Exciting Changes Proposed for California’s LEA Direct Billing Program

In late September 2015, DHCS released a copy of their draft State Plan Amendment (SPA 15-021) which proposes several changes to the LEA Medi-Cal Billing Option program.

If approved, the SPA includes several exciting additions that will impact California’s participating school districts, including: newly eligible services, practitioners types, and a revised method for capturing time spent performing services during the annual cost settlement process.

CMS generally has 90 days to respond with some form of feedback from the date a SPA proposal is submitted. Following this timeline, there should be more information about the proposed SPA after January 1, 2016.

New Services

The proposed added services listed in the draft SPA are:

• Personal Care Services
• Respiratory Care Services
• Nutritional Services
• Orientation and Mobility Services
• Infant Developmental Program

Although those EPSDT services under the purview of free care (general education assessments and treatments) are already included in California’s State Plan, this SPA does eliminate the currently imposed 24 total services combined limitation. The only “limitation” will be medical necessity.

Regarding transportation, the SPA requests that school buses that are equipped with lifts, ramps, and/or restraints be added as a qualified vehicle.

New Practitioners

In addition to added services, this SPA also request the following provider types be added to the list of eligible practitioners:

• Personal Care Assistants
• Registered Dietitians
• Certified Occupational Therapy Assistants (COTAs)
• Physical Therapy Assistants (PTAs)
• Speech-Language Pathology Assistant (SLPAs)
• Registered Marriage Family Therapist Intern

New Time Capture Method

As part of a previous agreement with CMS, California committed to incorporating Random Moment Time Survey (RMTS) into the LEA Billing program’s annual cost settlement process (the CRCS). RMTS is currently in use in the school-based Medi-Cal administrative activities program (MAA) and it uses a random sampling to capture the amount of time spent by staff performing various activities, including direct medical services.

The SPA proposes a transition to utilizing the direct medical services RMTS time percentages as the time component for the LEA Billing Option programs cost settlement process. Additional details on how integration with RMTS would unfold are still being discussed by the DHCS’s Implementation Advisory Group, likely pending approval of the SPA.