Senior Operations and Management Consultant MTM Services · Jan 2017—Dec 2018 Demonstration Phase...
Transcript of Senior Operations and Management Consultant MTM Services · Jan 2017—Dec 2018 Demonstration Phase...
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Speaker NameTitle
Organization
CCBHC Masters Class: Back Office Management
Michael D. Flora, MBA, M.A.Ed., LCPCSenior Operations and Management Consultant
MTM Services
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Your Faculty for Today
Michael Flora
MTM Services
David Lloyd
MTM Services
Rebecca C. Farley
National Council for Behavioral Health
Steven M Kohler
McBee and Associates
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Becoming a CCBHC might seem like a daunting task with all of the requirements necessary for implementation; never fear, the National Council experts are here to help! We will go through the back office management check list to make sure you have the right structures in place to ensure success.
After this session, your organization will be ready to manage internal utilization management, credentialing, costing reporting, and other processes that are keeping you up at night.
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Source: http://www.merriam-webster.com
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Learning Objectives
• Identify the key elements needed to ensure the right
structures in your back office are in place to guarantee
success as a CCBHC.
• Prepare your workforce infrastructure to handle the new
requirements, paper work, and processes that come
along with becoming a CCBHC.
• Address the contract needs for setting up partnerships
with DCOs, FQHCs, and other community or regional
services.
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• Focus on organizational Revenue Cycle
management needs and back office
infrastructure to support pre-service, point of
service an post service needs to enhance
performance
• Develop strategies to address DCO
contracts, Compliance and Billing
Learning Objectives
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BH Core
Competencies
Recovery/Resilience
GovernanceLeadership
Access &Intake
ServiceScheduling
Billing &Financial
ManagementCompliance
ManagementInformation
OutreachMarketing
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CCBHC Overview
Rebecca Farley
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It Passed!The largest federal investment in mental health and addiction treatment in a
generation.
Representatives
Leonard Lance and
Doris Matsui
Senators Roy Blunt and Debbie
Stabenow
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The Vision
• Improve overall health by bolstering community-based
mental health and addiction treatment
• Advance behavioral health care to the next stage of
integration with physical health care
• Assimilate and utilize evidence-based practices on a
more consistent basis
Certified Community Behavioral Health Clinics
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What makes CCBHCs so different?
• New provider type in Medicaid
• Distinct service delivery model:
trauma-informed recovery outside
the traditional four walls
• New prospective payment system
(PPS) methodology
• Requirement to contract with
other organizations
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24 States Selected for Planning Grants
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Timeline
Jan 2017—Dec 2018
Demonstration Phase
Oct 2015—Oct 2016
Planning Phase
May-Aug 5, 2015
Prepare Planning Grant Applications
SAMHSA has granted a 6-month extension for
states that are selected to participate in the
demonstration
• The demonstration start date may be
between Jan. 1 and June 30, 2017
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CCBHC Scope of Services
Must be delivered directly by CCBHC
Delivered by CCBHC or a Designated Collaborating
Organization (DCO)
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CCBHC Payment
• Establishment of a Prospective Payment
System
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Breaking through old limitations…
Think creatively!
? In-home services for
newly placed foster
youth
? Post-booking
assessment in jails
? Outreach to homeless
populations
Services are not confined to delivery within the
4 walls of a clinic
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Do I have to be a CCBHC?
• DCOs augment or fill gaps in CCBHCs’ service array…
No! You could
become a…
Designated Collaborating
Organization
• …And can benefit from CCBHCs’ enhanced reimbursement
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Decisions Ahead
• Is the CCBHC model a good fit for my organization?
• What changes to our service array are needed?
• What workforce education/training do we need to do?
• What capital investments do we need to make?
• What back office changes do we need to implement
to make all of this work?
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NatCon16: CCBHC Track
• Monday:
– 10:45: CCBHCs 101
– 12:00: Becoming Best Friends: CCBHCs and DCOs
– 3:00: Getting Paid as a CCBHC: Cost Reporting
Principles
• Tuesday:
– 10:00: Quality Reporting and CCBHCs
– 10:00: The Role of CCBHCs in Monitoring &
Managing Chronic Illness
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What About CCBHC?
Alaska Iowa Missouri Oklahoma
California Kentucky Nevada Oregon
Colorado Maryland New Mexico Pennsylvania
Connecticut Massachusetts New York Rhode Island
Illinois Michigan New Jersey Texas
Indiana Minnesota North Carolina Virginia
•Requires participating states to develop a Prospective Payment
System (PPS) for reimbursing Certified Behavioral Health Clinics for
required services provided by these entities. Participating states will
receive an enhanced Medicaid match rate for all of the required services
provided by the Certified Community Behavioral Health Clinics.
•On October 19th SAMHSA confirmed the following states have received
the one year CCBHC planning grant:
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Its no Longer Business as Usual
How does CCBHC change the back
Office and Revenue Cycle Work
Flow and processes?
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Identify the key elements needed to
ensure the right structures in your
back office are in place to guarantee
success as a CCBHC.
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CCBHC
Program Requirements
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“We are trying to create a new provider type, something that has never existed before!”
Chuck IngogliaSr. Vice President, Public Policy and Practice Improvement
National Council for Behavioral Health
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Defining the New Paradigm
CCBHC• Non-Four Walls
• Trauma-Informed Care Model
• PPS Rate Setting Support
Requirements
• PPS-2--Another Level of
Complication
• CCBHC Service Delivery
Operational Requirements
• Compliance with CCBHC
Certification Requirements
Current
Business
Practices
• Payer Verification
• Update
Demographics
• Credentialing
• UM/UR
• Co-Pays
• Pre-service
• Point of Service
• Post Service
• AR Management
Combined Areas
of Focus• Know the State Medicaid
Rules
• Understand How Your
Relationships Translate into
Costs
• DCO Management
• Getting Technology Right
• Fee Scale
• Telemedicine
• Clinical Quality Assurance
• Corporate Practice of
Medicine
• Decision-Making and
Change Management
Support Assessment
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Objectives for the Initiative:
The statute at subsection 223 (d)(4)(A) under which the program is authorized is explicit that preference must be given to selecting demonstration programs where participating CCBHCs will achieve at least one of the following:
• Provide the most complete scope of services as described in the Criteria to individuals eligible for medical assistance under the state Medicaid program; OR
• Improve availability of, access to, and participation in, services described in subsection Criteria to individuals eligible for medical assistance under the state Medicaid program; OR
• Improve availability of, access to, and participation in assisted outpatient mental health treatment in the state; OR
• Demonstrate the potential to expand available mental health services in a demonstration area and increase the quality of such services without increasing net federal spending.
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What is required of the state?
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The statute at subsection 223 (d)(4)(A) under
which the program is authorized is explicit that
preference must be given to selecting
demonstration programs where participating
CCBHCs will achieve at least one of the
following:
Statute under subsection 223 (d)(4)(A)
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CCBHC
Core Requirements
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CBHC Core Requirements
Program Requirement 1: Staffing (“Staffing requirements, including criteria that staff have diverse disciplinary backgrounds, have necessary State-required license and accreditation, and are culturally and linguistically trained to serve the needs of the clinic’s patient population.”)
Program Requirement 2: Availability and Accessibility of Services (“Availability and accessibility of services, including: crisis management services that are available and accessible 24 hours a day, the use of a sliding scale for payment, and no rejection for services or limiting of services on the basis of a patient’s ability to pay or a place of residence.”)
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CCBHC Core RequirementsProgram Requirement 3: Care Coordination (“Care coordination, including requirements to coordinate care across settings and providers to ensure seamless transitions for patients across the full spectrum of health services, including acute, chronic, and behavioral health needs. Care coordination requirements shall include partnerships or formal contracts with the following:
(i) Federally-qualified health clinics (and as applicable, rural health clinics) to provide Federally-qualified health clinic services (and as applicable, rural health clinic services) to the extent such services are not provided directly through the certified community behavioral health clinic. (ii) Inpatient psychiatric facilities and substance use detoxification, post-detoxification step-down services, and residential programs. (iii) Other community or regional services, supports, and providers, including schools, child welfare agencies, and juvenile and criminal justice agencies and facilities, Indian Health Service youth regional treatment clinics, State licensed and nationally accredited child placing agencies for therapeutic foster care service, and other social and human services. (iv) Department of Veterans Affairs medical clinics, independent outpatient clinics, drop-in clinics, and other facilities of the Department as defined in section 1801 of title 38, United States Code. (v) Inpatient acute care hospitals and hospital outpatient clinics.”)
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CCBHC Core Requirements
Program Requirement 4: Scope of Services (“Provision (in a manner reflecting person-centered care) of the following services which, if not available directly through the certified community behavioral health clinic, are provided or referred through formal relationships with other providers: (i) Crisis mental health services, including 24-hour mobile crisis teams, emergency crisis intervention services, and crisis stabilization. (ii) Screening, assessment, and diagnosis, including risk assessment. (iii) Patient-centered treatment planning or similar processes, including risk assessment and crisis planning. (iv) Outpatient mental health and substance use services. (v) Outpatient clinic primary care screening and monitoring of key health indicators and health risk. (vi) Targeted case management. (vii) Psychiatric rehabilitation services. (viii) Peer support and counselor services and family supports. (ix) Intensive, community-based mental health care for members of the armed forces and veterans, particularly those members and veterans located in rural areas, provided the care is consistent with minimum clinical mental health guidelines promulgated by the Veterans Health Administration, including clinical guidelines contained in the Uniform Mental Health Services Handbook of such Administration.”)
