The New York State Office of the Medicaid Inspector General (OMIG) has issued a Medicaid compliance alert warning health care providers that it is important to consider new and developing reimbursement program requirements in their Medicaid compliance program risk assessments. Risk assessments must be part of any compliance program required under New York State’s Medicaid program. New and developing Medicaid reimbursement and payment systems (e.g., capitation, value based payments, etc.) create the potential for additional program integrity concerns regarding Medicaid billing and payment. OMIG recommends that those risks be considered as part of an operating compliance program. The OMIG compliance alert on assessing risks of new Medicaid reimbursement and payment systems is available online.
2017 State Agency News
2017 State Agency News
December 29 – New OASAS Operating Certificates
OASAS’ Certification Bureau will be issuing new operating certificates next week to all programs effective 1/1/18. The expiration date of the Operating Certificate has been removed and replaced with the anticipated re-certification review date, as Operating Certificates do not expire and remain in effect until the Office takes an action against it. Programs that have received a re-certification review recently and are still working to complete the Corrective Action Plan or are in need of a new fiscal viability or those who will be reviewed in the near future, will not receive a new operating certificate until the renewal is finalized. If you have any questions regarding this change, please send them to Certification@oasas.ny.gov.
December 22 – DOH Guidance: Medicaid Members May Not Be Enrolled in Both FIDA and Health Home
Effective January 1, 2018, Medicaid Members enrolled in a FIDA Plan are excluded from enrollment in the Health Home Program. Outreach for Medicaid members enrolled in a FIDA Plan must also be discontinued. Please review the attached guidance for additional information.
December 5 – New Bureau of Social Determinants of Health
The Office of Health Insurance Programs (OHIP) has announced the establishment of the Bureau of Social Determinants of Health within the Division of Program Development and Management (DPDM). New York’s Medicaid program is a national leader in its work on the social determinants of health and its investment in supportive housing. Therefore, OHIP has decided to dedicate an entire bureau to focus on this important topic.
The new bureau will focus its work on the social determinants of health (SDH) and the important role it plays in the health outcomes of New York’s most vulnerable populations. The Bureau of Social Determinants of Health will focus on special SDH initiatives including but not limited to supportive housing, nutrition, and education. The bureau will work closely with Performing Provider Systems (PPS), VBP contractors, Health Plans, and Providers. It will also continue to enhance the role of Community Based Organizations (CBOs) within the health care sector. The Bureau will be led by Denard Cummings and report to Elizabeth Misa, Deputy Medicaid Director.
October 31 – October Medicaid Update Posted
The Office of Health Insurance Programs of the New York State Department of Health has approved the release of the October 2017 Medicaid Update. Please find the full current issue as a PDF (Portable Document Format) file available to be downloaded at: https://www.health.ny.gov/
October 30 – “In Lieu of Services” Guidance
The DOH website under Managed Care, Information for Health Plans, now includes some new guidance re: ‘in lieu of services’. Below are the links to this document:
- Medicaid Managed Care Guidance and Application to Offer Cost-effective Alternative Services (In Lieu of)
October 19 – Guidelines for Medical Necessity Criteria
NYS is pleased to announce the Guidelines for Medical Necessity Criteria for the Six New Children’s Specialty State Plan Amendment (SPA) Services and Utilization Management (UM) Grid for State Plan and Demonstration Services for Medicaid Managed Care Plans.
The purpose of the Guidelines for Medical Necessity Criteria (MNC) and Utilization Management grid is to provide a framework for Plans to develop their MNC and policies and procedures regarding utilization management. Plans’ MNC should not be more restrictive than the guidelines proposed by NYS.
October 4 – Children’s Medicaid Transformation Transition Plan & Stakeholder Feedback
The NYS DOH and its State Agency partners hosted a webinar on September 29 on the Children’s Medicaid System Transformation Draft Transition Plan and Stakeholder Feedback. Slides from that webinar are posted on the DOH website.
September 30 – September Medicaid Update Posted
The Office of Health Insurance Programs of the New York State Department of Health has approved the release of the September 2017 Medicaid Update. Please find the full current issue as a PDF (Portable Document Format) file available to be downloaded at: https://www.health.ny.gov/heal
September 11 – Naloxone Information
The NYS DOH has distributed to pharmacies information on their Naloxone Co-Payment Assistance Program. Information about this and other Opioid Overdose Prevention Program initiatives can be found at https://www.health.ny.gov/
September 8 – OASAS Memo Outlining Addiction Staff Roles
OASAS has released a memo clarifying the role of certified recovery peer advocates, certified addiction recovery coaches, and interventionists who provide addiction services. The memo clarifies the status, scope of practice, and responsibilities of these individuals working in the addiction field and identifies a pathway for lodging a complaint against one of these support staff that may be working outside of the scope of their legal authority.
