Effective upon the date of the MA Update issuance by the Division of Health Care Financing (DHCF), this memo provides direction to county agencies and tribes regarding claims for Medicaid (MA) Targeted Case Management (TCM). Addressed in the memo are instructions regarding:
This numbered memo replaces the joint Information Memo #2001-11, which became effective on July 1, 2001, by the Division of Children and Family Services (DCFS) and Division of Health Care Financing (DHCF) based on requirements associated with and analysis of the following factors:
TCM Claiming by Placement Status and Case Type
Child welfare services include a range of services to children, youth and families who enter into the child welfare service system presenting a variety of concerns. Administrative costs associated with providing services to child protective and juvenile service clients, served in-home or with out-of-home placement, may be covered by Title IV-E and TCM. Currently, the Department uses a cost allocation method to claim both Title IV-E and TCM based on the results of the Random Moment Time Study (RMTS). The
Department claims Title IV-E reimbursement for costs associated with allowable activities for all Title IV-E eligible cases, both child protective and juvenile services, provided to both in-home and out-of-home care cases. As indicated in Information Memo #2001-11, the Department continues to claim TCM for all cases where the child or juvenile has been determined to be ineligible for Title IV-E and is in out-of-home placement.
However, fee-for-service TCM claims have been and can continue to be made for allowable activities provided to both child protective and juvenile service target populations as defined by the DHCF. These activities can be performed by certified private providers under contract with the county agency or by non-child welfare county agency staff, e.g., 51.42 or long-term support staff, for both in-home cases and cases where the child is in placement and has been determined to be Title IV-E eligible. Based on the current draft of the DHCF MA Update, activities allowable for TCM reimbursement in child placement cases where the child has been determined to be Title IV- E eligible must be related to the coordination of medical services (Attachment #1). Clarifications presented in this document are based on the direction provided by the federal Center for Medicare and Medicaid Services (CMS), formerly known as HFCA, in January 2001. Under this federal directive, CMS has instructed state Medicaid programs that MA claims may only include coordination and monitoring services not covered by Title IV-E for children who are eligible for Title IV-E. As such, the DHCF has defined these allowable case management activities as those pertaining to medical services as covered by Wisconsinís Medicaid program.
Attachment #2 provides an overview of various case scenarios to depict potential TCM claiming by the Department, county agencies or private providers for allowable activities to eligible clients based on placement status and case type.
Determining Title IV-E Eligibility Status
County child welfare agencies and the BMCW are currently responsible for the following Title IV-E activities:
Consistent with DCFS Memo Series 2000-09, currently thirty-four counties and the BPP Adoption Program rely on the stateís Centralized Eligibility Unit (CEU) for assistance in compiling required documentation and recommending an initial determination or re-determination of a childís Title IV-E eligibility status. Documentation of the initial Title IV-E determination and all subsequent re-determination(s) must be maintained in the clientís case record.
Recent federal policy indicates upcoming restrictions to Title IV-E eligibility for court-ordered kinship care cases (Attachment #3). Currently, the Department submits Title IV-E claims for allowable administrative costs under the RMTS. Pending any other state policy changes, beginning October, 2002, these cases will become ineligible for Title IV-E reimbursement; at that point, the Department will use the RMTS to claim TCM on these cases as they will become ineligible for Title IV-E.
Local Personnel Master File
A directory of county agency and Bureau of Milwaukee Child Welfare (BMCW) child welfare service staff is maintained in the stateís Local Personnel Master File (LPMF). County agencies and BMCW are responsible for updating the LPMF on a monthly basis to reflect current agency staff dedicated to a variety of functions, including child protective service and juvenile justice staff. A sample is drawn from this directory on a quarterly basis for the RMTS and serves as the basis for RMTS contacts regarding staff activity.
In order to avoid double billing both TCM and Title IV-E and loss of revenue for the state and local county child welfare agencies, it is critical that the RMTS sample is inclusive of all child welfare service staff and reflects current staffing of the county agencies and the BMCW. For purposes of continued reporting to the LPMF, child welfare staff, including administrative, supervisory, professional and paraprofessional, associated with the following casework or service functions must be reported in the LPMF:
While private provider staff are not in the LPMF, in cases where the Department is making a TCM claim for a given month or months through the RMTS for costs associated with case management, no other provider(s) may simultaneously claim reimbursement for allowable activities during that same time period.
The State MA Plan amendments have received federal approval and serve to clarify the population for which TCM will be claimed using the Departmentís RMTS cost allocation methodology. This population includes all children in placement who are determined to be ineligible for Title IV-E. While the Department continues to claim TCM via the RMTS consistent with the Information Memo #2001-11, directions pertaining to fee-for service TCM claiming provided in this memo are effective as of issuance of the MA Update by DHCF. This clarification recognizes the continued capacity for local child welfare agencies or private providers to claim TCM for allowable activities not already covered by Title IV-E to Title IV-E eligible clients. Allowable activities, client eligibility by target population, and documentation requirements are addressed in the DHFS Medicaid and BadgerCare Information for Providers handbook under "Case Management Services" and can be found at the Departmentís website, http://www.dhfs.state.wi.us/medicaid/index.htm
Thank you for your continued efforts to work with our Divisions to identify and implement funding alternatives and to maximize resources available within local county agencies and across the state.
Attachment 1: Case Management Services (pdf-9 kb)
Attachment 2: Case Scenarios (pdf-13 kb)
Attachment 3: Clarifying
Guidance Regarding Candidates for Foster Care