Georgia Association of Homes and Services for Children

Provider Watch - April 28, 2007 - Commission Hosts Meeting on LOC Transition

 

Level of Care Transition meeting with the Commissioner and the Director of DMHADDD

 

On April 25th, the Commissioner of DHR, B.J. Walker and the State DMHDDAD Director, Gwen Skinner, hosted a meeting with LOC providers to discuss the transition to Room and Board and Watchful Oversight with Home and Community Based Services through Medicaid.  They were presented with 34 questions that they answered at the meeting.  Other questions presented to the Staff of DHR by the providers in attendance.  The interchange of questions and responses filled in many of the unanswered questions and concerns that have been circulating for months.  The Commissioner made a commitment to providers to do all that she could do to get “this transition to Room and Board and Watchful Oversight right the first time”.  This transition from Level of Care to this new funding and practice model is to be completed by July 1. 

 

Disclaimer:  The questions below are the questions presented to the Department by providers.  The answers below are the answers that were heard by GAHSC.  DHR promised to post their answers to these questions to the internet within a week.  This report is done only as a public service to all providers of child welfare services in the State both public and private.  This report is not an official policy and practice statement by the Department of Human Resources.   As soon as their answers are posted, GAHSC will replace this report with theirs.    The latest provider information can always be found on:  http://www.gahsc.org/nm/pp/2006/ccs/ccsindex.html

 

Alphabet Soup Definitions

 

APS – Georgia’s external review organization that monitors the care that providers and the Division MHDDAD to at risk children.

C&A – Child and Adolescent

CAFAS – A standardized assessment used to measure the treatment acuity of children.

CMS – The Federal Government Centers for Medicaid and Medicare Services, the Federal watchdog organization for Medicaid services.

CORE – Designation for providers of the full continuum of services for mental and behavioral health paid for by Medicaid or Medicare.

DCH – Department of Community Health, the state agency that manages Medicaid and Medicare

DFCS – Division of Family and Children Services, of DHR

DHR – Department of Human Resources

DJJ – Department of Juvenile Justice

IMD – Institutions of Mental Diseases, a facility of 16 or more beds that have more than half their children with mental health diagnoses.

ILP – Independent Living Program, for children ages 14 to 21. 

LOC – Level of Care, funding model to draw down federal Medicaid dollars through private agencies. 

MCO – Manage Care Organization, Georgia’s health services organization that manages the dollars and services for Medicaid.

MHDDAD – The Division of Mental Health, Developmental Disabilities and Addictive Diseases.

MICP –  Multipurpose Information Consumer Profile, the billing record for each client receiving Medicaid Services

MRO – Medicaid Rehabilitation Organization, a Medicaid provider of mental health services

ORS – Office of Regulatory Services, the state regulatory agency under DHR

PRTF – Psychiatric Residential Treatment Facilities, speciality hospitals that provide Medicaid services

RBWO – Room and Board and Watchful Oversight, the new buzz word for placement services only.

TFC – Therapeutic Foster Care, high level treatment services provided through highly trained foster parents and foster homes.

TRIS – Therapeutic Residential Intervention Services, the LOC treatment residential services.

 

Questions for the Commissioner:

 

  1. Will PRTF agencies be able to have CCI facilities on the same campus?  “We can not definitely answer this.  We have had a favorable response about these concerns from CMS.  Presently, we believe that this will be possible with certain safeguards.”
  2. How long will DFCS have to place children currently in PRTFs who no longer meet medical necessity?  “  APS is doing the medical necessity determination.  The DMHDDAD acknowledges that more children than expected are being disqualified in PRTFs and work with APS and CMS is needed to resolve these concerns.  Dialogue about community placement should be ongoing with the provider and APS and no child should be removed from an agency without an appropriate plan of placement.” 
  3. What happens when no appropriate placement is identified?  “See above.”
  4. Will the state be able to use PRTF’s when no other appropriate placement is found but need that level of supervision?  “PRTFs are about the treatment of the child, not about supervision.   As long as a child needs treatment that is appropriate for a PRTF the child will receive treatment.  The “90 day limit for PRTFs” is just a rumor and not policy.
  5. What is the status of the state’s decision regarding the specific transfer of the current TRIS Medicaid provider number to the Medicaid Rehab Option number?  “  New Medicaid numbers are being assigned to providers that are approved as MRO providers.” 
  6. Is there any plan to expand MRO “specialty services”?  “No plans for expansion of these services are being discussed right now.  Later when the needs of the children and best practice dictates, these services may be expanded.”
  7. What about Therapeutic Foster Care and respite be taken out of the state plan?  TFC never has been in the Medicaid plan.  After July 1st a 3rd party administrator will manage respite.  RB&WO expenses will be billed to DFCS.  DFCS will be paying for Foster Care.  Treatment will be provided by Medicaid.  A PRTF demonstration waiver has allowed DFCS to create something like TFC for a determinant number of children. 