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CCBHC Core Requirements
Program Requirement 5: Quality and Other Reporting (“Reporting of encounter data, clinical outcomes data, quality data, and such other data as the Secretary requires.” )
** Note - When partnering with DCO’s, you will have to be able to collect and show the services that they have delivered to you consumers as well, so communication between agencies and their systems will become of paramount importance.
Electronic systems that interface, and/or the ability to collect information from teams not in electronic systems will be a large focus here.
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CCBHC Core Requirements
Program Requirement 6: Organizational Authority, Governance and Accreditation (“Criteria that a clinic be a nonprofit or part of a local government behavioral health authority or operated under the authority of the Indian Health Service, an Indian Tribe, or Tribal organization pursuant to a contract, grant, cooperative agreement, or compact with the Indian Health Service pursuant to the Indian Self-Determination Act [25 U.S.C. 450 et seq.], or an urban Indian organization pursuant to a grant or contract with the Indian Health Service under title V of the Indian Health Care Improvement Act [25 U.S.C. 1601 et seq].”)
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The Data to Drive our Decisions Will Come From:
1. CCBHC Readiness Assessments2. Community Needs Assessment for each CCBHC Clinic
geographic area3. Claims data4. Cost Data5. Persons Served6. Events/Encounter Data7. State level Strengths, Weaknesses, Opportunities and
Threats (SWOT) Analysis8. Other measurement tools as/if deemed necessary.
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CCBHC Prospective Payment System
Under the CCBHC designation we
must be able to understand the PPS
while at the same time maintain our
current and future payers
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New Integrated CCBHC Certification Criteria
Feasibility and Readiness Tool (I-CCFRT)
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Source: New Integrated CCBHC Certification Criteria Feasibility and Readiness Tool (I-CCFRT)
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Assessing your Readiness…
• Does your clinic have the capacity to run
Medicaid population PPS rate scenarios to
determine the financial consequence for the
specific PPS rate established for your clinic?
• Does your clinic have the capacity to develop
internal Service Delivery guidelines and
protocols as well as continuously monitor
compliance with the guidelines to support the
PPS rate model?
Source: New Integrated CCBHC Certification Criteria Feasibility and Readiness Tool (I-CCFRT)
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Assessing your Readiness….
• Does your clinic have the capacity to run
Medicaid population utilization trends tied to
costs that will support the PPS rate setting?
• Does your clinic have the capacity to
establish the cost per delivered hour for each
service that you have provided and for
services that you will need to provide in the
new CCBHC non-four walls service delivery
system? .Source: New Integrated CCBHC Certification Criteria Feasibility and Readiness Tool (I-CCFRT)
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• CC PPS-1 Rate: Designated as Certified Clinic Prospective Payment System (CC PPS-1), the first option is a FQHC-like PPS that provides reimbursement of cost on a daily basis (as does the current PPS used for FQHC services reimbursement) with the addition of a state option to provide quality bonus payments (QBPs) to CCBHCs that meet defined quality metrics. QBPs are not a requirement and should not be seen as changing the underlying PPS system. It would only be there as a possibility for additional bonus payments and is at the option of the state.
CC PPS-1
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• The CC PPS-1 rate is based on total annual allowable CCBHC costs divided by the total annual number of CCBHC daily visits and results in a uniform payment amount per day, regardless of the intensity of services or individual needs of clinic users on that day.
• In developing the rates, states may include estimated costs related to services or items not incurred during the planning phase but projected to be incurred during the demonstration.
• States also should include in CC PPS-1 the cost of care associated with Designated Collaborating Organizations (DCOs). A DCO is an entity that is not under the direct supervision of the CCBHC but is engaged in a formal relationship with the CCBHC and delivers services under the same requirements as the CCBHC. Payment for DCO services is included within the scope of the CCBHC PPS, and DCO encounters will be treated as CCBHC encounters for purposes of the PPS. Services of a DCO are distinct from referred services in that the CCBHC is not financially and clinically responsible for referred services.
Section 2.1: Certified Clinic PPS (CC PPS-1)
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• The CC PPS-1 is a cost-based, per clinic rate that applies uniformly to all CCBHC services rendered by a certified clinic, including those delivered by qualified satellite facilities established prior to April 1, 2014.
• It pays CCBHCs a daily rate that is a fixed amount for all CCBHC services provided on any given day to a Medicaid beneficiary.
• In demonstration year one (DY1), the state will use cost and visit data from the demonstration planning phase, updated by the Medicare Economic Index (MEI) to create the rate for DY1.
• The DY1 rate will be updated again for DY2 by the MEI or by rebasing of the PPS rate.
• CMS requires the use of one full year of cost data and visit data, unless a state can justify the use of a shorter period of time.
Section 2.1: Certified Clinic PPS (CC PPS-1)
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• CC PPS-2 Alternative uses a monthly unit of
payment, provides for:
– Required QBPs – CC PPS-2 methodology, the state
is required to incorporate quality bonus payments as
part of the payment made using CC PPS-2.
– Rates that vary, depending on the populations
served by the certified clinic (e.g. patients who are
seriously mentally ill and those with substance use
disorders).
CC PPS-2 Rate
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• The CC PPS-2 is a cost-based, per clinic monthly rate that applies uniformly to all CCBHC services rendered by a certified clinic, including all qualifying sites of the certified clinic established prior to April 1, 2014.
• CC PPS-2 includes these required elements:
• a monthly rate to reimburse the CCBHC for services,
• separate monthly PPS rates to reimburse CCBHCs for higher costs associated with providing all services needed to meet the needs of clinic users with certain conditions,
• cost updates from the demonstration planning period to DY1 using the MEI and from DY1 to DY2 using the MEI or by rebasing,
• outlier payments made in addition to PPS for participant costs in excess of a threshold defined by the state, and
• QBP made in addition to the PPS rates.
Section 2.2: CC PPS Alternative (CC PPS-2)
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• A CCBHC receives the monthly rate whenever at least one CCBHC service is delivered during the month to a Medicaid beneficiary by the CCBHC; states may pay this rate only after a CCBHC service has been delivered.
• Under this methodology states will develop a standard monthly rate and also will develop monthly PPS rates that vary according to users’ clinical conditions. For example, states could set different rates for adults with serious mental illness and co-occurring substance use disorders and children and adolescents with serious emotional disturbance who require higher intensity services. The state has flexibility in determining how PPS rates could vary. An outlier payment is part of the CC PPS-2 and reimburses clinics for costs above a state-defined threshold. This helps to ensure that clinics are able to meet the cost of serving their users. Finally, the CC PPS-2 rate methodology requires the state to select quality measure(s) as permitted and make bonus payments to incentivize improvements in quality of care.
Section 2.2: CC PPS Alternative (CC PPS-2)
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• States should include in CC PPS-2 the cost of care associated with DCOs. A DCO is an entity that is not under the direct supervision of the CCBHC but is engaged in a formal relationship with the CCBHC and delivers services under the same requirements as the CCBHC. Payment for DCO services is included within the scope of the CCBHC PPS, and DCO encounters will be treated as CCBHC encounters for purposes of the PPS. Services of a DCO are distinct from referred services in that the CCBHC is not financially and clinically responsible for referred services.
Section 2.2: CC PPS Alternative (CC PPS-2)
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excluding clinic users with certain conditions
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• Under the CC PPS‐2 method, a state must
offer a QBP to any CCBHC that
demonstrates it has achieved all of the six
required quality measures as shown in Table
3 of the PPS guidance.
• The state can make a QBP on the basis of
additional measures provided in Table 3 of
the PPS guidance and may propose its own
quality measures for CMS approval.
Section 2.2.b CC PPS‐2 Quality Bonus
Payments
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Quality Measures
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PPS Rate and Back Office Functions
• PPS will be the same rate paid for any
qualifying CCBHC services provided.
• States will determine what qualifies as a
service and what level of provider(s) is
eligible to bill for that service.
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PPS Rate and Back Office Functions
• Sites will need to be very clear about what
their state counts as a visit and who can
provide the service so that they can make
sure the correct staff is providing the service
• Sites will still need to have a sense of their
costs so that they can continue to ensure that
the service provided is covered by the
payment rate (may want to have productivity
targets/duration targets for practitioners)
•
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In the CCBHC Environment
• Your current third party and other contracts
will still require your attention
• Depending on if your PPS-1 or PPS-2 you
will need to plan for cash flows and service
utilization
• You will need to develop payment structures
and UM/UR for your DCOs
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States have two options for incorporating
PPS rates into Medicaid Managed Care
Programs.
• Option 1: Incorporate cost of the PPS rates
into the Medicaid capitation rates and require
Managed Care Entities to pay PPS rates to
CCBHCs.
• Managed Care Entities must modify their
contracts with CCBHCs to reflect the CCBHC
scope of services and substitute PPS rates in
place of existing compensation levels.
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Source: Susannah Gopalan and Adam Falcone: Feldesman Tucker Leifer Fidell LLP
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States have two options for incorporating
PPS rates into Medicaid Managed Care
Programs.
• Option 2: Pay supplemental “wraparound”
payments to what CCBHC’s receive from
Managed Care Entities so that combined
payments equal PPS rates.
• Contracts with Managed Care Entities would
require that these entities pay rates to the
CCBHC equal to what other providers would
receive for similar services.
