Issue Analysis

California’s LEA Medi-Cal Billing Option program could transition to the use of Random Moment Time Survey (RMTS) as early as July 2017. The transition is contingent on the approval and implementation of State Plan Amendment 15-021.

The use of RMTS for school-based services billing programs is a common nationwide practice. Under this system, RMTS percentages are used to determine the amount of time spent by school practitioners performing eligible services throughout the year when completing the annual Cost & Reimbursement Comparison Schedule (CRCS).

Health service still need to be documented according to program standards and all indications are that the interim billing and reimbursement process will continue unchanged.

In June 2014 the federal Centers for Medicare and Medicaid Services (CMS) notified California that it would have to transition the LEA Billing program to RMTS as a condition of approval for the state’s new SMAA RMTS program, ending a years’ long deferral of that program. California’s SMAA program transitioned from a worker log time survey to the RMTS in January 2015, but the transition of the LEA Billing program to RMTS has taken additional time and planning, including an ongoing amendment to California’s state Medicaid plan which requires federal approval before the process can begin.


History

  • June 2014CMS notifies California that it will have to transition the LEA Billing program to RMTS as a condition of approval for the state’s new SMAA RMTS program, which effectively ended a years’ long deferral of that program.
  • February 2015 – DHCS launches an advisory committee of LEA Billing program stakeholders to help advise the Department on the development, approval, and execution of RMTS for LEA Billing and the State Plan Amendment required to facilitate this process. The group is known as the Implementation Advisory Group (IAG).
  • September 2015 – DHCS submits the first draft of State Plan Amendment (SPA) 15-021, which includes a transition of the LEA Billing program to RMTS as part of the cost settlement process. This officially kicks off the review and revision process with federal CMS that will continue until a final plan is agreed upon and approved.
  • February 2017 – DHCS releases FAQs on the pending implementation of RMTS for the LEA Billing program in their 2016 Fall Training FAQs (pertinent content begins on page 12).
  • February 2017 – DHCS and the state’s consultant, Navigant meet with the IAG and members of Local Educational Consortia (LEA) and Local Governmental Agencies (LGA) to discuss the implementation of RMTS for the LEA Billing program.

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