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Independent School Districts Federal Fiscal Year 2013 1 Agenda Program Overview Random Moment Time Study (RMTS) Overview Medicaid Administrative Claiming (MAC) - Financial Reporting School-based Medicaid programs Enrollment process Program contact responsibilities Allowable costs Claim submission Claim calculation State of Texas Automated Reporting System (STAIRS) Demonstration Desk Review & Helpful Program Information School Health and Related Services (SHARS) Overview Wrap Up 2 Medicaid Overview Jointly-funded state and federal health-care program An entitlement program that provides health coverage to people with low-income, people 65 and older, and people with disabilities School setting Enroll eligible children in Medicaid program Assist children already enrolled in Medicaid to access the benefits available to them 3 Medicaid Administrative Claiming (MAC) Program Federal reimbursement for the costs of Medicaid administrative activities performed in the school setting Linking students to appropriate Medicaid/health-related services Separate from but complimentary to School Health and Related Services (SHARS) program Centers for Medicare & Medicaid Services (CMS) administers the MAC program at the federal level and reimburses states for allowable outreach activity performed under the MAC program. The Health & Human Services Commission (HHSC) is the Medicaid Single State Agency in Texas (responsible for the administration of the MAC program at the state level). 4 MAC Program Reimbursement for certain medical and health-related outreach, case management and administrative activities surrounding the health services that are delivered. Programs are reimbursed for these activities, regardless of whether the student is Medicaid eligible or not. These services may be to a student or family, and are for activities that include coordinating, referring, or assisting the student/family to access the health-related services. 5 MAC Activities* Activities that improve the access to Medicaid coverage or improve the use of Medicaid covered services, include but are not limited to… Informing Medicaid eligible and potential Medicaid eligible children and families about the benefits and availability of services provided by Medicaid (including preventive, treatment, & screening) including services provided through the Early Periodic Screening, Diagnosis, and Treatment (EPDST) program. Assisting individuals or families to complete Medicaid eligibility application. Scheduling or arranging transportation to Medicaid covered services. Providing translation services for the purpose of accessing Medicaid services. Developing strategies to assess or increase the capacity of school medical/dental/mental health programs. Arranging for any Medicaid covered service that may be required as a result of a specifically identified medical/dental/mental health condition. 6 *Additional examples can be found on the HHSC MAC website To Participate in MAC . . . Complete the following: Intergovernmental Cooperation Agreement Business Associate Agreement Texas Identification Number Application Vendor Direct Deposit Form Vendor Information Form MAC Program Operating Plan Submit original documents. Documents are open-ended. Documents and instructions can be downloaded from the HHSC MAC website 7 Intergovernmental Cooperation Agreement & Business Associate Agreement ISD Agrees To account for activities of staff providing Medicaid administration To submit quarterly participation data through STAIRS To provide expenditure information on a quarterly basis To spend an amount equal to the federal match received on health related services for clients To designate a liaison to work with HHSC Comply with HIPAA regulations HHSC Agrees To pass on to the ISD 95% of Title XIX federal share for Medicaid Administration To reimburse allowable administrative costs at the appropriate Federal Financial Participation (FFP) rate (50% or 75%) To include the ISD expenditures for Medicaid administration in the claim it submits to CMS To designate a liaison to work with the ISD Comply with HIPAA regulations 8 Texas Identification Number Application Formerly known as the TPIN – Texas Payee Identification Number Assigned by the Comptroller’s office for the purpose of identifying any party receiving a payment from the State of Texas. The use of this number on all claims will reduce the processing time required by the State. 