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Source: Susannah Gopalan and Adam Falcone: Feldesman Tucker Leifer Fidell LLP
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States have two options for incorporating
PPS rates into Medicaid Managed Care
Programs.
• The state makes supplemental payments and
performs and annual reconciliation to ensure
that total payments to CCBHCs are equal to
the reimbursement under the CCBHC PPS.
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Solutions
• Some solutions are driven by CMS –
– CMS recommends that states consider
assigning all CCBHCs to one managed care
entity that is capable of collecting all data
pertinent to demonstration payment.
– They further recommend that each state’s
contract with a Managed Care Entity must
contain requirements for CCBHC quality
reporting and encounter data.
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What about Managed Care?
• The managed care interaction may depend
on how the state is structuring the PPS
payment with the managed care plans.
– If the state is building the PPS rate into the
managed care rates/contract, then expect
increased scrutiny.
– If however, the state is providing a wrap
around payment directly to the CCBHC, then I
there may be delays in payment from state
government of up to a year or two of this wrap
around payment.
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CCBHC Revenue Cycle Management
• A greater understanding of current and future cash flows and management of billing practices will be needed in the new environment– How long is your billing process?
• Are you billing weekly?
• Can you process third party claims daily?
– What is your percent of denials?
– What is your performance standard on reconciliation of billing errors?
– What work flows and billing structures will need to be in place for your DCOs
– What percent of co-pays and self pay amounts are you collecting daily
• Do you establish a daily collection figure for your front desk?
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Revenue Cycle Management
PRE-SERVICE
Admission Eligibility
Pre-Service Audit
Authorization
Verification
Open to Schedule
POINT OF SERVICE
Co-Pay Collections
Treatment
Post Session Scheduling
Post Service Audit
POST SERVICE
Billing
Denial Management
Account Receivable Management
Cash Posting
Consumer Follow-Up
Key Performance Indicators
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Where are the Revenue Cycle
Impacts?
• Reimbursement reductions
• Increased compliance risk management
• Technological efficiencies
• Compliance program effectiveness
• Quality of care
• New and expanded payment methodologies
• Insurance expansion and availability
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Challenges to the Revenue Cycle
• Effective, Efficient Operations Will Help to
Minimize the Impacts of Health Care Reform
– e.g. compliance, reduced rates, outcomes
focused, integration, and complicated
Medicare and Medicaid rules.
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Processes than Impact the Revenue
Cycle• Referral
• Authorization Process
• Scheduling
• Encounter/Documentation
• Charge Capture
• Billing
• Follow-up Functions
• Cash Posting
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Revenue Cycle – Payer Awareness
• Who are your payers now?
• Who will be your payers moving forward?
• What will the payer requirements be?
• Billing
• Timely Filing
• Modifiers
• Codes etc.
• Documentation standards
• Any other issues that may have an impact?
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Revenue Cycle Solutions-
Referrals
• Expect a SIGNIFICANT increase in demand/referrals
when you increase access to care
• Higher deductible plans will become more common and
may impact consumers in your organization
• Understand the impact of PPS on your revenue cycle
• Providers must gather accurate demographic and payer
information at this point in order to anticipate potential
problem areas
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Revenue Cycle Solutions-
Referrals
Solutions:• Analyze staffing levels and capabilities now to determine their
ability to complete tasks not only with an increase in referrals but
as it stands today
– What staffing will be needed under the CCBHC?• UM/UR
• Compliance
• RCM
• Organizations with numerous satellites may want to consider
consolidating these functions to one centralized function
• Develop new policies and procedures
• Train staff on new processes
• Education of consumers will be critical at this point
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Revenue Cycle Solutions-
Authorizations
• Providers should expect that a greater need
to manage UM/UR under CCBHC
• Re-authorizations may be difficult to obtain
– Review DCO issues related to authorization
• Medical necessity will be questioned
• Retro-active authorizations will become less
common
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Revenue Cycle Solutions-
Authorizations
Solutions• Analyze staffing capabilities today
• Plan and train
• Staff handling the authorization process will need to clearly
communicate consumer needs and medical necessity.
• Staff will need to understand individual payer expectations and
timelines for authorizations and re-authorizations
• Organizations with numerous satellites may want to consider
consolidating these functions to one centralized function
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Revenue Cycle Solutions-
Authorizations
COMMUNICATION BETWEEN CLINICAL AND
COMPLIANCE STAFF WILL BE MORE
CRITICAL THAN EVER
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Revenue Cycle Solutions-
Scheduling
• CCBHC will result in a greater demand for staff time– Care Coordination
– Compliance
– RCM
• Address back office needs of CCBHC
• Schedulers will need access to the most up to-date
technology in order get consumers scheduled
• Technology will need to effectively match the
insurance plan to the available authorized clinical
staff for that plan
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Revenue Cycle Solutions-
Scheduling
Solutions
• Put technology in place that makes matching
plan to clinical staff seamless
• Educate staff
• Review UM/UR and DCO needs
• Centralize functions
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Revenue Cycle Solutions-
Encounter and Documentation
• INCREASED COMPLAINCE on Claiming
• Billing (back and front office) staff will need to
clearly understand new payer requirements
for documentation and coding of the
encounter
• Reduced timely filing will require that staff
document efficiently
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Revenue Cycle Solutions-
Encounter and Documentation
• Staffing Consideration
• Do you need to increase clinical and support
staff to handle increase in service and back
office requirements and where will they come
from?????
• Educate clinical staff on documentation,
coding and billing requirements of each
individual payer and those under CCBHC
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Encounters
• Billable Staff
• Work Flow
• Manage costs for Care Coordination?
• Billable vs. Non-Billable
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Revenue Cycle Solutions- Charge
Capture
• Effectively implementing systems and
processes related to the encounter and
documentation will increase efficiencies in the
charge capture process
• Example: Same day access and
collaborative documentation can result in
same day charge capture.
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Revenue Cycle Solutions- Billing
• Numerous new plans will be in place for
consumers in your care
• Understand the CCBHC core requirements
and impact on RCM/Back Office
• New billing rules will be in effect
• Review denial rates and filing times
• Review your billing and denial codes
• Expect higher co-pays and deductibles
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Revenue Cycle Solutions- Billing
Critical Consideration:
• How will you collect and account for the
expected increase in copays and deductibles
• Front desk/receptions staff?
• Direct care staff?
• Check-out?
• Billing statement?
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Revenue Cycle Solutions- Billing
Solutions:
• Develop Policies and Procedures
• Implement technology or processes that focus
on communication between revenue cycle staff
and clinical staff
• Clearly communicate to consumers payment
expectations
• Educate…Educate…Educate
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Revenue Cycle Solutions-Follow-up
• Expect a significant increase in pended or
denied claims…..so plan for the impact on cash
flow
Solutions
• IMPROVE FRONT END PROCESSES
• Technology!
• Consider moving staff that had been previously
involved in the billing process to the front end of
the revenue cycle
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Revenue Cycle Solutions-
Summary• Significantly more covered lives ( including those of your
DCOs)
• Increase in co-payments and deductibles
• Referral and authorization process will be critical
• Potential significant changes to documentation, coding
and billing of services
• Timely filing reductions
• Increase in denied and pended claims
• Cash flow will be impacted
• TECHNOLOGY AND EDUCATION!!!!
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Compliance Program Solutions
• Baseline analysis to determine where problems
are today
• Monitor constantly including medical necessity
reviews
• Ensure clinical staff are trained on changes that
will impact service delivery and documentation
• Monitor denial rates and referral rates to other
providers
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Revenue Cycle Management in
Accessing Third Party Markets:
• Challenge with timely access to treatment to support third party payer referral requirements
• Challenge with Community Awareness and Branding strategies to increase capacity
• Inconsistent Revenue Cycle Management procedures that enhance timely collections
• Inconsistent message to the community
• Understanding of the target markets in our communities
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Identifying RCM Preservice needs for
the CCBHC
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Revenue Cycle Management
PRE-SERVICE
Admission Eligibility
Pre-Service Audit
Authorization
Verification
Open to Schedule
POINT OF SERVICE
Co-Pay Collections
Treatment
Post Session Scheduling
Post Service Audit
POST SERVICE
Billing
Denial Management
Account Receivable Management
Cash Posting
Consumer Follow-Up
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Pre-Service
1. Contract and Enrollment Management
2. Patient Scheduling
3. Medical Necessity
4. Eligibility/Benefits Management
5. Registration
6. Pre-Service Audit
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• Develop internal protocols for all Support
team members regarding Contract and
Enrollment Management
• Anchor KPIs and Protocols in Job
Descriptions
Contract and Enrollment Management
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• Assure that all consumers have the
appropriate authorizations, updated treatment
plans and that services scheduled are
ordered on the Treatment Plan PRIOR to
services being scheduled.
• If not Ordered, Assessed, Authorized or
Medically Necessary---DO NOT SCHEDULE
Patient Scheduling
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• Develop Protocols for Client Eligibility and
Benefits management
• Review Third Party Administration to assist
with this back office function
– TriZetto
– Phreesia
Eligibility/Benefits Management
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http://www.trizetto.com/
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http://www.phreesia.com/
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• Develop Protocols and KPIs for Client
Registration into the state or appropriate
payer portals.
• Example: All new consumer will be registered
same day of service 100% of the time
Registration
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Gather financial intake data
• a. Definition: A financial intake package (annual, updates, as status
changes, or as required by program) will be completed on all individuals
requesting services with the center.
