As a result of a federal directive, the Wisconsin Department of Health and Family Services (DHFS) is preparing to consolidate the Social Services Random Moment Time Study (RMTS) and the Community-Based Medicaid Administrative Claiming (CBMAC) RMTS into a single time study instrument, the Human Services Random Moment Time Study (HS RMTS). DHFS will be implementing the HS RMTS beginning April 1, 2004. This memo is intended to provide counties with information regarding the transition to the HS RMTS.
Counties currently participating in the CBMAC program should complete the attached 2004 Administrative Claiming Agreement and return to DHFS as soon as possible. Counties that want to begin participating in the CBMAC program effective April 1, 2004, should also complete and return the agreement. Additional information about the CBMAC program may be found in DSL Memo Series 2002-24 Community-Based Medicaid Administrative Claiming (CBMAC).
The Department of Health and Family Services (DHFS) operates Random Moment Time Study (RMTS) sampling processes to allocate time and costs for federal reimbursement consistent with OMB A-87 for:
Although the Random Moment Sampling and federal funds claiming processes are mutually exclusive, concerns were raised by county staff related to the efficiency of multiple time studies conducted by the DHFS. Similar concerns were raised by the U.S. Department of Health and Human Services Division of Cost Allocation (DCA) related to the potential for confusion between the two time studies and a misunderstanding of the program structures, and mutual exclusivity. As a result of these concerns, DHFS has agreed to consolidate the SS and CBMAC RMTS into a single time study instrument, the Human Services (HS) RMTS effective April 1, 2004. The intent of the consolidation is to alleviate the concerns of DCA regarding the operation of multiple time studies in counties, to eliminate potential misunderstanding between the IV-E and MA claiming processes, and to streamline the processes for sampling county staff for time study purposes.
Over the past several months, DHFS staff have met with a workgroup of county representatives to obtain input and feedback on the approach to consolidate the SS and CBMAC RMTS into the HS RMTS. The workgroup has provided valuable assistance in the development of the time study instrument and the instructions that will be distributed to all counties. This process is expected to continue over the next several months as implementation of the HS RMTS progresses.
Impact of HS RMTS on IV-E and MA Revenue
It is not anticipated that the consolidation of the current SS time study into the new HS RMTS will impact the IV-E revenue received by counties. Most IV-E revenue is claimed at the state level based on time study results and costs reported by counties. IV-E funds claimed at the state level are allocated to counties through the Community Aids and Title IV-E Incentive programs. Counties may receive Title IV-E funds directly for WiSACWIS, foster parent training or child welfare legal services. The time study consolidation will not affect the reimbursement rates for the IV-E pass-through programs.
It is anticipated that consolidation of the current CBMAC time study will have a minimal impact to the revenue received by counties currently participating in CBMAC. Counties that begin participating April 1, 2004, will share in 50% of the net federal revenue claimed under the CBMAC program. In order for those counties not currently in the CBMAC program to begin participating in the April-June 2004 quarter, counties must sign the attached agreement and submit the agreement to the appropriate Area Administrator. If a county wishes to participate at a later date, the agreement must be signed 45 days prior to the beginning of the next quarter. For example, if a county wishes to participate beginning with the July-September 2004 quarter, the agreement must be submitted to the Area Administrator by May 15, 2004.
Through the implementation of the HS RMTS, the Department will be able to differentiate medical from non-medical case management activities. As such, activities and corresponding costs associated with performing medical case management for children who are in placement and have been determined to be eligible for Title IV-E will be excluded from the state’s IV-E claim. Because the state is able to segregate this claim, it will be possible for counties to claim TCM for medical case management performed by any of the agency staff, including child welfare staff, for the Title IV-E eligible children in out-of-home care who are eligible for TCM. The DCFS Numbered Memo #2002-09 and related MA Provider Handbooks will be updated and reissued to reflect this change.
