Georgia Association of Homes and Services for Children   

Community Centered Services
Frequently Asked Questions

Information provided is the best available at this time; all information is qualified until more and better information is provided by the Department.

What is DHR proposing to do?  - DHR is proposing to change the way that children who are in the custody of the state are provided mental and behavioral health services.  Currently, children who are in the custody of the State that need behavioral or mental health services are placed in the Level of Care System of Placement in the private sector.  Providers are currently paid a per diem based on the level of need of the child. 

The new way would be that private child placing agencies (foster care agencies) or child caring institutions (group homes) who accept the placement of state children would be paid a per diem based only on room and board.  Any behavioral or mental health services to the child would be provided by a Medicaid Provider of these services.  The Commissioner of DHR full comments can be found here.

Why is DHR implementing this change from Level of Care to another paradigm for rate reimbursement? - DHR has been instructed by the Federal Government through their Centers for Medical and Medicaid Services that they had to "unbundle" the behavioral and mental health services currently paid through Level of Care.   This "unbundling" is being done in order to comply with Federal regulations. 

When will these changes be implemented? These changes will be phased in from now to July 2007.  The plan for this change has been submitted to CMS.  DHR is confident that their proposals will be accepted because they are similar to other proposals submitted and accepted from other states. 

What should providers do in anticipation of this implementation?  Based on preliminary information at this point, providers may need to immediately begin to think about their preparedness to become a Medicaid provider of specialty services.  All providers currently under the Level of Care System are now Medicaid providers.  Some providers are not aware that DHR holds their Medicaid provider number and DHR is receiving payment under that number for the placement and treatment services provided.  The details of how providers can use their own number has not been worked out by the Department of Community Health.  Providers can also apply to be a mental health services provider supported by Medicaid.  Go here for more information.  The GAHSC is planning trainings, institutes and consultation to prepare agencies for these changes. 

What organizational changes should I anticipate? 

1. All agencies are required to be accredited in order to be a Medicaid provider.  The Council on Accreditation (COA), Joint Commission on Accreditation of Healthcare Organizations (JCAHO), Commission on Accreditation of Rehabilitation Facilities (CARF), and the Council on Quality Leadership (CQL) are recognized national accrediting bodies. 

2. All agencies will have to have licensed therapist on their staff.

3. All agencies will have to have a sophisticated billing and accounting system to manage Medicaid payments and billings.

4. All agencies will have to become a Medicaid provider.

What if I do not want to be a Medicaid Provider, can I still serve children in a residential setting?  We anticipate that any provider who does not want to be a Medicaid Provider, can still provide just room and board services to children.  Children with mental or behavioral health needs can be served by other Medicaid providers such as the Community Services Boards and other independent Medicaid providers.  Providers will be paid a per diem based on room and board.  These rates have not been determined. 

How do Specialty Psychiatric Hospitals fit into this change?  It appears that Specialty Psychiatric Hospitals which serve child with Level Six needs could be exempt from most of these changes.  Medicaid can pay a per diem for the services offered by facilities that are defined under Medicaid as Psychiatric Residential Treatment Facilities (PRTF). 

Has any other State gone through this with CMS?  Yes, over 30 states that use the Rehab Option to finance part of child welfare have been identified by CMS.  Colorado is the first to be required to make changes in their system.  Colorado has a child placement system similar to Georgia.  They were informed that they could no longer bundle rehab option services in a per diem rate.  Colorado has set July 1, 2006 as the target date for implementation of their new system.  This new system appears similar to what Georgia is proposing.