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Reinvesting Medicaid Payments in California

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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.

Issue Summary: Reinvesting Medicaid Payments in California

California's Department of Health Care Services (DHCS) has changed internal rules that restricted funding on reinvested Medicaid payments for school health services. These rules disallowed school claiming for Medicaid (Medi-Cal) services and administration that were funded with reinvested reimbursements; this issue is often referred to as '5640' after the Standardized Account Code Structure (SACS) Resource Code used to identify LEA Billing reimbursements.

 

In July 2011, after reviewing current federal and state regulations and the state Medicaid plan, California DHCS confirmed that federal revenue received from the Local Education Agency Billing Option Program (through SPA 03-024) meets matching requirements for receiving additional Medicaid reimbursement dollars. This policy change, codified in Policy and Procedure Letter 11-013 (PPL 11-013), allows LEAs to reclaim eligible health service expenses incurred using Direct Service program reimbursements, including staff salaries supporting Medicaid Administrative Claiming (MAC) activities. Paradigm's Fiscal Division estimates that this policy change, which will allow LEAs to reclaim expenditures made with Direct Service billing reimbursements, has the potential to positively impact school Medicaid reimbursements for LEAs by up to 20%.

This additional revenue is now possible due primarily to the efforts of California's LEA Ad Hoc Committee, which collected supporting documentation from other entities, including Paradigm, and worked in partnership with DHCS to update the state's guidelines regarding Medicaid reimbursements.

In 2006, the state of California implemented a cost-reconciliation program for LEA Direct Service billing. This process, which required considerable work and resources, established that LEA Direct Service payments are reimbursement on actual cost and therefore qualify as a certified public expenditure (CPE) that can be used for supplemental reinvestment in eligible services and activities for reimbursement.

CPE is defined at the Federal level in the Office of Management and Budget (OMB) Circulars A-87 and A-133, as well as Title 45, § 433.51 of the Code of Federal Regulations published by the Centers for Medicare and Medicaid Services (CMS). California's regulations regarding CPE refer to these federal guidelines and are reiterated in state manuals and in contracts between California’s Department of Health Care Services (DHCS) and CMS as well as those between DHCS and California localities.

Although California has responded to the oversight that prevented LEAs from using CPE Direct Service reimbursement as matching funds to reinvest in eligible health services, this situation remains an issue for states using a similar Direct Services cost-reconciliation process in which reimbursements are incorrectly classified as ”federal” funds and therefore are restricted from reinvestment in school Medicaid programs.

Related News and Events: Reinvesting Medicaid Payments

Related Paradigm Publications: Reinvesting Medicaid Payments

  • 2011 Legislative and Regulatory Review
    Paradigm's Legislative and Regulatory Review is an annual review of federal and California state legislation and regulation that have impacted, or are projected to impact, school-based Medicaid billing and reimbursement programs; this publication is current at time of release, January 2012.
  • 2010 Legislative Review
    Includes information on federal legislative items (CMS 6028, HR 3590 'Health Reform', HR 1586, and CMS 2361) and state-specific California legislation (AB 3632, and the 1115 Waiver); publication is current at time of release, December 2010.