9 Vendor Direct Deposit Form Complete form to: Set-up direct deposit for MAC, Change financial institutions, or Change account number or type Section 2 – Leave the boxes blank if you do not have your 11 digit Texas Identification Number Select Texas Health & Human Services Commission as the agency with which you are doing business or leave blank 10 VENDOR INFORMATION FORM The ISD is the vendor. Section 2 (Person Who Will Sign the Contract) must contain the information of the person that signed the Intergovernmental Cooperation Agreement. Send the original, signed form to HHSC. 11 MAC Program Operating Plan Cover page must be printed on district letterhead. All contacts must match in STAIRS. POP includes only: District Contact Information RMTS Coordinator Roles & Responsibilities Contact will agree to terms by initialing section MAC Financial Coordinator Roles & Responsibilities Primary RMTS Coordinator (district employee) Primary MAC Financial Coordinator (district employee) Superintendent Contact will agree to terms by initialing section Authorized Signatures 12 Resubmit documents? Vendor Direct Deposit Form Depository bank, account number, etc changes Must complete form again & submit to HHSC MAC Program Operating Plan Update only “District Contact Information” page & submit to HHSC if one of the program coordinators changes Must update contacts in STAIRS Unnecessary to send entire POP again or any additional documents (organizational chart, description of coordinator’s job functions & responsibilities, etc.) 13 System Contacts Communication is critical Superintendent Random Moment Time Study (RMTS) Coordinator Medicaid Administrative Claiming (MAC) Financial Coordinator School Health & Related Services (SHARS) Financial Coordinator 14 Primary MAC Financial Contact Responsibilities Must be an employee of the district Serve as financial liaison to HHSC and STAIRS Communicate with all key stakeholders (RMTS contact, Special Education department, SSA/Co-op contacts, etc.) Attend MAC financial training for each Federal fiscal year Ensure that the MAC financial data is certified each quarter in STAIRS Ensure the Quarterly Summary Invoice is signed and notarized by the proper individuals Maintain financial documentation and supporting materials Must be listed as the primary MAC Financial Contact on the MAC Program Operating Plan and in STAIRS Ensure all contact information is current and accurate 15 Documentation & Recordkeeping Requirements Participation documents (Contract, MAC POP, etc) The following is a checklist of the minimum documents to collect and maintain quarterly: Financial data used to develop the expenditures and revenues for the claim calculations including state/local match used for certification Copies of computations used to calculate financial costs All revenues offset from the claim, by source Quarterly Summary Invoice (signed & notarized) Roster of eligible individuals, by category, submitted for inclusion of RMTS (Participant List) 16 Documentation & Recordkeeping Requirements (cont.) Information must be available upon request by federal or state Documents must be stored in a readily accessible location & entities. format. Records should be maintained for a period of no less than five (5) years or if an audit has started, the records shall be retained until the audit is completed and all issues are resolved. 17 Training Primary and secondary contacts should be trained for every Federal fiscal year (FFY). Initial and Refresher training options Having more than one trained MAC financial contact is highly recommended. MAC Financial Contact Role Training is from FFY to FFY. Not retro-active Switching Districts Full Access vs. View Only 18 Random Moment Time Study (RMTS) Overview 19 MAC Quarterly Process 1 2 3 4 Participant Identification Random Moment Time Study MAC Financial Data Collection MAC Claim Calculation Determine who performs MAC activities Determine how much reimbursable activity is performed Enter actual costs associated with these activities Reimbursement rates applied to calculate a claim Today’s Main Focus 20 Participant List = Allowable Salary Costs The district identifies eligible participants at the beginning of each quarter via the “Participant List” (PL). Costs reported are “position-specific” not “personspecific.” Substitutes - Individual replacing a provider on leave Direct replacement - Individual hired to fill a vacant position These are the only positions for which financial data can be reported. Positions and categories left off the Participant List cannot report their costs for that quarter. 