• b. Standard: Financial intake paperwork will be entered by support staff into
CMHC/CIS prior to or on the date of clinical intake.
• c. Source: Monthly audit of financial assessments.
• d. Compliance Rating: 100% of these entries made prior to clinical intake
=compliant. Less than 100% = non-compliant.
• e. Solution Plan: Development note and retraining for first non-compliant
rating. A Written Warning and retraining will be offered following the
second consecutive non-compliant period and Separation from employment
upon the third consecutive non-compliant period.
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Pre-Service confirmation/reminder calls
• During the confirmation call the Customer
Service Representative (CSR) not only
confirms the appointment but also confirms
outstanding balance and co-pay as needed.
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• Develop Protocols to
review all services at
least 72 hours prior to
services being rendered
• For Open Access to
care-develop protocols
for Same day review of
eligibility and consumer
fee determination
Pre-Service Audit
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• Most health insurance policies cover behavioral health and substance abuse services
to some extent. IF YOU HAVE HEALTH INSURANCE, INCLUDING MEDICARE OR
MEDICAID, IT IS IMPORTANT THAT YOU GIVE US THIS INFORMATION RIGHT
AWAY. We will bill your insurance company directly so that they can pay us directly.
Should your insurance company pay us for what you have already paid, we will credit
your account or give you a refund. Your insurance company is billed our full fee. You
are responsible for any deductibles, co-pays, and the balance that is not covered by
your insurance company. Any deductibles and co-pays are not eligible for a
sliding fee adjustment. If your balance after insurance payments reaches $300,
you will be required to make a payment to lower the balance below $300 or
your next appointment will not be scheduled.
• If this is your first visit , we will attempt to verify insurance and co –pay
amounts at the time of service , a minimum fee of $XX.00 is required at the
point of service. You are responsible for any amount of your care not covered
by your insurance carrier.
Health Insurance/Benefit Coverage
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• If necessary, an Extended Payment Plan may
be arranged. If this approach will assist you
in paying your bill, please arrange to meet
with our Client Accounts staff. Should your
financial circumstances change, we reserve
the right to renew and revise your extended
payment plan at any time.
Extended Payment Plan
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• If your financial circumstances are such that
paying the full fee is impossible, you may be
eligible for a Sliding Fee, which will allow
payment at less than the full fee rate. If this
approach seems necessary for you, please
discuss it with our Client Accounts staff. If
you are put on a sliding fee schedule,
there is a discount applied to your fee if
you pay at the time of service.
Sliding Fee
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Assessing your Readiness…
• Is your clinic’s Back Office staff effective in
managing a CCBHC including establishing a
sliding fee scale payment model for non-
Medicaid clients?
Source: New Integrated CCBHC Certification Criteria Feasibility and Readiness Tool (I-CCFRT)
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CCBHC Financial and Cost Expectations
• Cost of services
• Fee Schedule
• Written Policy and Procedures on availability
and accessibility
• “No rejection for services or limiting of
services on the basis of a patient’s ability
to pay or a place of residence.”
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So in what way will you….
• Monitor this to ensure viability?
• Are there any additional sources of revenue
for indigent care?
• Can you make a case to the state for federal
block grant dollars to pay for indigent care?
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Sliding Fee ScaleCCBHCs will be required to have a sliding fee
schedule and to make this very publicly available.
You will need to have a process for assessing
everyone in regards to this, uninsured and insured
as well.
Even if person has private insurance that does not
cover CCBHC services, they are still required to
provide them and in this instance would want to
use sliding fee schedule to recover whatever they
can from the cost
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FEE Policy
Family Size
from to from to from to from to from to from to
1 $0 $11,770 $11,771 $16,243 $16,244 $17,655 $17,656 $23,540 $23,541 $40,607 $40,608 $35,310 $35,311 $64,970
2 $0 $15,930 $15,931 $15,932 $15,933 $23,895 $23,896 $31,860 $31,861 $39,830 $39,831 $47,790 $47,791 $63,728
3 $0 $20,090 $20,091 $20,092 $20,093 $30,135 $30,136 $40,180 $40,181 $50,230 $50,231 $60,270 $60,271 $80,368
4 $0 $24,250 $24,251 $24,252 $24,253 $36,375 $36,376 $48,500 $48,501 $60,630 $60,631 $72,750 $72,751 $97,008
5 $0 $28,410 $28,411 $28,412 $28,413 $42,615 $42,616 $56,820 $56,821 $71,030 $71,031 $85,230 $85,231 $113,648
6 $0 $32,570 $32,571 $32,572 $32,573 $48,855 $48,856 $65,140 $65,141 $81,430 $81,431 $97,710 $97,711 $130,288
7 $0 $36,730 $36,731 $36,732 $36,733 $55,095 $55,096 $73,460 $73,461 $91,830 $91,831 $110,190 $110,191 $146,928
8 $0 $40,890 $40,891 $40,892 $40,893 $61,335 $61,336 $81,780 $81,781 $102,230 $102,231 $122,670 $122,671 $163,568
Income Level Income Level
% DISCOUNT - 0%
Income Level
Sample Agency
SLIDING FEE SCHEDULE
EFFECTIVE 2016
(BASED ON FEDERAL INCOME GUIDELINES PUBLISHED 2016)
% DISCOUNT - 30% % DISCOUNT - 20%% DISCOUNT - 40%
Income Level
Federal Guidelines
Income Level
% DISCOUNT - 80%
Income Level
% DISCOUNT - 60%
Income Level
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Sliding Fee Based on Income
DRAFT
Discount
% 20.00$ 40.00$ 50.00$ 60.00$ 80.00$ 100.00$ 140.00$ 160.00$ 200.00$
0% 20.00$ 40.00$ 50.00$ 60.00$ 80.00$ 100.00$ 140.00$ 160.00$ 200.00$
20% 16.00$ 32.00$ 40.00$ 48.00$ 64.00$ 80.00$ 112.00$ 128.00$ 160.00$
40% 12.00$ 24.00$ 30.00$ 36.00$ 48.00$ 60.00$ 84.00$ 96.00$ 120.00$
60% 8.00$ 16.00$ 20.00$ 24.00$ 32.00$ 40.00$ 56.00$ 64.00$ 80.00$
75% 5.00$ 10.00$ 12.50$ 15.00$ 20.00$ 25.00$ 35.00$ 40.00$ 50.00$
80% 4.00$ 8.00$ 10.00$ 12.00$ 16.00$ 20.00$ 28.00$ 32.00$ 40.00$
Services Case Mgt 1 hr group Drug 1 1/2 hr group 1 hr Therapy & Psychiatric Psychological Assessment 1 hr Evaluation/ Med Check
1/2 hr therapy Screening Medication Evaluations, Testing with Doctor
Monitoring Crisis
Intervention,
1/2 hr therapy
with Doctor, &
F
e
e
A
m
o
u
n
t
Full Fee Amount
Sample Agency
DISCOUNTED FEE SCHEDULE
EFFECTIVE FY16
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Assessing the
clients ability to
pay:1) pay stub
2) W-2/Income tax form
3) House Hold size
4) Household Income
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Understanding your compliance and
RCM risk to address the contract
needs for setting up
partnerships with DCOs, FQHCs,
Encounters and other community
or regional services.
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CCBHC Readiness
• Readiness to become a CCBHC will require more than simply asking whether or not
you are ready to be a CCBHC provider; instead, you will need to ask whether or not
you are prepared to become a brand-new provider type with the responsibilities
associated with this new role.
• CCBHCs as a provider type have two unique elements that have not been seen in
other provider types: 1) the requirements to include structured meta-data into both
your organization and your relationship with your partners, and 2) the ability to
provide services outside of your CCBHC through relationships with DCOs. These two
requirements create novel complications that must be considered to create
successful relationships and protect you from liability that can come from the
CCBHC's unique provider type structure.
• The following issues will help you to begin thinking about what it means to become a
new provider type with structured-data requirements and novel relationships that
allow you to move your services outside the walls of your facility.
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DCOs and YOU
• Has your clinic developed procedures to
manage the clinical relationship with DCOs
from both a clinical care and data sharing
requirement?
Source: New Integrated CCBHC Certification Criteria Feasibility and Readiness Tool (I-CCFRT)
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DCOs
• Whether directly supplied by the CCBHC or by a DCO,
the CCBHC is ultimately clinically responsible for all
care provided. The decision as to the scope of services
to be provided directly by the CCBHC, as determined by
the state and clinics as part of certification, reflects the
CCBHC’s responsibility and accountability for the clinical
care of the consumers. Despite this flexibility, it is
expected CCBHCs will be designed so most services are
provided by the CCBHC rather than by DCOs, as this will
enhance the ability of the CCBHC to coordinate services.
• Note: See CMS PPS guidance regarding payment.
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CCBHC
• The CCBHC ensures all CCBHC services, including those supplied
by its DCOs, are provided in a manner aligned with the requirements
of Section 2402(a) of the Affordable Care Act, reflecting person and
family-centered, recovery-oriented care, being respectful of the
individual consumer’s needs, preferences, and values, and ensuring
both consumer involvement and self-direction of services received.
Services for children and youth are family-centered, youth-guided,
and developmentally appropriate.
• Note: See program requirement 3 regarding coordination of services
and treatment planning. See criteria 4.K relating specifically to
requirements for services for veterans.
