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Quality & Compliance Update |
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April 12, 2019
Intermediate Care Facilities (ICF) Billing Change
Effective July 1, 2019, The
Arc New York Chapters operating Intermediate Care Facilities (ICFs) must comply with billing documentation requirement changes as directed in OPWDD's April 4, 2019 memo.
Claims submission for ICF claims submitted on and after July 1, 2019 are required to include the National Provider Identifier (NPI) of the reviewing physician, as listed on the annual Level of Care Eligibility Determination form. The physician's NPI can be obtained here.
Chapters should provide Accounts Receivable/Billing Department staff with this information to ensure that all ICF claims include the correct NPI.
Federal regulations require that the physician who completed the LCED must also be enrolled in the NYS Medicaid program. Chapters will need to develop a system for routine verification of the physician's enrollment in the Medicaid program. Enrollment can be verified here.
Corporate Compliance Programs and ICF Administrators should work together to identify internal controls that will be implemented to ensure submissions for ICF claims comply with the new requirements. Clear internal controls in this area will help mitigate exposure during future OPWDD or Office of Medicaid Inspector General (OMIG) audits.
"Heightened Scrutiny" Updated Guidance
The Centers for Medicare and Medicaid Services (CMS) released updated guidance to State Medicaid Directors in the form of frequently asked questions. CMS has extended the state transition period to March 17,2022. Through their Site Survey Protocol, OPWDD has been reviewing The Arc New York Chapters for compliance with the Home and Community-Based Services (HCBS) regulations.
The FAQ contains clarification for "Heightened Scrutiny" designated sites that must be identified by site in the public notice. Only those on the grounds, or adjacent to a public institution will need to include the specific address. This is provided OPWDD agrees that including the site addresses may enable some individuals to be identified, thus violating privacy protections.
Another useful clarification is that when an individual's residence is determined to be an institutional setting, it does not disqualify them from receiving HCBS day services (i.e., individuals do not have to reside in HCBS residential settings to receive HCBS day services).
Arc New York Chapters with locations that have been identified as subject to "Heightened Scrutiny" should continue to work towards HCBS compliance for each identified site.
Please contact us if you have any questions regarding any of this information.
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CONTACT:
Josh Christiana
, Associate Executive Director for Quality Improvement & Compliance
This email was sent to:
- Executive Directors
- Chief Operating Officers
- Chief Financial Officers
- Quality & Compliance Staff
- State Office Staff & Trust Managers
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