21 Participant List (cont.) The Participant List drives the number of eligible MAC participants and determines the MAC financial cost eligible. If a Participant List is not certified for a quarter by a district, that district will not be able to participate in RMTS and will not be able to report MAC costs for that quarter. The results of the time study are the basis for the calculation of the administrative time study percentage that is used during the MAC financial process to allocate costs to the Medicaid program. 22 Ineligible Participants: MAC Only Category Overhead costs/indirect costs are captured in the Indirect Cost Rate (IDCR) on the claim Salaries for staff in accounting, budgeting, payroll, human resources, purchasing, and employee relations are generally indirect costs Ineligible participants include: Function 41- General administration Function 53- Data processing services 23 MAC Participation Requirements MAC financial quarters will not be opened unless the following requirement are met: Active contract with HHSC Approved MAC Program Operating Plan Received MAC / RMTS training for the FFY Certified Participant List for that quarter An Intergovernmental Cooperation Agreement must be filed and executed with HHSC in order to enter financial expenditure information. Required RMTS participation must be satisfied for the quarter in which the claim is filed. If you are unable to access the quarter, please contact the MAC team. 24 Important Dates for MAC Federal Fiscal Year 2013 Federal Fiscal Quarter 1st Quarter (Oct – Dec) 2nd Quarter (Jan – Mar) 3rd Quarter (Apr – Jun) 4th Quarter (July – Sept) Financials Open Financials Close February 18, 2013 May 27, 2013 August 19, 2013 November 25, 2013 (6 p.m. CST) April 5, 2013 July 12, 2013 October 4, 2013 January 10, 2014 **Claim must be certified and must upload QSI in the system by deadline.** 25 MAC Financial Data Collection Interim billing is not a MAC requirement Where to enter financial data? Electronic Reporting MAC financial reporting will be completed entirely online via the State of Texas Automated Information Reporting System (STAIRS) located on the Fairbanks LLC website. Who can enter data? Trained MAC Financial Contacts 26 Financial Data District Employee Salaries/Wages Position must be included on the Participant List for that quarter Perform MAC activities Payroll Taxes & Benefits “actual” costs only Contractor Payments Set aside/reserved funds are not actual costs TRS on behalf of payments are not actual costs Position must be included on the Participant List for that quarter Perform MAC activities Federal Revenues (Federal revenues offset expenditures) 27 District Employees Compensation of employees Wages and salaries Subject to federal withholdings Reconcile back to general ledger Example of 9 Month Versus 12 Month Reportable Salary 9 Annual Salary $ 30,000 If paid over 9 months =$30,000/9 =$3,333 x 3 If paid over 12 months =$30,000/12 =$2,500 x 3 $ $ 3,333 Actual Monthly Cost 10,000 Actual Reportable Cost $ $ 2,500 Actual Monthly Cost 7,500 Actual Reportable Cost 28 District Employees (cont.) Quarterly salaries/wages for the individuals on the participant list Federal Fiscal Quarters: October-December, January-March, April-June, July-September Example of 9 Month Versus 12 Month Reportable Salary 9 Annual Salary $ 30,000 If paid over 9 months =$30,000/9 =$3,333 x 3 If paid over 12 months =$30,000/12 =$2,500 x 3 $ $ 3,333 Actual Monthly Cost 10,000 Actual Reportable Cost $ $ 2,500 Actual Monthly Cost 7,500 Actual Reportable Cost 29 Position Specific Example Example: Position #85 had the following employee changes throughout the quarter: Employee A works Jan 1st thru Jan 19th, earns $800. Substitute A works Jan 20th thru Feb 28th, earns $1,200. Employee B works March 1st thru March 31st, earns $1,500. The Total MAC Reportable Expenditure for Position #85 is $800 + $1,200 + $1,500 = $3,500. 