HS RMTS Process
The two key components of the HS RMTS are Time Reporting and Financial Data Collection. Instructions and training will be provided to the counties. A brief description of these components follows:
The time reporting process, the random moment sample, measures the work effort of county and applicable contract staff performing either child welfare (defined as: out-of-home care or preventing out-of-home care activities) or Medicaid outreach or administrative activities by sampling and analyzing the activities of randomly selected staff within the statewide participant group. Employees are polled at random moments over a given time period. The results of the polling are used to determine the percentage of time spent by staff on either IV-E, MA or CBMAC eligible activities. The polling will be performed via phone calls to randomly selected staff participating in the HS RMTS. The number of samples per worker will depend on the number of eligible workers participating in the HS RMTS. It is anticipated that responding to the call will take approximately two minutes per call and that a worker would receive a maximum of 1-2 calls per quarter for a total of 2,500 to 3,000 random moments per quarter. This method provides a statistically valid means of determining the work effort eligible for both IV-E, MA and CBMAC reimbursement.
The Roster is the list of staff who will participate in the time study random moment sample and who potentially perform federally reimbursable activities. These staff are identified by the county agency based on the expectation that they perform the activities for which federal costs are reimbursable as part of their job function. Full time and part time staff, both contracted and employed, may be listed on the roster for participation in the HS RMTS. The following selection criteria will be used when selecting participants for the HS RMTS roster:
Counties are responsible for assigning an HS RMTS Coordinator, identifying county staff and contract personnel to participate in the time study, and training participants. The county HS RMTS Coordinators review the job descriptions and functional expectations of potential participating staff to determine which positions are Social Services or are positions expected to perform allowable Medicaid administrative activities, and submit a roster identifying these staff for participation in the HS RMTS time study. The county HS RMTS Coordinator is responsible for updating the HS RMTS roster for additions, deletions and corrections each quarter. Updated rosters are due 45 days before the start of each quarter via e-mail to firstname.lastname@example.org.
Contract staff may be included on the HS RMTS roster. Counties may review their contract staff and determine that selected contract staff perform allowable administrative activities and should be included on the HS RMTS roster. Counties should sign an Administrative Claiming Agreement with their contract agencies which documents performance of administrative activities and full participation in training and the sampling process as contract requirements. Once an agreement is in place, selected contract staff from the contract agencies may be added to the counties' HS RMTS roster.
The State will administer the HS RMTS and apply the HS RMTS results.
All telephone polling will be conducted from the DHFS State Office Building located at 1 West Wilson Street in Madison, Wisconsin. The following staff will be conducting the telephone polling interviews:
Back up polling will be provided by:
Monthly Financial Data Collection
To calculate the IV-E and Medicaid administrative costs and to assure that there is no duplication of federal funds for the same services, monthly reporting of financial information by the counties using the Community Aids Reporting System (CARS) is required. A new profile will be added to the CARS system and will be used to identify all costs allocable to county and contractor staff included in the HS RMTS sample population. Allowable costs include all costs attributed to the participants subject to the time study sample population, costs of non-sampled supervisory and clerical staff that provide 100 percent direct support to the participants, direct costs that relate solely to expenditures of the participants identified by the county, and attributable indirect costs. Through the CARS system counties will offset federal funds that support staff costs included in the time study.
The financial reporting process and the time reporting ensures that federal funds and unallowable costs are excluded from the claim calculation model. As state policies and practices change, the financial reporting process can be easily amended to address changes.
Required County Actions
Responsibilities of the County Department of Human Services, Social Service, and Community Programs, the Bureau of Milwaukee Child Welfare and the State Special Needs Adoption Program participating in the HS RMTS include:
The Department has entered into an agreement with MAXIMUS, Inc. to assist with the implementation of the HS RMTS including providing training to the counties, assisting DHFS with operating the Random Moment Sample system, and assisting with preparation of the federal claim.
Timeframe for Implementation
DHFS has resolved to implement the consolidated time study instrument, the Human Services (HS) RMTS effective April 1, 2004. A summary of the important dates and deadlines follows:
CENTRAL OFFICE CONTACTS: