Issue Analysis
A comprehensive explanation of policy issues affecting Medicaid reimbursement and billing programs. Each item includes an objective summary, related news and events, Paradigm Policy publications, regulations, and other source documents pulled from the Library.
California's Healthy Families Program Transition
Beginning no sooner than January 2013, California will begin a phased transition of more than 800,000 children from the Healthy Families Program to Medi-Cal.
Federal Deferral of California's School MAA Claims
On June 26, 2012, the federal Centers for Medicare and Medicaid Services (CMS) asked the state of California to re-evaluate unpaid School Medi-Cal Administrative Activities (SMAA) claims and to change the reimbursement program claiming methodology for fiscal year 2012/13.
Third Party Liability in Medicaid
The Medicaid program by law is intended to be the payer of last resort for health services to individuals with dual insurance coverage. A 2006 G.A.O. report cites that this population represents approximately 13% of Medicaid recipients at any given time during the year. Medicaid requirements for billing services to this population can block otherwise eligible reimbursements for school health services.
Medicaid's Free Care Practice
This Medicaid payment practice by CMS limits reimbursement to schools for medically necessary health services to regular education students with Medicaid coverage. Medicaid's free care practice prohibits reimbursement for covered services if a school provides those same services at no charge to other students.
Looking at RMTS for California's School MAA Program
California's Department of Health Care Services (DHCS) is currently negotiating the details of a new state plan for the school Medi-Cal administrative activities (MAA) program which is likely to rely on a new method of capturing reimbursable time and costs, the random moment time study (RMTS).
Transportation Billing in California
California regulations previously prevented school districts from receiving federal reimbursement for eligible transportation services when provided to students that did not require the use of a wheelchair or transportation in the prone or supine position. In September 2012, Governor Brown signed AB 2608 (Bonilla) into law, temporarily expanding transportation billing for schools under the LEA Billing Option program through 2018.
Parental Consent and IDEA
New federal regulations dictating parental consent requirements under the Individuals with Disabilities Education Act (IDEA) were issued in February of 2013, providing greater access to reimbursement for special education health services provided by schools. Previously, regulations for parental consent under 34 CFR § 300.154(d) (iv) (A) had stated that a school must obtain consent each time that access to public benefits or private insurance is sought. This regulation unintentionally restricted Medicaid billing for school health services provided by LEAs across the nation.
Reinvesting Medicaid Payments in California
To support provision of school health services, Local Education Agencies (LEAs) often reinvest their Medicaid reimbursements in additional health treatments and administration costs. The state of California recently amended reinvestment rules that had negatively affected Medicaid reimbursements.
Speech-Language Equivalency
In California, speech-language equivalency refers to an opinion issued by the state Attorney General in 2006 acknowledging that certain types of credentialed speech language pathologists (SLPs) were equivalent to the federal standard for speech pathologists, and the efforts made to incorporate this equivalency by removing restrictive billing requirements on credentialed SLPs participating in the LEA Billing Option program.
Federal Budget Control Act of 2011
Signed into law on August 2, 2011, the Budget Control Act of 2011 will reduce federal spending over the next 10 years by $917 billion. The act also increased the federal debt limit by $2.1 trillion, and includes an additional $1.2 trillion in automatic trigger cuts (excluding Medicaid) which were instituted after the Deficit Reduction "Super" Committee failed to propose an alternative package to trim the budget by the same amount by November 23, 2011.