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Required Quality Data Elements for Clinics
and State
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1. Number/Percent of clients requesting services who were determined to need routine care
2. Number/percent of new clients with initial evaluation provided within 10 business days, and mean
number of days until initial evaluation for new clients
3. Mean number of days before the comprehensive person-centered and family centered diagnostic and
treatment planning evaluation is performed for new clients
4. Number of Suicide Deaths by Patients Engaged in Behavioral Health (CCBHC) Treatment
5. Documentation of Current Medications in the Medical Records
6. Patient experience of care survey
7. Family experience of care survey
8. Preventive Care and Screening: Adult Body Mass Index (BMI) Screening and Follow-Up
9. Weight Assessment and Counseling for Nutrition and Physical Activity for Children/Adolescents (WCC)
(see Medicaid Child Core Set)
CCBHC Data and Quality Measures
Required Reporting – Clinic List
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10. Controlling High Blood Pressure (see Medicaid Adult Core Set)
11. Preventive Care & Screening: Tobacco Use: Screening & Cessation Intervention
12. Preventive Care and Screening: Unhealthy Alcohol Use: Screening and Brief Counseling
13. Initiation and engagement of alcohol and other drug dependence treatment (see Medicaid Adult Core Set)
14. Child and adolescent major depressive disorder (MDD): Suicide Risk Assessment (see Medicaid Child Core Set)
15. Adult major depressive disorder (MDD): Suicide risk assessment (use EHR Incentive Program version of measure)
16. Screening for Clinical Depression and Follow-Up Plan (see Medicaid Adult Core Set)
17. Depression Remission at 12 months
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1. Housing Status (Residential Status at Admission or Start of the Reporting Period Compared to Residential Status at Discharge or End of the Reporting Period)
2. Number of Suicide Attempts Requiring Medical Services by Patients Engaged in Behavioral Health (CCBHC) Treatment
3. Follow-Up After Discharge from the Emergency Department for Mental Health or Alcohol or Other Dependence
4. Plan All-Cause Readmission Rate (PCR-AD) (see Medicaid Adult Core Set)
5. Diabetes Screening for People with Schizophrenia or Bipolar Disorder who Are Using Antipsychotic Medications
6. Diabetes Care for People with Serious Mental Illness: Hemoglobin A1c (HbA1c) Poor Control (>9.0%)
7. Metabolic Monitoring for Children and Adolescents on Antipsychotics
8. Cardiovascular health screening for people with schizophrenia or bipolar disorder who are prescribed antipsychotic medications
CCBHC Data and Quality Measures
Required Reporting – State List
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CCBHC Data and Quality Measures
Required Reporting – State List
9. Cardiovascular health monitoring for people with cardiovascular disease and schizophrenia
10. Adherence to Mood Stabilizers for Individuals with Bipolar I Disorder
11. Adherence to Antipsychotic Medications for Individuals with Schizophrenia (see Medicaid Adult Core Set)
12. Follow-Up After Hospitalization for Mental Illness, ages 21+ (adult) (see Medicaid Adult Core Set)
13. Follow-Up After Hospitalization for Mental Illness, ages 6 to 21 (child/adolescent) (see Medicaid Child Core Set)
14. Follow-up care for children prescribed ADHD medication (see Medicaid Child Core Set)
15. Antidepressant Medication Management (see Medicaid Adult Core Set)
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IT requirements for CCBHC Compliance
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Health Information Technology-
Telehealth
• NOTE: To the extent that CCBHC Clinics use DCO agreements to deliver the required CCBHC services, the same quality reporting data will be required of each DCO.
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• The state has the capacity to annually report any data or
quality metrics required of it, including but not limited to
CCBHC‐level Medicaid claims and encounter data. The
data include a unique consumer identifier, unique clinic
identifier, date of service, CCBHC service, units of service,
diagnosis, Uniform Reporting System (URS) information,
pharmacy claims, inpatient and outpatient claims, and any
other information needed to provide data and quality
metrics required in Appendix A of the criteria. Data are
reported through the Medicaid Management Information
System (MMIS/T‐MSIS).
Program Requirement 5: Quality and Other
Reporting
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• Does the clinic have the capacity to collect, report, and
track encounter, outcome, and quality data, including all
data and quality measures that Appendix A of the criteria
requires be reported by clinic s rather than the state?
• Do clinical data reporting systems have the capacity to
track the following elements: (1)consumer
characteristics; (2) staffing; (3) access to services; (4)
use of services; (5) screening, prevention, and
treatment; (6) care coordination;(7)other processes of
care; (8) costs; and (9)consumer outcomes?
Questions
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• The state has capacity to provide Treatment
Episode Data Set (TEDS) data and other
data that may be required by HHS and the
evaluator.
Program Requirement 5: Quality and Other
Reporting
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• Reporting is annual and data are required to
be reported for all CCBHC consumers, or
where data constraints exist (for example, the
measure is calculated from claims), for all
Medicaid enrollees in the CCBHCs.
Program Requirement 5: Quality and Other
Reporting
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• Do reports reflect data for all clinic
consumers?
• If data constraints exist, do reports at a
minimum include all Medicaid enrollees in the
clinic?
Questions
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• CCBHCs evidence the ability (for, at a
minimum, all Medicaid enrollees) to collect,
track, and report data and quality metrics as
required by the statute, criteria, and PPS
guidance, and as required for the evaluation
and annually submit a cost report with
supporting data within six months after the
end of each demonstration year to the state.
Program Requirement 5: Quality and Other
Reporting
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• To the extent possible, these criteria assign to the state responsibility for data collection and reporting where access to data outside the CCBHC is required. Data to be collected and reported and quality measures to be reported, however, may relate to services CCBH Consumers receive through DCOs. Collection of some of the data and quality measures that are the responsibility of the CCBHC may require access to data from DCOs and it is the responsibility of the CCBHC to arrange for access to such data as legally permissible upon creation of the relationship with DCOs and to ensure adequate consent as appropriate and that releases of information are obtained for each affected consumer.
Program Requirement 5: Quality and Other
Reporting
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Requirement for States - Part III – Data
Collection and Reporting Planning
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CCBHC Readiness
• Readiness to become a CCBHC will require more than simply asking whether or not
you are ready to be a CCBHC provider; instead, you will need to ask whether or not
you are prepared to become a brand-new provider type with the responsibilities
associated with this new role.
• CCBHCs as a provider type have two unique elements that have not been seen in
other provider types: 1) the requirements to include structured meta-data into both
your organization and your relationship with your partners, and 2) the ability to
provide services outside of your CCBHC through relationships with DCOs. These two
requirements create novel complications that must be considered to create
successful relationships and protect you from liability that can come from the
CCBHC's unique provider type structure.
• The following issues will help you to begin thinking about what it means to become a
new provider type with structured-data requirements and novel relationships that
allow you to move your services outside the walls of your facility.
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DCOs and YOU
• Has your clinic developed procedures to
manage the clinical relationship with DCOs
from both a clinical care and data sharing
requirement?
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DCOs
• Whether directly supplied by the CCBHC or by a DCO,
the CCBHC is ultimately clinically responsible for all
care provided. The decision as to the scope of services
to be provided directly by the CCBHC, as determined by
the state and clinics as part of certification, reflects the
CCBHC’s responsibility and accountability for the clinical
care of the consumers. Despite this flexibility, it is
expected CCBHCs will be designed so most services are
provided by the CCBHC rather than by DCOs, as this will
enhance the ability of the CCBHC to coordinate services.
• Note: See CMS PPS guidance regarding payment.
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CCBHC
• The CCBHC ensures all CCBHC services, including those supplied
by its DCOs, are provided in a manner aligned with the requirements
of Section 2402(a) of the Affordable Care Act, reflecting person and
family-centered, recovery-oriented care, being respectful of the
individual consumer’s needs, preferences, and values, and ensuring
both consumer involvement and self-direction of services received.
Services for children and youth are family-centered, youth-guided,
and developmentally appropriate.
• Note: See program requirement 3 regarding coordination of services
and treatment planning. See criteria 4.K relating specifically to
requirements for services for veterans.
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• Does the clinic have a relationship with DCOs
that allows for collection of data and quality
measures following consumer consent for
releases of information?
Questions
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• CCBHCs have policies and procedures in place requiring and enabling annual submission of the cost report within 6 months after the end of the demonstration year.
• CCBHCs have formal arrangements with the DCOs to obtain access to data needed to fulfill their reporting obligations and to obtain appropriate consents necessary to satisfy HIPAA, 42 CFR Part 2, and other requirements.
Program Requirement 5: Quality and Other
Reporting
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• As specified in Appendix A, some aspects of data reporting will be the responsibility of the state, using Medicaid claims and encounter data. States must provide CCHBC-level Medicaid claims or encounter data to the evaluators of this demonstration program annually.
• At a minimum, consumer and service-level data should include a unique consumer identifier, unique clinic identifier, date of service, CCBHC-covered service provided, units of service provided and diagnosis. These data must be reported through MMIS/T-MSIS in order to support the state’s claim for enhanced federal matching funds made available through this demonstration program.
Program Requirement 5: Quality and Other
Reporting
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• For each consumer, the state must obtain and
link the consumer level administrative Uniform
Reporting System (URS)information to the claim
(or be able to link by unique consumer
identifier).CCBHC consumer claim or encounter
data must be linkable to the consumer's
pharmacy claims or utilization information,
inpatient and outpatient claims, and any other
claims or encounter data necessary to report the
measures identified in Appendix A.
