to our rates consultant indicating that the school plans to bill for IEP mentalhealth assessments or evaluations for the sole purpose of determining the needsof the child for an IEP or IFSP.

• Options 2 and 3 will share the School CTSS Primary Certification Application, andthe application will require the appropriate information for each option.

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IEP evaluation assessments vs. Diagnostic Assessments

Difference between billable assessment (Option 1) and evaluation from mental health professional and Diagnostic Assessment CTSS (Option 2 and 3)

• Assessment for evaluation to determination IEP/IFSP eligibility• School psychologist or mental health professional or clinical trainee

• Diagnostic Assessment to diagnose and treat

• Mental health professional or clinical trainee

• Coming this fall…DHS new Option 1 letter of intent

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Evaluation Documentation

Description of evaluation activity

• Enter a description of the evaluation or assessment activities used to identifythe specific needs of the child or youth, and determination of the need for thehealth related service or supports.


Questions ?

Can you tell me…

What If…

ICD-10

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Jenny Roth DHS

Optional Tagline Goes Here | mn.gov/websiteurl

ICD – 10 – CM Code Sets

ICD-10-CM codes sets are used to identify the reason an assessment, evaluation or services was performed. This includes:

• Medical diagnoses or disorders

• Signs or symptoms

• Abnormal findings

• Chief complaints

• External causes of injury or disease

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Selecting an ICD – 10-CM code

The ICD – 10-CM code must:

• Clearly represent the medical need as identified in the child’s IEP or IFSP andlogically relate to the assessment or service being billed

• If a diagnosis is available you may use that as the primary diagnosis, but wouldstill need “secondary” to identify the why assessment was performed or why aservice or treatment is being provided

• In most cases you can document the diagnosis in the child’s file, and use theselected sign, symptoms or condition coded as the primary.

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IEP Services Documentation

9/21/2018 47

Jenny Roth DHS

Documentation of Medically Necessary

Establishing medical need requires that in addition to showing the child falls below prevailing standards and identifying a disability, the IEP must also identify the services that address the disability and develop a plan of service with clear and specific measureable goals and objectives.

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Errors Identified in Past Audits

• Non-covered services provided to students

• Documentation that does not demonstrate the need for thehealth related service

• Missing or Inadequate clinical notes/progress notes

• Lack of, or inadequate documentation in progress reports

• The start and end times for services rendered were notdocumented

• Records indicate the service was provided, but the attendancerecords show the child was not is school that particular day


Non-covered Services Provided to Student

What would make a service not covered?

• Not in the IEP or IFSP

• Not within the service providers scope of practice

• Unclear description of service (social or friendshipgroups)

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Documentation does not Demonstrate Need

Identify the decision making process.

• What test/instruments/protocols were performed and howthe child scored.

• Professional determination and description of what the childneeds and how it will be provided.

• How the services provided will assist the child in attendingschool.


Clarify the Need

Clearly explain how the sign, symptom, condition, disease or disorder the child is experiencing affects their ability to attend schools and receive a Free Appropriate Public Education



Clinic notes/Progress notes

What is in a clinical notes/progress note?• A description of the actual services provided during the

session, relating to goals or objectives on the IEP or IFSP.• Type and amount of services received• Concerns• Progress• Strategies and objectives to address the goals• Updates needed

Progress Reports

Based on measurable goals and outcomes – documenting what is being done and how the child is responding to the treatment.

• Measurable description of progress toward goals includingprogress toward each objective.

• Indicate whether or not they are making sufficientprogress to meet annual goals.


Documentation, Checklists and Service Logs

The start and end times for services rendered are now documented.

You have backup information for attendance.

• New DHS Forms were created to accommodate start and end time entry for all services• Software vendor supports have updated their systems• Schools attended Web X trainings on how to complete the new forms• Trained their staff• Updated and developed new time studies• Shared documents with other districts• Tested and provided input to DHS and MDE

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Attendance Records

Attendance record shows the child was not is school, but service was provided.

• Mistakes happen it could be somehow the teacher did notmark the child out sick or as coming in late,

• It could be the biller transposed a number in the date.

What can you do?