September 4 – OMIG Issues Medicaid Compliance Alert on Risks of New Reimbursement Systems
August 28 – NYS OMIG Posts Compliance Program Assessment Results
As part of its ongoing efforts to provide information and guidance to the state’s Medicaid provider community, OMIG posted on its website Compliance Program Assessment Results January 2015 through June 30, 2017 (Results). The Results detail statistics that identify the percentage of times OMIG observed, in the course of compliance program reviews, required providers to be insufficient in meeting any of the requirements under each of the eight elements of a mandatory compliance program.
The Results can serve as a valuable tool for required providers to assist their efforts in targeting areas where additional focus can be placed when doing self-assessments of their compliance program, operating their compliance programs, as well as developing compliance work plans and risk assessments. Other resources on OMIG’s website that can help a required provider complete its self-assessment of its compliance program are the Compliance Program Self-Assessment form and the Compliance Program Review Guidance.
If you have any questions, please contact OMIG’s Bureau of Compliance at (518) 408-0401 or firstname.lastname@example.org.
July 24 – Health Home Monitoring Revised Policy
On April 15, 2017 the Department issued the Health Home Monitoring: Reportable Incidents Policies and Procedures and Reporting Timeframes Policy. The Department has conducted an on-going assessment and evaluation of the policy requirements and workload for Health Homes and network Care Management Agencies. Based on this assessment, the Department has further revised the policy in an effort to reduce unnecessary workload for Health Homes. Effective immediately, submission to the Department by Health Homes will include the Initial Incident Report only. No further reporting or member specific documentation will be required unless otherwise requested on a case-by-case basis by the Department. This change applies to all previously reported incidents. The new Health Home Monitoring: Reportable Incidents Policies and Procedures (Policy number: HH0005) is now available. If you have any questions or require assistance, please contact Tracey Camilli at (518) 474-9575.
July 22 – NGS Medicare Will Soon Reject Handwritten Claim Forms
Beginning August 7, 2017 for upstate providers (localities 03 and 99) and October 9, 2017 for downstate providers(localities 01, 02 and 04) all handwritten claims submitted to NGS Medicare will be returned to providers with a note attached stating that a new claim will need to be submitted. All submitted, or resubmitted, claims after these dates will need to be either printed (not handwritten) paper claims or electronically submitted claims.
Providers who wish to continue to submit paper claims may do so as long as they are printed and as long as the only handwriting included in the claim is in a signature field. Software programs are available that will allow providers to print information into a CMS 1500 form. You can find a number of these programs by performing a Google search for CMS 1500 form fillable software.
Alternatively, providers can submit electronic claims through a variety of software programs or directly through NGSConnex by clicking here. There is no charge to use NGSConnex, a web-based self-service portal, and the only requirement for its use is that you have internet access.
July 6 – OMH Releases Telepsychiatry/Telemedicine Guidance
OMH has released final guidance for OMH-licensed providers who wish to contract with telepsychiatry/telemedicine companies for distant/hub services. It is OMH’s intent that this will further expand the pool of available practitioners. Programs approved for telepsychiatry and seeking to enhance psychiatry services via a contract with a private telepsychiatry/telemedicine company must submit a regulatory waiver request. While the waiver will allow for practitioners that are employed by the telepsychiatry companies to be located in a private office or an office in their home, the location of the office or home must be within NYS. Upon reviewing the guidance document please direct any questions to your local OMH Field Office and/or to Amy Smith at (518) 474-5570.
June 28 – June Medicaid Update Posted
The Office of Health Insurance Programs of the New York State Department of Health has approved the release of the June 2017 Medicaid Update. Please find the full current issue as a PDF (Portable Document Format) file available to be downloaded at: https://www.health.ny.gov/health_care/medicaid/program/update/2017/jun17_mu.pdf.
June 28 – OMH Managed Care Update – June 2017
Behavioral Health (BH) Value Based Payment Readiness Program
- Frequently Asked Questions for the BH VBP Program have been posted on the OMH website.
- The period for submitting the Notifications of Interest has closed. OMH and OASAS would like to thank all providers who have participated in this process. The program application will be released shortly. Please visit the VBP Readiness program for more information and updates as they are posted.
- Please also see the webinar on forming an Independent Practice Association (IPA) hosted by MCTAC earlier this month.
Assisting with Health and Recovery Plan (HARP) Enrollment: Guidance for Providers
New York State (NYS) has issued a memorandum to help providers and advocates identify and assist with Health and Recovery Plan (HARP) enrollment for eligible individuals. The attached document provides the following information:
- Overview of the Health and Recovery Plan (HARP)
- HARP eligibility
- Reasons why a HARP-eligible individual may not be enrolled in a HARP
- How behavioral health providers and advocates may assist a HARP-eligible individual enroll in a HARP.
Licensed Behavioral Health Practitioner (LBHP) Benefit Webinar
Join MCTAC and State partners for a webinar on the Licensed Behavioral Health Practitioner (LBHP) Benefit onThursday, June 29th from 3-4 pm.
The LBHP benefit reimburses OMH licensed Part 599 clinics for the provision of offsite clinic services to Medicaid managed care enrollees. This benefit is applicable to both child and adult serving OMH clinic providers.
UPDATE: CMHA Now Billed Directly to eMedNY
On March 27th, 2017, New York State distributed guidance regarding a process change for billing the Community Mental Health Assessment (CMHA). Care Management Agencies (CMAs) will now be able to bill NYS Medicaid directly through the eMedNY system for assessments. Please see the original guidance attached to this update for more information.
PSYCKES Utilization Review Reports for VBP
OMH and MCTAC have worked closely with the PSYCKES team to pull together reports that will better align providers to be ready for the shift to Value Based Payment. These reports will allow provider agencies to view distributions of:
- Other agencies providing services to your Medicaid clients by service type
- Volume and type of Medicaid services provided by any agency to your agency’s clients, and
- Medicaid Managed Care plans and product lines for Medicaid clients served by your provider agency
Watch the MCTAC webinar on PSYCKES Utilization Reports for more information.
Upcoming NYS BH Managed Care Plan/Provider Roundtables:
- The next New York City Plan/Provider Roundtable is Tuesday, July 11th at 10:30 a.m.
- The next Rest of State Plan/Provider Roundtable is Tuesday, August 8th at 10:30 a.m.
May 22 – OASAS Letter re: “Auto-waiver”regarding admission and discharge documentation for providers operating multiple bedded programs
Providers operating multiple bedded programs have requested waivers in order to facilitate intra-agency clinically justified patient transfers between modalities with reduced documentation for admissions and discharge. Moving patients from one level of care to another as part of the same episode of care is clinically sensible, however, it is not accommodated by OASAS’ current reporting and regulatory requirements.
Therefore, while OASAS develops amendments to regulations they have released a letter outlining the rules that will apply only to providers operating multiple bedded programs (816 crisis,818 inpatient rehab, 819 and 820 residential services).
May 15 – HCBS Providers: Short Term Crisis Guidance Released
NYS has issued guidance on utilization management for Short-term Crisis Respite and Intensive Crisis Respite, which are currently available within Adult Behavioral Health Home and Community Based Services. All HARP enrolled members and HARP eligible members enrolled in a HIV SNP are eligible to receive these services. Prior authorization is not required for access to these two crisis services, whether the provider is participating or not participating with the health plan. However, providers should notify MMCOs of admissions when they occur.
Read the full memo issued by NYS here.
May 2 – April Medicaid Update Posted
The Office of Health Insurance Programs of the New York State Department of Health has approved the release of the April 2017 Medicaid Update. Please find the full current issue as a PDF (Portable Document Format) file available to be downloaded at:https://www.health.ny.gov/health_care/medicaid/program/update/2017/apr17_mu.pdf.
April 17 – March Medicaid Update Posted
The Office of Health Insurance Programs of the New York State Department of Health has approved the release of the March 2017 Medicaid Update. Please find the full current issue as a PDF (Portable Document Format) file available to be downloaded at: http://www.health.ny.gov/
April 6 – FAQs re: NYS OMH Licensed BH Practitioner (LBHP) Benefit
OMH has released a document containing answers to Frequently Asked Questions (FAQs) regarding the NYS OMH Licensed Behavioral Health Practitioner Medicaid Managed Care Benefit (LBHP).
March 30 – HH UPDATE: Clarification Regarding HHSC Processes & Contact w/ DOH
DOH has updated the following two guidance documents to ensure that HHs and CMAs are properly contacting the DOH HHSC team to track and document the children enrolled with an IDD or a child in foster care that needs to be enrolled with a non-VFCA.
March 29 – Expansion of FIDA to Suffolk and Westchester Counties
The NYS Department of Health (NYSDOH) announced the expansion of the Fully Integrated Duals Advantage (FIDA) Demonstration to Suffolk and Westchester Counties. Eligible individuals can enroll now through NY Medicaid Choice.
