RMTS for LEA Billing—DHCS Hosts Combined Stakeholder Meeting on Oct. 4, 2018

On Thursday, Oct. 4, 2018, the Department of Healthcare Services (DHCS) held the first LEA Billing and School Medi-Cal Administrative Activities (SMAA) combined meeting. Paradigm attended the meeting by webinar and below are the highlights.

There are 2 issues DHCS is still working out with CMS before formally submitting the final version of the SPA, which includes RMTS for LEA Billing, for approval:

1—RMTS notification/response time (this impacts LEA Billing and SMAA)

2—Memorandums of Understanding (MOUs) with Managed Care Organizations (MCOs)

In lieu of the 0/2 RMTS notification, where CMS requested no prior notification of a moment and only 2 days to respond, DHCS presented a 1-day notification and 4-day response time window for RMTS participants to respond. Currently, they are still waiting to hear if CMS will accept this request. DHCS is also in the process of working on an MOU template between LEAs and MCOs to satisfy this CMS requirement. DHCS stated they are still planning for a July 1, 2019 implementation date.

In addition, DHCS indicated they are still sorting out their policy for what type of backup documentation will be required to support RMTS results coded to direct medical services (and used in the cost reconciliation process).

As part of the new SPA, and for the implementation of RMTS for LEA Billing, CMS is requiring a change in the CRCS process and forms. Because these changes are applicable to FY 2015/16 and forward, this means LEAs will need to backcast their cost reconciliation claims for FYs 2015/16, 2016/17, 2017/18, and 2018/19. This also means that DHCS Audits and Investigations (A&I) will be stalled in their normal timeframe for reviewing the cost reconciliation reports starting with FY 2015/16—A&I cannot complete their review until the backcasting is completed.

Lastly, DHCS also announced that beginning FY 2019/20, CRCS claims will be due five (5) months after the close of the fiscal year, as opposed to 17 months after. This means that in the Fall of 2020 California LEAs will be submitting two CRCS claims, one for FY 2018/19 and one for FY 2019/20.