IEP Documentation

Record Keeping and Documentation

• Health Care Service Records

• Additional documentation information

• Service Time, Encounters (start and end times)

• Record Retention


http://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=dhs16_188548

PCA Plan of Care

PCA Plan of CareThe Minnesota Department of Human Services (DHS) has updated the IEP Services manual to reflect changes in the Personal Care Assistance (PCA) Plan of Care and PCA training requirement

• Schools will have the option to embed a PCA plan of care into a child’s IEP or create theplan of care as a separate document

• The example in the manual is provided to show the level of specific details needed in aPCA plan of care.

• Schools may follow their own school policy for format (template or form created bythe school, bulleted list, etc.)

• Follow school policy for documentation and location of the plan of care . (In the IEPor IFSP or in a or separate document.)

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http://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=dhs16_185220#pca

Questions ?

Can you tell me…

What If…

Rates and Payments

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Jesusa Williams - DHS

Optional Tagline Goes Here | mn.gov/websiteurl

Rates and Payments

Rates and Payments• Overview• Provider Tax• Cost Based Rates

• Assistive Technology• Special Transportation• All Other Health-Related Services

• Interim Rates and Final Rates• Appeal Final Rates• Reconciling Final Rates – Results• Reporting cost data – Districts Responsibility

• Payments• Administration Fee• Remittance Advice (RA)

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http://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=dhs16_188546

Data Needed to Calculate IEP Cost Based Rates


School Districts

• Direct Service Time

• Direct Encounters

MDE

• Total Annual Salary (per personnel type code)

• Total Contract Expenses (per personnel type code)

• Full Time Equivalence (FTE) (per personnel type code)

• District Fringe Benefit percent

• District Unrestricted Indirect Cost percent

• District Contract Days

• District Daily Hours

IEP Services Annual Data Report Form

Service Hours and Encounters

• Service Hours• Direct face to face time with MA-eligible child

• Multiple service providers = combine time of service providers and record in MA-eligiblechild’s activity logs

• Encounter• Count one encounter per child per IEP service per day

• Multiple encounters with child for same service – record as one encounter for service forthe day

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MDE - SPECIAL EDUCATION SALARY AND FTE INFORMATION FOR MEDICAL ASSISTANCE

REMINDERS

• Only costs reported through the SEDRA designated by MDE are included in the costbased rates for IEP services

• Districts are responsible for all required data reported to DHS and MDE, includingdata prepared by third parties

• Review all data for accuracy

• Review all data during the data review periods specified by MDE and DHS

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19/21/2018

Example: Calculation of IEP Rates for Occupational Therapy (OT)

Example: Calculation of IEP Rates Occupational Therapy per Day (unit)

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IEP Transportation Rates

• In FY 2010 MDE began calculating “trip rates” for each school district based upon the actual expenditures reported to MDE through Uniform Financial and Reporting Standards (UFARS) Finance 723

• The total transportation expenditures reported in Finance 723 (salaries of drivers only, fringe benefits, gas, oil, insurance, maintenance) are divided by the number of days that students with special education transportation required by the IEP (Minnesota Automated Reporting Student System (MARSS) Transportation Category 3) to get a daily rate, divided by two to get a trip rate (to and from school.)


IEP Transportation Rates Formula


719/21/2018

IEP Transportation Rate Example

Request for Rate Revisions

• Rates are too high/too low

• Changes in salary costs/contract expenses

• Changes in school staff personnel• New hires

• Retirement of staff

• Changes in services being provided in district• Increase/decrease in the # of kids in district

• Admission/release of high needs child in district

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FINAL RATES

• District notifies districts of final rates by email.

• Districts must review all submitted data and final rates within 60 days

• To dispute the final rates, a written appeal must be filed within 60days from the date the notice was mailed

• DHS cannot accept appeals filed after 60 days

• If no appeal is filed within 60 days, all paid claims are reprocessedwith the final rates.

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FORMAL APPEAL

• Appeal must list the disputed items, reasons for the dispute and the name and address of the contact person for the appeal.

• Send the appeal to: Dept. of Human ServicesIEP Services Rates SpecialistP.O. Box 64984St. Paul, Minnesota 55164

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SETTLE – UP UPDATE FOR FY 2016-2017

• Final Rates FY 16-17

• Interim Rates FY 18-19

• School Districts will be notified by email.

• Review Final Rates - within 60 days

• File Formal Appeal if necessary

• Formal Notification of Final Reprocessing once 60 days is up.

• Hold off Billing for 30 days for Fiscal Year 18-19 – Interim Rates are entered in system

MN Its Provider Mail Box - September 28, 2018

Thank you!