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Program Requirement 5: Quality
and Other Reporting
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• These linked claims or encounter data must also be
made available to the evaluator. In addition to data
specified in this program requirement and in Appendix A
that the states to provide, the state will provide such
other data, including Treatment Episode Data Set
(TEDS) data and data from comparison settings, as
maybe required for the evaluation to HHS and the
national evaluation contractor annually.
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Program Requirement 5: Quality
and Other Reporting
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• The clinic has agreed to and demonstrates
the ability to report data listed in Criteria
Appendix A, CCBHC Required Measures and
such other data as the state requires to
participate in the demonstration program.
• The clinic agrees to participate in discussions
with the national evaluation team.
Questions
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• CCBHCs annually submit a cost report with
supporting data within six months after the
end of each demonstration year to the state.
The state will review the submission for
completeness and submit the report and any
additional clarifying information within nine
months after the end of each demonstration
year to CMS.
Program Requirement 5: Quality and Other
Reporting
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• Does the clinic have procedures in place to
submit an annual cost report with supporting
data to the state within 6 months after the
end of the demonstration year?
Questions
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• Documents to Review Onsite or in Advance:
• (1) Continuous quality improvement (CQI) plan for clinical services and clinical management (not administrative management) with CQI projects identified,
• (2) clinic policies and procedures related to CQI, (3) job description of personnel responsible for CQI plan,
• (4) data on consumer suicide attempts and completed suicides, and
• (5) data on consumer 30-day hospital readmissions for psychiatric or substance use reasons
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5.B Continuous Quality Improvement Plan (
CQI)
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• The CCBHC develops, implements, and maintains an effective, CCBHC-wide data-driven continuous quality improvement (CQI) plan for clinical services and clinical management. The CQI projects are clearly defined, implemented, and evaluated annually. The number and scope of distinct CQI projects conducted annually are based on the needs of the CCBHC’s population and reflect the scope, complexity and past performance of the CCBHC’s services and operations.
• The CCBHC-wide CQI plan addresses priorities for improved quality of care and client safety, and requires all improvement activities be evaluated for effectiveness.
• The CQI plan focuses on indicators related to improved behavioral and physical health outcomes, and takes actions to demonstrate improvement in CCBHC performance.
• The CCBHC documents each CQI project implemented, the reasons for the projects, and the measurable progress achieved by the projects. One or more individuals are designated as responsible for operating the CQI program
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5.B Continuous Quality Improvement Plan (
CQI)
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• A, Does the clinic develop, implement, and maintain a clinic -wide data-driven CQI plan for clinical services and clinical management?
• B. Does the CQI plan identify CQI projects that are based on the needs of the clinic population and reflect the scope, complexity, and past performance of the clinic’s services and operations?
• C. Does the CQI plan address priorities for improved quality of care and client safety?
• D. Are the CQI projects evaluated annually and for effectiveness?
• E. Does the CQI plan focus on indicators related to improved behavioral and physical outcomes and call for actions designed to improve clinic performance in those areas?
• F. Does the clinic document each CQI project implemented, the reasons for the projects, and measurable progress achieved by the projects?
• G. Whom has the clinic designated to be responsible for operating the CQI program?
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• Although the CQI plan is to be developed by the CCBHC and reviewed and approved by the state during certification, specific events are expected to be addressed as part of the CQI plan, including:
• (1)CCBHC consumer suicide deaths or suicide attempts;
• (2) CCBHC consumer 30 day hospital readmissions for psychiatric or substance use reasons; and
• (3) such other events the state or applicable accreditation
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• A. Does the clinic CQI plan address
consumer suicide deaths and suicide
attempts?
• B. Does the clinic CQI plan address
consumer 30-dayhospital readmissions for
psychiatric or substance use reasons?
• C. Does the clinic CQI plan address events
that the state or applicable accreditation
bodies deem appropriate?
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• Develop Protocols to review services
delivered verses Services ordered on the
treatment plan
• Develop Audit functions to review Medical
Necessity and compliance to report back to
leadership, managers and direct care staff
Utilization Management
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Audit Functions
• Quantitative Measures of Compliance
• Qualitative Measures of Compliance
• Contractual Compliance
• Clinical Key Performance Measures
• Non-Clinical Key Performance Measures
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Compliance, Accountability &
Monitoring
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Why is this important?
• Increased Accountability
• UM UR
– If we find that UM UR reviews
provide unsubstantiated claims
this will impact your CCBHC and DCO audit risk
– Horizontal and vertical accountability
– KPIs for clinical and non clinical team members
• Follow your UM UR/Corporate Compliance policy
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• Just because we have passed a state audit is no guarantee that we are not open to problems.
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Documentation
Get the CheckWithstand the audit
Keep the MoneySo, you can do it again.
Find the clientAssess the clientTreat the ClientDocument it all
Give the info to the next part of the process
SubmitThe
Claim for Payment to the Correct payer(s)
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Performance Standard Model
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UM/UR- Corporate Compliance
• Is the set of structures or methods that provide for authorization of care, using particular criteria.
– These are usually determined by the payer.
• Corporate Compliance Programs are structures and methods to review and monitor federal and state guidelines for quantitative and qualitative compliance
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OVERVIEW
• AGENCY will employ a Corporate Compliance Officer to perform monthly reviews of all agency and DCO programs. Each program (including Crisis, Adult Mental Health, Substance Abuse, C&A Mental Health, Psychiatry, DCO, and others) will have at least 5% of its charts reviewed a minimum of 4 times each year.
• UR reports will be generated following each of these reviews and distributed to the manager of the affected programs. The managers will be responsible for instructing staff to amend what they can and will also search for trends of non-compliance that need further corrective action.
• Annually, the consultant will review each program and make recommendations on systemic improvement and assess each program’s strengths.
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NEW CLINICAL STAFF/DCOs
• For the first six weeks of active clinical work, QA will review each chart weekly. They will then provide a personal review to the staff member and DCO regarding their paperwork timeliness and accuracy. At the end of this four week period, QA will either sign off that the clinician/DCO is competent or that the clinician requires another two weeks of review.
• Once the clinician has been signed off on, QA will review one week of charts once per month for the next nine months. QA will provide a written assessment of their performance to their supervisor, which will be reviewed during supervision, signed off on by both supervisor and employee, and placed in the employee’s personnel file.
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EXISTING STAFF
• All staff/DCOs will have 20% of their charts audited the month before their annual contract review. QA will provide a written evaluation to assist the manager with the review process. If their compliance is above 95%, they will be placed in the “A” category. If less than 95% compliance is noted on this annual review, the clinician will be put into the “B” category. If less than 85% compliance is noted, the clinician will be placed in the “C” category.
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Category A:
• Clinicians/DCOs in this category will receive semi-annual spot audits in addition to their annual review audit.
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Category B:
• Clinicians/DCOs in this category will be required to adjust any incorrect documentation in the audited charts. They will also be subjected to once-per-month spot audits that will be documented and reviewed in supervision. They will have to make any necessary adjustments to the documentation and will need to have their supervisor sign-off on their spot-audit sheet verifying that this is done. This will continue monthly until compliance meets 95% or until 6 months have passed. If 95% compliance is not reached within 6 months, the clinician/DCO will be put into category C.
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Category C:
• Clinicians/DCOs in this category will be required to submit all documentation daily to Compliance Review Staff. They will evaluate it for completeness and accuracy and will provide the supervisor with a daily report.
• They will be available to provide additional training to the clinician if required to ensure compliance. This will continue for 30 days, at which time compliance should reach 95%. The clinician will then be placed in Category B, although they will have expanded evaluation of treatment plan compliance for the first three months. If compliance does not reach 95% within 30 days, further disciplinary action will need to be taken at the discretion of the supervisor or termination of the DCO contract
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Manage risk of unexpected losses or expenses
caused by regulatory action
◦ Prevent large payback sums, costly attorney’s
fees, negative public relations, employee
resources committed to response
◦ Civil/criminal liabilities
Implement proactive Corporate Compliance
initiatives to meet increased scrutiny from state
and federal funders
Meet our ethical obligations of quality care
Why incorporate CORPORATE
COMPLIANCE with your CCBHC?
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• Compliance risk assessment
– Train employees and DCO contractors
– Review documents (UR: billing and coding,
medical necessity documentation)
– Identify risk areas (CI, CM, Family and Group
Rx, Fidelity to EBP, etc.)
• Infrastructure review– Review program components (self-disclosure,
corporate compliance log, removing billings that are unsubstantiated)
CORPORATE COMPLIANCE
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Document and Claim Services Accurately
◦ Meet credentialing requirements
◦ Signatures must be original, dated and
accompanied by credentials (or meet e-
signature standards)
◦ Document actual time, date, duration
◦ Reflect service provided as required
◦ Include required documentation elements
◦ Include medical necessity, “golden thread”
SAMPLE CORPORATE COMPLIANCE
Elements
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Understanding your Cost Reporting
Structure and Infrastructure needs
Steve Kohler
McBee and Associates
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Speaker NameTitle
Organization
CCBHC Masters Class
Back Office Management
Steve KohlerDirector
McBee Associates, Inc.
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Cost Report Basics
• What specific type of information is gathered?
– Facility characteristics (ownership status, type
of facility)
– Statistical Information ( Volume statistics by
payer)
– Financial Data, primarily P&L data, revenue
and expense
– Wage related data
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Cost Report Basics
• Why is a Cost Report Important?