30 Detailed Reporting: Payroll Taxes & Benefits Examples of Employer-Paid Benefits: Health Insurance Life Insurance Medicare Employer 403(b) Contribution Liability Insurance Worker’s Compensation Unemployment Compensation Social Security 31 Payroll Taxes & Benefits (cont.) Only Report “True” Expenditures If your district incurs an insurance cost (premium paid), the district is entitled to report the cost incurred during the quarter. If your district is self-insured and pays a third party administrator for claim administration, the district is entitled to report the cost incurred for administrative fees and claims paid during the quarter. Teacher’s Retirement System (TRS) The district should not report any assumed liability such as set-aside funds, the cost should reflect the true expenditures of the district. Only costs to the district are allowable “On behalf of” retirement payments cannot be claimed Please ensure that you maintain documentation that the costs were actually paid by the ISD. 32 Employee vs. Contracted Staff Employee – Full-time and Part-time Providers hired by the district – On payroll Listed on participant list as Full-time employee or Part-time employee Report costs under: “Employee Salaries” and “Payroll Taxes and Benefits” columns and “Federal Revenue” column if appropriate Contracted Staff Not employees of the district – on Accounts Payable Either outside vendor or through SSA/Co-op (fiscal agent) Listed on participant list as Contract Report costs under “Contracted Staff Costs” column and “Federal Revenue” column if appropriate 33 Contracted Staff (cont.) 34 Contracted Staff (cont.) Ensure participant list is up-to-date (employment type is correct) Request breakdown of costs on invoice from the contractor to ensure the number of positions you are claiming and to place the costs in the correct categories 35 Federal Revenues Identify ALL federal funded positions on the participant list. Report (state, local, & federal) position costs in the Employee Salary, Payroll Taxes & Benefits and Contracted Staff columns as appropriate. The Federal Revenue column is used to subtract the Federal portion of costs that were included in the Employee Salary, Payroll Taxes & Benefits and Contracted Staff columns. Example: 36 Federal Revenues (cont.) Federal funds include, but are not limited to: Federal Grants Matching Funds ARRA/Stimulus Funds NOTE: MAC and/or SHARS funds are considered “reimbursement” funds and are not required to be backed out of the MAC financial claim as revenue offset. 37 Federal Revenues (cont.) To maximize federal revenue sources, it is recommended that MAC providers are funded with state/local funds. The system will automatically calculate the Local/State Net Expenditures (Gross Salaries less Federal Revenue). 38 What if my ISD is in an SSA/Co-op? The fiscal agent can only report costs for the students “enrolled” in the district serving as the fiscal agent. All ‘shared’ costs must be allocated to each of the member districts. For example, if a member district contributed 15.75% of the budget, that district would be allocated 15.75% of the paid hours and payroll costs for each staff person. Allocation of costs based on budget contribution is only one way in which a fiscal agent may choose to allocate costs. IMPORTANT: Allocation methodologies used to distribute shared costs to member districts of an SSA/Co-op must be documented and presented to HHSC upon request. Allocation methodologies should appropriately reflect the level of direct service costs associated with the students enrolled in each district. 39 What if my ISD is in an SSA/Co-op? Determination of ‘enrolled’ per TEA … “While it is true that multiple districts may be involved in the provision of special education and related services to a student with disabilities, only one district can report Public Education Information Management System (PEIMS) data on a student, so it is our position that the SHARS-related billing should be through the district that is reporting PEIMS data.” Additional information may be found in the Student Attendance Accounting Handbook (SAAH) at: http://www.tea.state.tx.us/index4_wide.aspx?id=7739&menu_id=645&menu_id2=789 40 Regional Day School Program for the Deaf (RDSPD) If host district reports all the students on their PEIMS data: Host district will report 100% of the salary and benefits of the providers for the RDSPD. Allocation of costs not required Member districts will not report any costs associated with the RDSPD. Contact HHSC regarding district-specific questions. 41 Functional Reporting There are two options to enter financial data: 1. Participant Details • Detailed basis by individual position 2. Group Summary Schedule Detailed Worksheet Psychologists and Interns Bob Employee Joe Employee Mary Contract Staff • Summary of costs by category • Refer to the participant list • Financial detail by position/individual must be kept on file • Enter Total Employees & Total Contractors claimed that quarter Category Summary Registered Nurse (RN) Salaries 30,000 Benefits 6,000 Purchased Svcs. 8,000 42 Financial Tips Refer back to the certified participant list for the quarter. Do NOT make adjustments from prior quarter with current quarter. The participant list is available in advance. Contact HHSC to correct a prior quarter. Not necessary to mail the MAC financial supporting documentation each quarter. However, the district is required to maintain the financial data; and the records must be made available upon request from state or federal entities. 