 

Questions for Gwen Skinner, DMHDDAD:

 

  1. What will the specific steps and time frames for transitioning children in residential settings to MRO services?  July 1st will mark the beginning of billing for MRO’s and RBWO for children in placement through DFCS and DJJ.  MRO providers are listed on www.mygcal.com .  Between now and July 1st, every child will have been staffed as to how they are going to receive services.  The Department acknowledged that this is going to be a challenge.  Private Mental Health providers can service these children if they are approved Medicaid providers. “
  2. For those providing Core services, what is the expected date we need to have the doors open to the community?  As soon as a provider is approved, they can provide services to the larger community.  All MRO providers must start providing community wide services by July 1st.  “
  3. What are the MH guidelines for the times frames for those MRO services which have gaps in time frames from one service to another?  For example, there is a big gap in individual counseling in regard to time.  There is 25-30 minutes, 45-50 minutes  and 75-80 minutes.  What happens when one has a 60 minute session?  Or a 40 minute session?  Do we round up or down?  The gap between the last two is 25 minutes.  APS indicated in the last orientation, that they did not have any guidelines for auditing for this gap and that each agency/organization should have an internal policy to indicate its billing process.  The responsibility should not be placed on each its billing process.  The responsibility should not be placed on each agency/organization to determine the correct way to bill for the service codes which have different time frames with such large gaps. -   “It is a decision internal to each agency.  There are no guidelines for this from CMS or APS.  Agencies were admonished to be consistent.”
  4. Which agencies have made application to provide core/specialty services in each region?  See www.mgcal.com . 
  5. Does Gwen Skinner think there are enough providers to meet the need come July 1st?  “Yes.”
  6. Are there regions Gwen Skinner would like additional providers to pursue this option.  Yes.  The Southern Regions of Georgia are in the most need.”
  7. The Institutions of Mental Diseases issue is not resolved as of last Friday, for those effected, what shall we expect?  We are currently expending much energy and dollars to be prepared to be a Medicaid provider.  “CMS has not spoken officially on this issue.  CMS has told us that they believe Georgia has put in place safeguards to assure that the IMD issues will not disqualify congregate care providers of 16 or more kids from Medicaid eligibility for those children.” 
  8. Is APS ready to process MICP’s on all kids currently in placement before July 1 so we are ready to go? “Submission can not occur before July 1st.  APS is ready to process them.  Providers will need a Medicaid number prior to submission.  Providers can profile them before July 1 for processing after July 1. ” 
  9. Is CAFAS still the criteria used to judge treatment need?  Will the adjustments to lower the scores indicated at Forsysth LOC meeting be in place by July?  The current scores are not in line with Kay Hodges’ guidelines. “CAFAS still will be used.” 
  10. If all foster care children are assigned to MCO’s and they have no benefits available/do not meet medical necessity, what other resources will be available to serve?  “DFCS children are not in MCO’s.  DFCS children will be served by the DMHDDAD and paid for by Medicaid.  No MCO will be involved.”
  11. When will youth in non PRTF’s begin to be reviewed by APS?  “APS will only monitor MRO provider services and not placement services.”
  12. Still no Medicaid numbers issued from Community Health, what is the status?  “DCH is working on issuing Medicaid numbers.”
  13. At Forsyth, it was indicated that staff with Masters were Mental Health Professionals.  Provider Manual notes Masters with internship.  What is the acceptable practice and which guidelines are being followed in practice in APS audits?  “Always use the MHDDAD provider manual as a guideline.”
  14. The provider manual allows a youth (state custody) who turns 18 and is receiving C&A to remain in C&A services rather than having to move to adult services.  DFCS typically converts youth (referred to ILP) to adult Medicaid.  Can that youth remain in C&A to receive CORE services from the C&A provider for consistency rather than being converted simply due to age?  At age 18, a child will be evaluated to determine what are the appropriate services and service delivery model for the child/adult.  The child/adult could continue to receive CORE services from a C&A provider.”
  15. Status of Masters Addiction Counselors within the MH guidelines for staff qualifying as substance abuse qualified?  “Always follow the requirements of the DMHDDAD staffing requirement as found in the provider manual.”
  16. When we get to July 1 and APS determines that large numbers of youth currently in level 6 placements do not meet “medical need” for PRTF services, what is going to happen to these youth?”  Appropriate services will be provided to each and every child and with proper planning no “large numbers” should be identified.”
  17. Is it possible that every one of these youth will be discharged on July 1?  “NO.”
  18. Where would they go and who could care for them?   “See above.”
  19. What about level 6 sex offenders that do not meet APS criteria for PRTF?  What services will be provided for these youth and will they remain in current placements to complete treatment?  “DFCS and DJJ will be responsible for placement services.  Some CCI’s have the capacity to serve these type of youth.” 
  20. In the past, I have heard mention that DHR had planned to set aside some money to assist with these type of situations both as they relate to smooth transitions, chronically ill youth and sex offenders.  Is there such a reserve and if so when will we know how to access it?  There is no reserve.  DMHADDD is looking at some options that may address these children. “
  21. When will APS begin to review level 4 and 5 facilities?  “APS only will be reviewing MICP’s.  “