– The cost report is a financially report that identifies
the cost, charges, and volume statistics related to
healthcare treatment activities
– Cost Reports Impact Reimbursement
• Today
• Future Reimbursement – Prospective Payment
System Implementation; Monitoring; and rate
adjustments
– Congressional / CMS policy and rate setting
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PPS Rate Development
• Facility specific base year cost as it stands now
would be utilized to develop a facility specific
rate per visit. The base year rate would be
updated, by the MEI (Medicare Economic Index)
or other state determined factors
• At this time, updates would not be provided for a
change in services or service mix.
• Budgetary constraints can also impact future
payment rates
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PPS Benefits
• Predictability of Cash Flow and Receipts
• Shared Risk between the Payer and the
Provider
• Offers Reward (Profit) where costs are less
than reimbursement and Loss where cost
exceeds the PPS payments
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Cost Report Preparation
• Assemble your team
• Develop a plan and timetable
• Know the regulations
• Compile all required records
• Keep in mind the cost data is based on
accrual accounting
• Keep and provide all backup supporting
statistical records
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Who Are the Team Members
• CFO/Director of Finance
• Payroll
• Finance Department Staff
• Compliance Officer
• Operations
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Additional Staffing
• Will I need more staff???
– Consider roles and responsibilities of current
finance department staff.
• Depending on the complexity and size of the
organization this will take time to prepare for
and to complete the cost report.
• Discussion
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Assess
• Current accounting software
– Is it flexible to add new accounts?
– Rename accounts and assign new account
numbers?
• Current billing system capabilities
– Capturing all visits data?
– Does that visit data match what the
regulations indicate are to be counted as
enumerated visits?
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Assess
• Current payroll process
– Can your system accurately assign worked in
a program or is it a manual process?
• Consider
– Do you need do have staff do time studies?
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Plan and Timetable
• Assign responsibilities to address:
– General Ledger Mapping
– Salary Schedule
– Visit Enumeration
– Job Descriptions
– Regulations Impacting Your State
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Job Descriptions
Take Credit Where the Credit is Due
• You may need to revise several job
descriptions.
• Why?
– Do you really know what everyone does in the
organization and are they actually doing what
the job description says
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Get it Right!
• Why Get it Right?
– You may have to live with the rate you
establish
• When setting your rate consider:
– Budgeting for growth
– Potential new staffing requirements
– New documentation or collaboration
requirements
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Preparing for the Cost Report
• Direct and Allowable Cost (as defined by
regulations)
• Allocation of Overhead Cost
• Determination of Cost of Services (Cost per
Unit)
• Determination of Cost of Services related to
Medicaid Patients
• Provides for Cost Basis to Develop a
Prospective Payment System (PPS)
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Cost Report Essentials
• Commonly Used Data in a Cost Report
– General Ledger (Summary Trial Balance)
– Payroll Register
– Statistical Reports of Services by Payer with a
detailed review required – Patient Census
– Overhead Allocation Statistics
– Other Specific Purpose Data
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The CCBHC Cost Report
• Costs must adhere to:
– 45 Code of Federal Regulations (CFR) 75
Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for the
U.S. Department of Health and Human
Services (HHS) Awards, and
– 42 CFR 413 Principles of Reasonable Cost
Reimbursement
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The CCBHC Cost Report
• CCBHC records must be:
– Detailed
– Orderly
– Complete, and
– AVAILABLE for REVIEW or AUDIT
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The CCBHC Cost Report
• Supporting documents must be maintained
for all costs reported;
– Cost report package and source
documentation (e.g. invoices, patient records,
cancelled checks) must adhere to federal and
state record retention requirements.
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The CCBHC Cost Report
• Accrual basis of accounting required
• All information requested in the cost report
tabs must be furnished
• Failure to complete applicable tabs properly
will result in rejection and return to the
CCBHC for correction and re-submission
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The CCBHC Cost Report
• Part 1 – Provider Information Tab
– Basic information Gathered
• Part 2 – Provider Information For Clinics
Filing Under Consolidated Cost Reporting
– Must be completed for each site included in
the consolidation
• If more than 1 satellite exists, create a new tab
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Trial Balance Tab
• Purpose:
– Record amounts from the trial balance
expense accounts
– Perform necessary reclassifications and
adjustments to adhere to Medicare and
Medicaid cost principals
– Record estimates of anticipated changes in
costs
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The General Ledger
• General Ledger – Summary Trial Balance
– The General Ledger serves as the source
document for initial reporting on the cost
report
– A properly established General Ledger will
serve to categorize expense and revenue
related to the specific departments / types of
services provided that will ease the burden of
completing the cost report without the need
for post year-end analysis, or at least
minimize it.
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The General Ledger
• General Ledger – Trial Balance (cont’d)
– With a properly detailed general ledger (accounts /
departments / etc. mapping expenses to the cost
report becomes easy, okay, easier.
– With an overly simplistic general ledger, one which is
constructed just with natural accounts, e.g. salary
expense, benefit cost, supply expense, etc. and not
on a cost center basis, be prepared for late hours for
analysis and breakdown of expenses to meet the cost
reporting requirements.
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Trial Balance Tab
• Cost elements of an expense category
maintained separately must be reconciled to
the worksheet expense
• Working Trial Balance must be submitted with
Cost Report
• MATERIALS ARE SUBJECT REVIEW or
AUDIT
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• Key Column Descriptions
– Column 4 – Reclassifications
– Column 6 – Adjustments
– Column 8 – Anticipated Costs
Direct CCBHC Expenses
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Anticipated Costs
• What are “Anticipated Costs”?
– Costs you expect to incur to meet the
expectations of operating as a CCBHC!
• Discussion of Anticipated Costs
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Expense Line Descriptions
• Key Line Descriptions
– Part 1A- CCBHC Staff Costs
– Part 1B- CCBHC Staff Costs Under
Agreement (these are your DCO costs)
– Part IC – Other Direct Expenses
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Indirect Costs
• Part 2A – Site Costs• What are Overhead Costs?
– Depreciation / Rent
– Insurance
– Interest Expense
– Utilities
– Housekeeping and Maintenance
– Property Taxes
– Administrative Salaries
– Office Supplies
– Legal
– Accounting
– Insurance
– Telephone
– Fringe Benefit Costs, including Payroll Taxes
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Direct Costs for Non-CCBHC Services
• Part 3A- Direct Costs for Services other than
CCBHC Services
– This is the subtotal of direct costs for non-
CCBHC services “COVERED” by Medicaid
“EXCLUDING” overhead and “SPECIFY” in
the comments tab.
• Part 3B – Non-Reimbursable Costs
– Is the subtotal of direct costs for Non-CCBHC
services “NOT REIMBURSABLE” by Medicaid
and “SPECIFY” in comments tab.
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Trial Balance Reclassifications Tab
• Reclassifies expenses to determine proper
cost allocation
– Must be identifiable in accounting records
– Use when expenses apply to more than 1
expense category
• Example Staff Psychiatrist
• Narrative must support reclassification of
expense
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Trial Balance Adjustment Tab
• Used to Adjust Expenses in the Trial Balance
• Made on the basis of cost or revenue
• If an adjustment is made on the basis of cost
the provider may not adjust the expense on
the basis of cost in future cost reporting
periods
• If total direct and indirect cost can be
determined us cost as the basis of the
adjustment ….revenue as basis if not
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Common Adjustments
• Investment income on restricted and
unrestricted funds
• Home office costs
• Services provided by National Health Service
Corps
• Depreciation Expense
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Unallowable Costs
• Found in 45 CFR 75
• Examples
– Related Party Transactions
– Bad Debts
– Certain Advertising and Public Relations
Costs
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Anticipated Costs Tab
• Additional costs for services needed to be a
CCBHC
• Costs expected to increase as a result of
offering CCBHC services
• Costs should support Medicaid and Non-
Medicaid patients
• Allowed only in year demonstration year 1
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Indirect Cost Allocation Tab
• Used to identify the method used for
calculating allocable indirect costs to CCBHC
services using:
– Indirect rate approved by a cognizant agency
– A 10% rate
– Calculated indirect cost allocable to CCBHC
– Other method
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Allocation Descriptions Tab
• Used to describe calculations and methods
that support the allocation methodology
• Additional documentation supporting
allocations must be kept on file
• Allocation of direct costs must be detailed
– Time Study
• Home office adjustments
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Time Studies
• Why do a time study?
– Allows you to accurately attribute costs to the correct
cost center
– Identifies how much administrative time is dedicated
to those duties versus directly program related duties
– Reduces your administrative costs
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Daily Visits Tab
• PPS-1 only
• Visits by one patient to multiple locations on
the same day may only be counted 1 time.
• Unique visit days directly from the CCBHC
• Unique visit days from DCO
• Anticipated unique visits
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Monthly Visits Tab
• Used for PPS-2
• Patient Demographics Consolidated
– Patient visits to multiple locations counted 1
time
• Categorize costs according to whether
monthly outlier threshold and whether they
were allocated to certain conditions
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Services Provided Tab
• Used to record FTE’s and # of services
provided for CCBHC services for each type of
practitioner
• This should be the units of service not days
• Must provide:
– CCBHC staff services
– CCBHC services under agreement
– Services by site
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Additional Tabs
• Comments Tab- used for considerations
• PPS-1 Rate Tab –auto populated
– * Enter applicable Medicare Economic Index (MEI)
• PPS-2 Rate Tab
• Certification Tab
– Must be an officer or other authorized administrator
• CEO or CFO
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Questions
• ????
