Tags Posts tagged with "Temporary Enhanced Rates"

Temporary Enhanced Rates

ODP Announcement 21-059 is to inform stakeholders of the rate load timeline and to provide guidance for the temporary enhanced rates associated with Community Participation Supports (CPS) and Transportation Trip services.

The enhanced rates are anticipated to be visible on Individual Support Plans (ISPs) in the Home and Community Services Information System (HCSIS) on August 1, 2021 with an effective date of August 1, 2021. For the most part, services should auto-authorize, and there should be no need for manual intervention. However, if errors set, see the section of this communication titled “Manual Review Process in HCSIS For a Mass Rate Change,” which is found on the next page. Providers are strongly encouraged to review Service Authorization Notices or the Provider Service Detail report in HCSIS to confirm the enhanced rates were loaded and authorized before attempting to bill for any CPS or Transportation Trip services rendered August 1, 2021 and after.

Compensation for Temporary Enhanced Rates for the Period July 1, 2021 – July 31, 2021

The enhanced CPS and Transportation Trip rates will not be loaded in ISPs for the period July 1, 2021 through July 31, 2021. Instead, the current rate will remain for that period, and ODP will be compensating providers, via gross adjustments, for the difference between the rate billed and the temporary enhanced rate for CPS and Transportation Trip services that were rendered during the period July 1, 2021 through July 31, 2021. This is intended to eliminate the effort of voiding and re-billing claims. ODP anticipates processing gross adjustments during October 2021 to ensure all billing for the month of July 2021 has been completed. Providers are requested to bill in a timely manner to minimize the need for corrections.

Rate Load Impact on ISPs in Draft and Pending Approval Status

Plans in draft or pending approval status will be updated with the temporary enhanced rates for CPS and Transportation Trip services. If there are any exceptions that set on the draft or pending approval plan as a result of the rate load, these plans will be “locked” and the AEs must resolve the issue using the View Modifications screen found in the Mass Rate Change tab in HCSIS.

Two Service Segments on ISPs for CPS and Transportation Trip Services

Since the temporary enhanced rates for CPS and Transportation Trip services will have a begin the date of August 1, 2021, two service/rate segments in authorized status will be present on ISPs, assuming no errors set. One service/rate segment will reflect the period July 1, 2021 to July 31, 2021 and the second service/rate segment will reflect the period August 1, 2021 to June 30, 2022.

Rate Load Causing Cap Limitation to be Exceeded

It is possible that once the temporary enhanced rate load occurs in HCSIS, cap limitations may be exceeded for individuals not currently approved for a cap exception. Plans associated with individuals approved for a cap exception should not experience an enhanced rate load issue. If a cap limitation prevents the enhanced rate to update, the service will be in a pending authorization status until AEs modify the plan accordingly or a cap exception is put in place.

Manual Review Process in HCSIS for a Mass Rate Change

Once the rate change is initiated, if one or more plans are not updated automatically by HCSIS, AEs may review the errors that set the exception and fix the errors accordingly. Administrative Entities may view the impacted service contracts, impacted claims, impacted plans, and exceptions, resulting from a mass rate change, via the View Modifications screen in HCSIS. All line items with a status of “Updates in Progress” will need to be addressed by the AE before the rate change is finalized.

See ODP Announcement 21-059 for full details.

Photo by Markus Winkler on Unsplash

A message from ODP Deputy Secretary Kristin Ahrens:

On February 3, 2021, pursuant to authority granted through an approved Appendix K, the Department announced temporary enhanced rates for Community Participation Supports and Transportation Trip services for services rendered January 1 through June 30, 2021. The end dates for the temporary rates were programmed in HCSIS consistent with the timeframe announced in the PA Bulletin; therefore, rates effective July 1, 2021 reverted to the previously published rates for these services.

In May 2021, CMS published SMD# 21-003 RE: Implementation of American Rescue Plan Act of 2021 Section 9817: Additional Support for Medicaid Home and Community-Based Services (HCBS) during the COVID-19 Emergency. The SMD addresses requirements to receive the increased federal medical assistance percentage (FMAP) rate for certain Medicaid expenditures for HCBS, including that federal funds attributable to the increased FMAP must be used to supplement existing state funds expended for Medicaid HCBS in effect as of April 1, 2021.

CMS has advised the Department that it must continue the temporary enhanced rates until the end of the approval of its Appendix K for the Commonwealth to receive the increased FMAP. Accordingly, subject to further CMS guidance, the enhanced rates will continue through the approval of the Appendix Ks. The Appendix Ks for the Consolidated, Person/Family Directed Support (P/FDS), Community Living and Adult Autism Waivers are authorized for 6 months after the federal Public Health Emergency ends.

ODP anticipates that the temporary enhanced rates will be loaded in HCSIS during the week of August 1, 2021. Additional information for handling individual plan authorizations will be transmitted via an ODP communication prior to the rate load in HCSIS.

RCPA, along with the other ID/A Coalition members, requested that CMS require ODP to continue these enhanced rates, so we are pleased to share this news.

Managing the Impact of Temporary Enhanced Rates for Community Participation Support and Transportation Trip on Individual Support Plans (ISP) and Annual Fiscal Limits

The Home and Community Services Information System (HCSIS) was automatically updated to include the temporary increases to the CPS and Transportation Trip fee schedule rates. Critical revision will not be necessary for most ISPs to implement the change to the fee schedule rates. However, ODP recognizes that the temporary rate increases may result in an individual’s ISP exceeding the CL or P/FDS waiver caps. As a result, ODP Announcement 21-021 provides guidance to ISP teams to do the following:

  1. When adjusting the ISP, Supports Coordination Organizations should select a manual review. Even if the manual review is selected and there is no service change to the ISP, an auto authorization will occur, and Administrative Entities should conduct a quality assurance review.
  2. If the implementation of the temporary enhanced rates puts an ISP budget total over the respective cap established for the P/FDS waiver or the CL waiver, ISP teams should review current utilization of the services and adjust services accordingly in an attempt to bring the ISP budget within the cap. ISP Teams should follow the guidelines in the ISP Manual when looking at service utilization on an ISP, as follows:
    1. Determine if the designated service has the desired effect to address the specified need, which promotes the achievement of an Outcome Statement.
    2. Determine if there is an established limit associated with the service.
    3. Determine if the units in the ISP are necessary based on the individual’s current needs and are not above the established limit.
    4. Review the previous year’s utilization to inform discussions for future decisions.
    5. Determine continued need and skill attainment.
  3. When it is determined that, due to underutilization, service units can be reduced after completing a service utilization review; an ISP Team Meeting should occur to ensure individuals, families, and providers are aware and agree with any changes to the ISP. If an individual or family does not agree, the SC should request a cap exception by submitting the request to the Administrative Entity, using the existing process. ISP Teams will have an opportunity to revise ISPs for Fiscal Year 21-22 in accordance with forthcoming guidance, including taking the individual’s needs into account for Fiscal Year 21-22 which could include restoring units that were reduced this year.
  4. If the waiver cap for the P/FDS or CL waiver will be exceeded after utilization is reviewed and adjusted accordingly, the ISP team should request a cap exception by submitting the request to the Administrative Entity, using the existing process. Please refer to ODP Announcement 20-069 for the process and cap exception form.