Related Library Files: Reinvesting Medicaid Payments

  • PPL 12-006
    PPL 12-006, LEA Medi-Cal Billing Option Program - Changes To Standardized Account Code Structure (SACS) Resource Code 5640, is related to the policy change originally set out in PPL 11-013 regarding the reinvestment of LEA Billing reimbursements in the MAA program. The PPL reiterates that Resource Code 5640 revenues will no longer be considered federal income for the purpose of the LEA Billing program, announces the official change to the California Department of Education (CDE) SACS coding structure to reflect the policy change, and outlines the incorporation of this policy into the CRCS for LEAs dating back to FY 09/10.
  • Moving Ahead Amid Fiscal Challenges: Results from a 50-State Medicaid Budget Survey for State Fiscal Years 2011 and 2012
    The 11th annual 50-State Medicaid budget survey from the Kaiser Family Foundation’s Commission on Medicaid and the Uninsured finds that Medicaid officials in virtually every state are enacting a variety of cost cutting measures as states’ spending for Medicaid is projected to increase 28.7 percent in fiscal year 2012 to make up for the loss of federal stimulus money.
  • CMS 9989-P: Establishment of Exchanges and Qualified Health Plans, PPACA
    This proposed rule would implement the new Affordable Insurance Exchanges, as part of the Affordable Care Act (ACA, 'Health Reform'), which will become operational by January 1, 2014. The commenting period for this regulation is open through October 31, 2011.
  • PPL 11-013
    Notification that Local Educational Agencies participating in both Local Educational Agency Medi-Cal Billing Option and School-Based Medi-Cal Administrative Activities may include SACS resource code 5640 in their SMAA invoice.
  • SMAA Manual FY 2011-2012
    Combined / Searchable Version with Bookmarks and Hyperlinks For Easier Reference
  • 42 CFR Parts 405, 424, 447, 455, 457 and 498 (CMS 6028-FC): Medicaid Integrity
    A final rule regulating additional screening requirements, application fees, temporary enrollment moratoria, payment suspensions and compliance plans for providers and suppliers participating in the Medicare, Medicaid, and Children's Health Insurance programs. This regulation implements parts of the Affordable Care Act (ACA, 'Health Reform').
  • 42 CFR 433 - State Fiscal Administration of Medical Assistance Programs
    The complete text of 42 CFR 433 which dictates state fiscal administration of medical assistance programs under CMS and DHHS.
  • PPL 10-007
    Certified Public Expenditure (CPE) Requirements for Federal Financial Participation (FFP) for CMAA: This Policy and Procedure Letter (PPL) clarifies existing requirements and additional legislation for Federal claiming for CMAA.
  • 34 CFR Part 300: IDEA Part B Regulations
    Children and youth (ages 3-21) receive special education and related services under IDEA Part B; pertinent citations: Subpart D - Evaluations, Eligibility Determination, Individualized Education Programs and Educational Placements 34 CFR 300.300 (Parental Consent) and 301 (Initial Evaluations)
  • SMAA Manual FY 2010-2011
    Combined / Searchable Version with Bookmarks and Hyperlinks For Easier Reference
  • DHCS Report to the Legislature, May 2010
    Report Period April 2009 through May 2010
  • Patient Protection and Affordable Care Act (PPACA)
    Also referred to as the Affordable Care Act (ACA) and 'Health Reform', under the PPACA: 1. most individuals will be required to have health insurance beginning in 2014, 2. individuals who do not have access to affordable employer coverage will be able to purchase coverage through a health Insurance Exchange with premium and cost-sharing credits available to some people to make coverage more affordable (small businesses will be able to purchase coverage through a separate Exchange), 3. employers will be required to pay penalties for employees who receive tax credits for health insurance through the Exchange, with exceptions for small employers, 4. new regulations will be imposed on all health plans that will prevent health insurers from denying coverage to people for any reason, including health status, and from charging higher premiums based on health status and gender, 5. Medicaid will be expanded to 133% of the federal poverty level for all individuals under age 65. Summary of legislation courtesy of Kaiser Family Foundation.
  • 2010 CMAA LGA Provider Manual
    The California County-Based Medi-Cal Administrative Activities Manual (CMAA Manual) intends to help local governmental agencies (LGAs: counties and chartered cities) participate in the CMAA program and maintain proper documentation for their claiming units. This is the original LGA provider manual, last published in 2010 prior to the development and implementation of a new time survey methodology for CMAA claiming expected to be released for FY 2012-13.
  • DHCS Report to the Legislature, March 2009
    Report period: April 2008-March 2009
  • Section 1903 of Title XIX of the Social Security Act
    Provision dictating requirements for payment to states; pertinent citations include 1903(c)
  • Section 1902 of Title XIX of the Social Security Act
    Provision dictating requirements for state plans for medial assistance; pertinent citations include: 1902(a)(11)(B), (a)(17)(B), and (a)(25)
  • American Recovery and Reinvestment Act (ARRA)
    A direct response to the economic crisis, the Recovery Act (also referred to as the 'Stimulus Package') provided $288 billion in tax cuts and benefits for millions of working families and businesses, and increased federal funds for entitlement programs, such as the federal matching assistance percentage (FMAP) used in calculating Medicaid direct billing and administrative program claims, by $224 billion. All data has been posted on Recovery.gov so the public can track the Recovery funds.
  • Children's Health Insurance Program Reauthorization Act (CHIPRA)
    The Children's Health Insurance Program Reauthorization Act of 2009 (CHIPRA or Public Law 111-3) reauthorized the Children's Health Insurance Program (CHIP) and provides financing through FY 2013.
  • OMB Circular A-133: Audits of States, Local Governments, and Non-Profit Organizations
    Office of Management and Budget (OMB) Circular A-133 sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of States, local governments, and non-profit organizations expending Federal awards.
  • Deficit Reduction Act of 2005
    The Deficit Reduction Act of 2005 (DRA) was signed into law on February 8, 2006 . This legislation affects many aspects of domestic entitlement programs, including both Medicare and Medicaid.