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Point of Service and Post Service
needs in the new environment
Michael Flora
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Revenue Cycle Management
PRE-SERVICE
Admission Eligibility
Pre-Service Audit
Authorization
Verification
Open to Schedule
POINT OF SERVICE
Co-Pay Collections
Treatment
Post Session Scheduling
Post Service Audit
POST SERVICE
Billing
Denial Management
Account Receivable Management
Cash Posting
Consumer Follow-Up
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Point of Service
1. Collection of Co-Pays
2. Clinical Care Documentation
3. Charge capture
4. Coding
5. Utilization Management
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• You will be expected to pay your fee each
time you receive service. Credit cards may
be accepted. If, however, you are unable to
remain current with your account, a different
approach may be necessary. Please discuss
such circumstances with our Client Accounts
staff or your clinician. If you do not, and
payment is not made, we reserve the right to
turn your account over to a collection agent.
Collection of Co-Pays
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• Clinical Documentation must support the
services provided for the day
• Services provided must be on the Treatment
Plan and Assessment of need
• Documentation must be completed and
accurately submitted with in 24 hours after
service is rendered.
Clinical Care Documentation
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Roles of Clinical and Financial Staff In
Third Party Billing
1. Completion and submission of all required
clinical documentation by direct care staff will
be needed to support authorizations after
Intake (if required) and re-authorizations
2. Filing timely and accurate claims will be
critical
3. Monitoring level of unreimbursed third party
care – determine reasons for non payment
and correct issues
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• Review current coding Policy and procedures
to assure compliance
• Review current denial rates by CPT code
• Develop KPIs to reeducate denied claims
with in 24 hours
Coding
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Coding Correctly
• Proper coding is necessary to ensure
appropriate reimbursement and avoid audit
liability
• Correct coding implies the selection is the
most accurate description of “what” services
were provided and “why” they were provided
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Coding Correctly
• Per CPT, any procedure or service in any
section of CPT can be used by any qualified
physician or health care professional
– E/M codes can be reported by psychiatrists
– Psychiatric codes can be billed by other
qualified providers
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Coding Correctly: HCPCS Codes
• Alpha-numeric codes and modifiers used by some payers such as Medicaid or Medicare
– H0031- Mental health assessment by non-physician (Medicaid)
– J codes for injectable medications (Medicare and Medicaid)
– Medicare modifier AJ for services provided by clinical social worker
• Code and modifier determines reimbursement level
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Coding Correctly in
Integrated Care Setting
• General guidelines:
– Psychiatric services codes should be
reported by behavior health professionals
– E/M codes should be reported by
physicians, NPs, PAs, etc.
• Psychiatrist may report services from either
category depending on service provided
• Payers may have different coverage and
payment policies!
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Coding Correctly in
Integrated Care Setting• Distinguish medical and mental health
diagnoses
• Providers select diagnosis (es) that’s chiefly
responsible for services provided
• Report only codes you treat or that impact
treatment
• Use codes for signs and symptoms until
diagnosis has been determined
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Roles of Support Staff In Third
Party Billing
Centralized Scheduling is needed to ensure referral is
made to clinician on the appropriate insurance panel or
approved CCBHC PPS rate
– Ability to know at all times the availability of clinical
staff that are credential on third party panels will
be critical to timely acceptance of new referrals
Re-think Front Desk functions/needs
– Collection of Co-Pays prior to Service
– Confirmation of Insurance via copy of Insurance cards prior
to service
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Point of Service Contact• Collection of Co-Pay/Reimbursement for services
• a. Definition: collection for all billable service co-pays provided by the center staff will be executed at each customer visit.
• b. Standard: CSR staff will accurately collect bill for services at the point of service
• c. Source: Review of financial reports.
• d. Compliance Rating: 98% or greater of these entries made at the POS =compliant. Less than 98% = non-compliant.
• e. Solution Plan: Development note and retraining for first non-compliant rating. A Written Warning and retraining will be offered following the second consecutive non-compliant period and Separation from employment upon the third consecutive non-compliant period.
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Revenue Cycle Management
PRE-SERVICE
Admission Eligibility
Pre-Service Audit
Authorization
Verification
Open to Schedule
POINT OF SERVICE
Co-Pay Collections
Treatment
Post Session Scheduling
Post Service Audit
POST SERVICE
Billing
Denial Management
Account Receivable Management
Cash Posting
Consumer Follow-Up
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Post Service
1. Billing
2. Collections Management
3. Denial Management
4. Data Warehouse Analytics
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Accelerating Cash Collection
• What are your days of sales outstanding?
• After services are delivered behavioral healthcare organizations revenue cycle needs to assess and maximize revenue capture and streamline the billing and collection process.– electronic claim processing,
– direct entry of Medicare/Medicaid claims,
– automatic secondary/Waterfall billing,
– remittance posting,
– contract and denial management,
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Non-Clinical Performance Indicators
• Billing statements
•
• a. Definition: Client statements will be accurate and issued to each individual via mail each month.
• b. Standard: Client statements will be reviewed for accuracy and mailed out no later than the 20th day of each month.
• c. Source: Client statement spreadsheet
• d. Compliance Rating: 98% or higher of the statements are accurate and mailed = compliant. Less than 98% accuracy and distribution = non-compliant
• e. Solution Plan: Development note and retraining for first non-compliant rating. A Written Warning and retraining will be offered following the second consecutive non-compliant period and separation from employment upon the third consecutive non-compliant period.
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Improving Access Management
• Assess the workflow processes and eliminate
redundancies in collection and rework.
• Providers will need to accurately:
– Obtain authorization for services,
– Determine, validate coverage for payment,
– Assess payment risk
– Schedule resources prior to the consumer’s
arrival.
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Roles of Support Staff In Third
Party Billing
1. Centralized Scheduling is needed to ensure referral is made to clinician on the appropriate insurance panel or is enrolled with Medicaid/Medicare
– Ability to know at all times the availability of clinical staff that are credential on third party panels will be critical to timely acceptance of new referrals
2. Re-think Front Desk functions/needs
– Collection of Co-Pays prior to Service
– Confirmation of Insurance via copy of Insurance/Medicare cards prior to service
– Obtain and validate at each visit the demographic information from consumers. Make this a KPI.
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Information
Capture at the
Front Desk
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Third Party Payer Assessment Sheet
Revenue Enhancement Work Sheet
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Non-Clinical Performance Indicators
• FINANCE:
• Goals:
1. Accurate billing statements will be generated and issued to consumers
no longer than 10 business days after month end 100% of the time
2. Based on the number of consumers billed, substantiated customer
complaints will not exceed 2%
3. Third party fees will be billed 100% of the time
4. 100% of complete and accurate invoices will be paid within 30 days of
receipt
5. Financial reports will be generated and distributed to management staff
within 15 business days of month end 90% of the time
6. Consumer satisfaction survey rating for financial matters/charges will
not fall below a score of 90%.
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What about the payers?
• Improving Payer Performance
– Knowing Payer expectations
– What payers are in your market
– What is the % of Medicaid ?
– What is the % of Medicare?
– What is the % of uninsured?
– What is the % of Insured?
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Identifying your work force needs in
the new CCBHC Revenue Cycle
Has your clinic developed a plan to
re-classify personnel to most
effectively leverage the PPS cost-
based reimbursement methodology?Source: New Integrated CCBHC Certification Criteria Feasibility and Readiness Tool (I-CCFRT)
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Do You Have the Right Team?
• This is the most common question that asked
by Managers, Supervisors, Owners, and
CEOs. What do you think of your
management team? How do their skills
compare with those of other managers in
competitive organizations?
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Do You Have the Right Team?
– Does your team perform “excellently” today?
Are they the team to implement your plans for
the next few years?
– Does your team have the skill sets needed to
manage CCBHC back office requirements?
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Do You Have the Right Team?
– Who do you think is the most qualified to take
on your next major strategic initiative?
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Do You Have the Right Team?
– Are any members of your team ever being
able to be promoted?
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Do You Have the Right Team?
– If so, how long will it take for them to be
prepared? What should you do to make it
happen? If not, what are you going to do to
make it happen
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The steps for ensuring that you have the
right staff with the right skills at the right
time are fairly straightforward:
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Do You Have the Right Team?
• #1. Conduct an assessment of the
competencies and knowledge requirements
for critical executive, management and line
positions - for the present and for your
business’s long-term strategic future.
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Do You Have the Right Team?
• #2. Assess current employee performance,
capabilities, and potential along the CCBHC
requirements and other key dimensions.
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Do You Have the Right Team?
• #3. Develop a plan to either buy or build the
competencies you need for organizational
success.
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Questions and Feedback
• Questions?
• Feedback?
• Next Steps?
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Resources
I-CCBHC Feasibility and Readiness Assessment FINAL REVISED
E-FORM12-8-15…
Demo State Proposal Guidance_100515f_revised
101515_submitted with OMB # attached
Requirements of States for CCBHC Demonstration Program –
Clean – 1-7-16
CCBHC State-Certification-Guide 7-15
State Level Community Needs Assessment Check List FINAL 1-21-
16-1
CCBHC Certification Criteria Checklist 1-7-16
CCBHC Demonstration Application Guidance Analysis 1-5-
1601062016
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