This memo amends the TCM Claiming on Child Welfare Cases, #2002-09. The memo provides direction on TCM claiming for both in-home and out-of-home placement cases, identifying when TCM can be claimed on a fee-for-service basis for activities performed by county agency staff and private providers under contract with county agencies. The major change from #2002-09 is that for children who are in placement and have been determined to be Title IV-E eligible, the county will be able to claim TCM for allowable activities as described in this memo.
This numbered memo replaces the joint Information Memo #2002-09,
DHFS Random Moment Time Study
The Department uses a random moment time study (RMTS) process to claim both federal TCM and Title IV-E funds. As part of this RMTS, the Department is able to differentiate medical from non-medical case management activities. Consistent with federal Medicaid policy, the 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 are excluded from the stateís 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.
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 case management services to child protective and juvenile service clients, served in-home or with out-of-home placement, may be covered by Title IV-E or by TCM. 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 and in Numbered Memo #2002-09, 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 Division of Health Care Financing (DHCF). Based the coding process for activities in the RMTS, TCM can be claimed on a fee-for-service for allowable activities as follows:
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). In these cases, the federal Center for Medicare and Medicaid Services (CMS) provided policy direction in January 2001 limiting covered services for this population to those directly related to the provision of medical services. Under this federal directive, CMS has instructed state Medicaid (MA) 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 allowed under Title XIX of the Social Security Act (Medicaid).
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. For purposes of these scenarios, child welfare staff include those persons who have a primary case assignment to the child and/or family case and perform the case management function on behalf of the agency.
Determining Title IV-E Eligibility Status
The county child welfare agencies and the stateís Special Needs Adoption Program utilize the Statewide Eligibility Unit and the Bureau of Milwaukee Child Welfare (BMCW) uses the FAST Unit to compile documentation and assist in the establishing and updating a childís Title IV-E status. These activities are performed in order to carry out the following federal Title IV-E requirements:
Documentation of the initial Title IV-E determination and all subsequent re-determination(s) must be recorded and maintained as part of the childís or juvenileís eWiSACWIS documentation.
The current State MA Plan and the RMTS serve to clarify the population for which Title IV-E or TCM will be claimed using the Departmentís cost allocation methodology. Under this methodology, the Department will continue to claim Title IV-E whenever possible for both in-home and placement cases and will claim TCM for activities associated with children in placement who are determined to be ineligible for Title IV-E. Counties or private providers certified by MA may claim TCM for allowable activities as described in Attachment #2. 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.