 

DCH Questions: 

  1. How reliable is ACS now that they have lost the PeachCare disk?  “They will have to respond to this question.”
  2. ACS is not providing information from their personnel about how soon they can set us up and process payments?  The sessions for training that LOC providers were asked to sign up for are limited and they are not prepared to provide additional sessions according to APS staff.  Currently there are no sessions available for training until June 2007 or later.  “No information currently about this.”

 

ORS Questions: 

  1. Need clarification from ORS for licensing for substance abuse for CORE clients.  The regulations are very confusing as to requirements.  ORS staff, when asked the question have indicated to determine by number of hours provided.  How do you determine need based on projected hours and what are the designations?  “The regulations will determine what rules apply.”
  2. ORS currently requires (by practice) charts in the Therapeutic Group Homes.  Will the CORE provider chart remain in the homes or be maintained at the Central Office and have the practice required by ORS changed?  “Proposed new CPA and CCI regulations are being drafted.   Files will continue to be required.” 
  3. Will a shadow file be required at a secondary location once the primary location is determined?  (The question has been addressed at LOC transition meetings but not answered.)  Resident files should be at the primary location.  Personnel files should be accessible even if at a main office.”
  4. When will ORS guidelines for CPAs and CCIs be available with treatment language removed and practice changed? 
    “Draft rules are currently on the web.” 

 

Other Statements by the Department in response to Questions from the Audience:

 

  1. Will providers be required to do the 160 hours of training as spoken about at the provider meeting on March 25th?  Only case manager staff from CPA would be under this requirement by Kenny A.  No determination has been made about this.  This would only then apply directly to Fulton and Dekalb county providers.  “
  2. Who will determine placement of the child in parental custody?  “DFCS will still be responsible for RBWO for children in parental custody. “
  3. Who will authorize wrap around services?  “Case managers will authorize services for wrap around services.  What was formally under TRIS will now be under the Provider Support Unit.  Some of these services could be done under IFY.”
  4. “Premiums lists will be developed.  Letters will be going out to providers about the services that they provide no later than May 1.  “
  5. “Sharon Doughtery is now the Director of the Office of Regulatory Services.”
  6. “DHR anticipates that 40% of the providers will qualify preminum services rates and 60% will only qualify for a base rate.”
  7. “Some special categories will be created as the need for services are determined such as for the medically fragile.”
  8. “Providers will have a draft contract by June 1 and every provider will have a contract by July 1, 2007.”
  9. “Providers will have a letter of minimum commitment about their rate(s) and the number of children that each rate will cover by May 1st.” 

 

GAHSC Home Page  Referral Central  Index  Contacting Us

Site contents are Copyright © 2002,  Georgia Association of Homes and Services for Children
Updated by Normer Adams on 05/01/07 10:21 AM -0400          .