43 Detailed Explanations – System Edits STAIRS is designed to perform various edits checks depending on the data entered. Explanation of variances are required. Provide a concise explanation as to why a costs increased or decreased, etc. Helps find possible errors and allows ISD to correct the current financial report before certifying the data. Contact HHSC if a data entry error occurred in a previous quarter. 44 Example: Quarterly Summary Invoice (QSI) 45 Quarterly Summary Invoice (QSI) Signing the Quarterly Summary Invoice certifies that the following items are true and correct: I am the officer authorized to submit this form; I have examined this statement and to the best of my knowledge and belief, the expenditures included in this statement are based on the actual cost of recorded expenditures; The required amount of State and/or local funds were available and used to pay for total computable allowable expenditures; This statement is of expenditures that the undersigned certifies are allocable and allowable to the State Medicaid program; I understand that this information will be used as a basis for claims for Federal funds and falsification and concealment of material fact may be prosecuted under Federal or State civil or criminal law. 46 Quarterly Summary Invoice (cont.) Have the proper employee of the district sign the Quarterly Summary Invoice (QSI). Per the RMTS/MAC Implementation Guide effective April 25, 2007 pg. 17; Certifier must have signature authority which includes the Chief Executive Officer (CEO), Chief Financial Officer (CFO) Executive Director (ED), Superintendent (SI) or other individual (district employee) designated as the financial contact for the ISD. Printing on letterhead is not necessary. Ensure that the Signer and Notary dates are the same. The notary language on the QSI reads “This instrument was acknowledged before me.” This means that the date signed by the Signer and the Notary must be the same. The Notary should not be writing his/her name in the field marked “Printed Name of Officer of Provider”. The district must keep the QSI onfile. 47 MAC Claim Calculations Cost Pool Cost Pool #1 Cost Pool #2 Net Expenditures Claimable Percentage Claim Amount Total Federal Share 5% Retention Net Claim Direct Service & Admin Administrative Only 48 Claimable Percentage RMTS Results • • State-wide, quarterly Ratio developed for Cost Pool #1 and Cost Pool #2 Medicaid Eligibility Rate (MER) • • District-specific, quarterly Percent of students in district who are Medicaid eligible Unrestricted Indirect Cost Rate (IDCR) • • District-specific, annually Developed by TEA 49 Random Moment Time Study (RMTS) Results Identifies reimbursable and non- reimbursable time. Used to identify the percent of time providers are participating in MAC activities (as well as participating in direct medical services). Each cost pool has separate and different time study percentages. The MAC financial claim is calculated for Cost Pool # 1 and Cost Pool # 2 using their relevant cost and time study percentages. 50 Medicaid Eligibility Rate (MER) The Public Education Information Management System (PEIMS) enrollment data for the current school year is submitted to TEA by each district. The Medicaid eligibility files for each quarterly period is gathered by HHSC. The Medicaid eligibility data is sent to TEA for use in the developing the MER. TEA develops an unduplicated Medicaid eligibility file from the quarterly files provided by HHSC. The unduplicated Medicaid eligibility file is matched against the PEIMS enrollment data. There are 2 matches performed – 1) first is a match based on Social Security Number (SSN), 2) for those who do not match based on SSN, a second run is performed based on first name, last name and date of birth. The total number of matches divided by the total number of enrolled students (by district) becomes the district’s quarterly MER. 51 Indirect Cost Rate (IDCR) Must have an approved IDCR from the Texas Education Agency (TEA) How can your district get an IDCR? Submit an Exhibit J-2, Schedule of Expenditures for Computation of Indirect Costs Located in district’s official audited Annual Financial Report (AFR) A