DHCS Submits Proposal Outlining the Implementation of RMTS for FY 2014/15 and “Reasonableness Test” Criteria for Approving Deferred School MAA Claims

On August 15, 2013 the California Department of Health Care Services (DHCS) submitted two documents aimed at resolving the ongoing school MAA program (SMAA) deferral and new plan development process to the federal Centers for Medicare and Medicaid Services (CMS).  A formal update posted to the Department’s website earlier this week provides a thorough review of the current issues and summary detail of the two proposals that were submitted on August 15:

  • Milestones – This document, referred to as the ‘milestones document,’ had been requested by CMS as grounds for approving an interim claiming process for the current fiscal year, as well as to “ensure progress toward moving to Random Moment Time Study (RMTS) and releasing the deferrals.” The document outlined steps toward developing:
    1. a revised statewide claiming plan and new time study methodology based solely on RMTS beginning in FY 2014/15; under this new plan, the 5-day worker log will be eliminated as a method for time study,
    2. a way to reconcile schools’ interim claims for FY 2012/13 and FY 2013/14 using RMTS, and
    3. a reasonableness test to be applied to outstanding deferred claims.


  • Reasonableness Test Criteria – DHCS submitted two reasonableness tests to CMS and is working to answer their questions and reach a swift agreement on which test to implement. Following this, the processing of deferred claims – which stalled in January of 2013 – can resume for the more than 800 school districts and claiming units that have been without reimbursement for more than a year. LEAs will also have the opportunity to see exactly which stage of the process their deferral certification is in when the Department releases a progress report on the individual certifications, expected on August 30, 2013.


CMS must still approve the milestones and reasonableness test proposals before any movement can occur, but the formal – and transparent – submission of this documentation by the Department is a big step in the right direction.

While California LEAs continue to wait for instruction on what will be expected of them in order to maintain funding for their Medi-Cal outreach programs this year, the Department’s recent program update seems to show collaboration by the state and federal agency to ensure that schools receive reimbursement for the current fiscal year and that the SMAA program continues without disruption during the transition to RMTS.


Read More
Read the complete SMAA Program update, posted to the DHCS website on Wednesday, August 20…
View our complete Issue Analysis on the SMAA deferral…
View our complete Issue Analysis on RMTS in California…