The FIDA Demonstration was originally approved to run January 1, 2015 through December 31, 2017. In November, it was extended through December 2019. NYSDOH and the Center for Medicare and Medicaid Services (CMS) are committed to delivering maximum integration of care to dual eligibles to help ensure all medically necessary services are provided, care in the community is promoted, and avoidable hospitalizations and nursing facility stays are reduced.
March 28 – Bureau of Narcotics Enforcement & Mandatory Prescriber Education
The NYSDOH Bureau of Narcotics Enforcement (BNE) has released an FAQ regarding the Mandatory Prescriber Education requirement for controlled substances. Included is a Q&A on how prescribers are to attest to having taken the 3 hour course using Health Commerce System (HCS) accounts.
March 15 – Uniform Clinical Network Provider Training
Uniform Clinical Network Provider training is available to Article 31 and Article 32 behavioral health providers as part of the NYS Medicaid Managed Care Program. This training is a unified state-of-the art web-based training for Medicaid managed care network providers in clinical core competencies and evidence-based practices for mental health and substance use disorder services.
Below is information relevant to the registration and trainings available in the CPI Learning Management System (LMS).
NYC, LI and Westchester regions:
- Providers were asked to register Article 31 and Article 32 clinics by December 31, 2016. If you have not already registered, the enrollment survey is on the CPI website: www.practiceinnovations.org. Registration information will follow from CPI.
- Once registered, trainings are available in the CPI learning management system (LMS). Providers are encouraged to complete these trainings by March 1, 2018.
Rest of State regions:
- Providers are now invited to register Article 31 and Article 32 clinics. The registration period will continue until June 1, 2017 through the enrollment survey on the CPI website.
- Once registered, providers will have until June 1, 2018 to complete these trainings.
March 9 – DOH on Health Home & HARP
Effective March 7, 2017, the Community Mental Health Assessment will no longer be required for HARP Medicaid Managed Care Plan Members. As you are aware the current workflow requires the NYS Eligibility Assessment followed by the Community Mental Health Assessment completed within 90 days. As a result of this change the NYS Eligibility Assessment is all that is required effective immediately. Revised guidance is imminent but please do not wait for the formal guidance to message this change to your CMAs.
Additionally the Department is working on guidance to address the payment backlog for assessments completed by CMAs. This guidance is also imminent and for an interim period effective April 1, 2017 CMAs will be allowed to direct bill eMedNY for assessments completed retroactively in NYC from 10/1/15 and 7/1/16 for ROS. This interim billing process will continue and will be revised with Health Home Payment in October 2017.
March 8 – NYS Law re: DEA Licensed Prescribers and Required Pain Management Course
The NYS DOH has released guidance related to the law enacted last year which takes effect July 1, 2017 requiring all prescribers with a DEA license to complete a 3 hour course in pain management and some additional areas every three years.
February 8 – Executive Budget and Global Cap Webinar
The PowerPoint presentation from the DOH’s 2017-18 Executive Budget and Global Cap Update webinar and the 2017-2018 Executive Budget Scorecard are now available on the NYS Department of Health website.
February 1 – January 2017 Medicaid Update Posted
The Office of Health Insurance Programs of the New York State Department of Health has approved the release of the January 2017 Medicaid Update. Please find the full current issue as a PDF file available to be downloaded at: https://www.health.ny.gov/
January 25 – OASAS Peer Services Guidance FINAL Draft
The NYS OASAS Division of Practice Innovation and Care Management (PICM), in cooperation with the Recovery Bureau and Clinical Advisory Panel (CAP), have developed a guidance document to assist the provider community in the use of Peer Advocates as part of SUD Outpatient treatment. The Peer Guidance Document is intended to delineate the role of peer advocates, provide information on the certification process, give information on reimbursement, and give examples of how peer services might be used. Questions regarding this document can be e-mailed to the PICM mailbox at PICM@oasas.ny.gov.
January 13 – OASAS regarding Youth Medicaid Redesign
The State Partners (OASAS, DOH, OMH and OCFS) have been working on preparing submission of the State Plan Amendment and the 1115 Waiver to CMS. Approval of these submissions is necessary for the State’s plan to proceed. In light of changes at the Federal Level, it has been decided to hold our 1115 Waiver while we get clarity on any impact on our proposal. The two SPA’s have been submitted. These relate to adding the six new plan services that have been proposed.
The State has also decided to move forward on several aspects of our preparation so that we can implement as soon as possible. We are continuing to solicit applications for Designation as a new SPA service. We have moved the application due date to April 1.