new indirect cost rate must be obtained every fiscal year. Helps ISD recover some of indirect costs CMS approved use of unrestricted IDCR Charter schools that need an IDCR should contact TEA – Division of Federal Program Compliance 52 STAIRS (Fairbanks) System Demonstration 53 MAC Claim Desk Review Utilized to ensure integrity and accuracy of the claim data Discrepancies brought to the attention of primary MAC financial contact identified in the system HHSC will contact ISD requesting explanation, clarification, and/or correction of discrepancies 54 MAC Reimbursement Timeframe for reimbursement MAC reimbursements are Title XIX Medicaid administrative reimbursement funds Not considered ARRA funds Are subject to the Single Audit Act MAC reimbursement is recommended to be used to enhance the provision of health services and/or improve and/or expand the level and quality of health/medical services provided to all students within the district. 55 STAIRS Reminders Passwords will not change each school year. If you forget your password, you can reset it at the log-in screen. Fairbanks can consolidate username/passwords for contacts with multiple ISDs. You will be able to access historical data. Messages (Warnings) are highlighting areas where there may be an issue. All reference material is on the website. Contact Fairbanks regarding system issues. 56 Allowing E-mail Messages Communication is done predominantly via e-mail. Role in Fairbanks dictates what messages you receive. Critical that your district authorize your e-mail system to accept emails from Fairbanks. Confirm with your IT staff to make sure that e-mails with [email protected], @hhsc.state.tx.us, and @tea.state.tx.us extensions pass through firewalls and spam filters. 57 Managing Contacts in STAIRS Primary contacts can… Only one primary contact per role Add and/or delete contacts Assign additional roles to contacts Restrict access of trained contacts Unlimited number of secondary contacts Contact Fairbanks if you are having any issues 58 School Health & Related Services (SHARS) Overview 59 Wrap Up If you are not listed in STAIRS as a contact, then you cannot receive credit for completing this training. There are no certificates for training. You will receive an email thanking you for attending today’s training; however, this does not mean that you received training credit. Training credit can be viewed in STAIRS. Primary contact at the district can add you to STAIRS MUST filter appropriately Can print screen to keep for your records A maximum of 7 days processing time is required after attending training before the session attended will be listed next to the contact’s name and the “status” column will then show full access. Once full access is indicated, you will be able to update/certify the MAC financial data. 60 MAC Website http://www.hhsc.state.tx.us/rad/ Select: Medicaid Administrative Claiming (MAC) Independent School Districts (ISD) MAC Guide Participation Documents Frequently Asked Questions Training Materials Important Notices 61 Additional Resources… CMS Medicaid School-Based Administrative Claiming Guide Office of Management & Budget (OMB) Circular A-87 Title 45 Code of Federal Regulation (CFR) Part 74 and 95 Title 42 CFR 430.1 and 42 CFR 431.15 Title 19 of the Social Security Act, section 1903(a)(7) General information regarding Texas Medicaid Program http://www.hhsc.state.tx.us/medicaid/ 62 Common Acronyms MAC – Medicaid Administrative Claiming SHARS – School Health & Related Services CMS – Centers for Medicare & Medicaid Services HHSC – Health & Human Services Commission TEA – Texas Education Agency HIPAA – Health Insurance Portability and Accountability Act FFP – Federal Financial Participation TIN – Texas Identification Number (formerly known as TPIN – Texas Payee Identification Number) POP – Program Operating Plan RMTS – Random Moment Time Study TS – Time Study PL – Participant List STAIRS – State of Texas Automated Information Reporting System (formerly known as Fairbanks) FFY – Federal Fiscal Year MER – Medicaid Eligibility Rate IDCR – Indirect Cost Rate PEIMS – Public Education Information Management System RDSPD – Regional Day School Program for the Deaf QSI – Quarterly Summary Invoice 63 Contact Information Medicaid Administrative Claiming Ph: (512) 491-1802 Email: [email protected] Yvonne Moorad (Team Lead) Jessica Makdsi Texas Education Agency – Division of Federal Program Compliance Ph: (512) 463-9127 Email: [email protected] STAIRS (Fairbanks, LLC. ) Ph: (888) 321-1225 Email: [email protected] 64