Retroactive Guidance for California’s SMAA-RMTS Program May Signal Mass Invoice Revisions

**Update, April 20, 2017: DHCS has verbally stated that this new guidance does not supersede PPL 15-012. DHCS is currently drafting a new PPL to outline the process for handling 100% federally funded or ICR time survey participants that were inadvertently included in an RMTS pool; more details will be available once the new PPL is published.**


On March 30, 2017, DHCS sent an email with new guidance regarding staff who were inadvertently included in the SMAA Time Survey Participation (TSP) universe despite ineligibility due to being fully federally funded or part of the Indirect Cost Rate (ICR). According to federal CMS, in this situation, “all related moments should be removed entirely from the computation of the RMTS percentages.”

This means that invoices previously submitted for FY 2014/15 Q3 and Q4 will need to be recalculated and resubmitted if an LEA, or any LEA in their administrative unit (LEC, LGA, or Consortium), had fully federally funded or ICR staff on their TSP list. This policy will also remain in effect for all subsequent invoices.

This new guidance appears to supersede PPL 15-012, which had stated that moments for staff whose funding changed to be fully federally funded mid-quarter could remain in the RMTS calculations. Program rules prohibit fully federally funded or ICR staff from participating in the program; however, human error can occur or a participant’s funding source may change mid-quarter rendering a previously eligible participant ineligible.

While we anticipate that a majority invoices for FY 2014/15 Q3 and Q4 will need to be revised due to this new guidance, we should know as early as next week when LEA and LGA Coordinators are scheduled to notify DHCS if their administrative unit is impacted.