July 26, 2023 DHCS LEA Billing Stakeholder Meeting: Highlights and Updates
On July 26, 2023, the DHCS LEA Billing Stakeholder meeting took center stage, paving the way for a promising new fiscal year. While the agenda was packed with critical updates, we've compiled a summary of the most noteworthy information to keep you in the loop.
Immediate Updates Impacting Day-to-Day LEA Billing Business:
Erroneous Payment Correction (EPC) for Students with Unsatisfactory Immigration Status (UIS): Earlier this month, DHCS processed an EPC to correct payments made on students with UIS from July 16, 2021, to June 30, 2022. It’s important to note that the annual CRCS is cost-based, so while this EPC will result in adjustments to the 2021/22 CRCS (lowering the total paid interim claims), it does not change an LEA’s maximum reimbursable amount. This is good news! However, DHCS mentioned that there is one remaining back-end change that may prompt another, albeit minor, EPC on students with UIS in the future.
ERMHS/ERICS Update: In August of 2022, DHCS issued an email stating that ERMHS/ERICS are not reimbursable through the LEA Billing program. Advocacy efforts from stakeholders, including Paradigm, encouraged DHCS to leave the issue open for discussion, and they committed to working with Centers for Medicare and Medicaid Services (CMS) to address concerns. In this meeting, DHCS indicated that the issue is still unresolved but is actively being worked on.
Updates from Audits & Investigations (A&I):
A&I representatives provided full transparency on the CRCS audit process during the second half of the meeting, and we commend their efforts. If you're a Paradigm client and would like to revisit our walk-through of the audit process that was offered during our past Education Series, we encourage you to log in to your account to access the resource.
A&I also shared their estimated timelines for auditing back-casted CRCSs and the most recent 2021/22 CRCS:
2015/16 – 2017/18: Audits likely to start in Fall 2023
2018/19 – 2019/20: Audits likely to start in July 2024
2021/22: Audits likely to start in Late 2023/Early 2024
Noteworthy Updates on LEA Billing-Adjacent Topics:
All-Payer Fee Schedule: As part of the Children and Youth Behavioral Health Initiative (CYBHI), California's 2023/24 Budget allocated $10M for DHCS to implement a third-party administrator (TPA) to maintain a school-linked provider network and facilitate claims processing. This TPA will act as the intermediary between schools and MCPs, simplifying the process for LEAs, similar to the LEA Billing program. Paradigm will be ready to assist its clients once the new fee schedule is in place, which is expected for January of 2025.
Before January 2025, however, a small “learning cohort” of LEAs will be selected to participate early. The purpose of this cohort is to help the workgroup, the selected TPA, and MCPs get ready for full implementation. COEs are being asked by DHCS to assist with selecting LEAs for the cohort, which will be dependent on a few different factors. What was shared on Wednesday is that decisions on cohort participants should be made by November of 2023.
CYBHI Capacity Grants: Another CYBHI work-stream aims to release grant funding to help LEAs set up infrastructure related to behavioral health and substance use services. Wednesday’s meeting confirmed that the grants will be administered by a single lead COE, who will work with other COE partners to select and facilitate the transfer of funds to LEAs for the Capacity Grants. We eagerly await more information, which should be available late August or early September.
In conclusion, the DHCS LEA Billing Stakeholder meeting on July 26, 2023, provided valuable insights into the current state and future prospects of behavioral health services in California schools. From addressing payment corrections for students with unsatisfactory immigration status to discussing the intricacies of the audit process, the meeting covered critical aspects that impact LEAs across the state. Additionally, updates on the Children and Youth Behavioral Health Initiative, including the implementation of an all-payer fee schedule and capacity grants, promise to revolutionize access to vital services for students. As we look ahead to a brighter future for behavioral health in schools, we remain committed to supporting and empowering educational institutions on this transformative journey. Together, we can make a lasting difference in the lives of students and enhance the overall well-being of our communities.