This memo provides a synopsis of the Children's Long Term Support Waivers (CLTS) and child welfare services, with programmatic and fiscal direction for administering case management services and exceptional placement cost claiming for children enrolled in both programs.
The purpose of this memo is to describe the requirements of and provide direction on state and local claiming for administrative and service expenditures associated with the Children's Long-Term Support Medicaid Home and Community-Based Services Waivers (CLTS Waivers) and child welfare services. Attachments A & B provide an overview of the program background and philosophy, service requirements and components, and a fiscal overview for each program respectively.
This memo was developed jointly by the Division of Disability and Elder Services (DDES) and the Division of Children and Family Services (DCFS), in collaboration with county representatives, Human Services Area Coordinators and the Division of Management and Technology (DMT). The memo briefly describes related federal requirements and provides state policy related to program operation and fiscal claiming for case management or service coordination activities and exceptional placement costs when children and their families are being served in both the CLTS Waivers and child welfare programs.
Case Management Claiming for Title IV-E and Support and Service Coordination for CLTS Waivers
The federal Centers for Medicaid and Medicare Services (CMS) has established a policy related to third party liability in cases where services can be claimed to Title IV-E. This requirement states that whenever a service can be claimed to Title IV-E, Title IV-E must be payor of first resort (an exception to this is noted in "Exceptional Placement Cost Claiming " below). As such, Medicaid, whether claimed through the CLTS Waivers or through some other Medicaid program, such as Targeted Case Management (TCM), may be claimed only if the service is not covered by Title IV-E.
The CLTS Waivers generally pay AFTER Medicaid Fee for Service, however TCM is paid first by the CLTS Waiver for Waiver clients and not through Medicaid Fee for Service (exception: Children in Community Support Program (CSP) and CLTS Waiver will bill TCM to CSP, NOT CLTS Waiver).
To ensure that duplicate billing for services does not occur, if a child is temporarily being served in the Child Welfare program AND the child has been determined eligible and received a CLTS Waiver slot for which the county is also providing Support and Service Coordination, the county agency should do one of the following:
Documentation of all contacts on behalf of the child and his/her family is required for both programs. Documentation of contacts should be recorded in eWISACWIS Case Notes window for child welfare services and must be documented in the Support and Service Coordinator's case notes for CLTS Waiver services. This documentation is to include the date and time of contacts, the participants in the contact, the purpose of the contact and the results of the contact. Documentation must be kept in this manner regardless of whether a county has separate program support and service coordination/case management staff for each program, or a single individual performing support and service coordination/case management for both programs. This ensures accountability to the programs' respective federal regulations.
Exceptional Placement Cost Claiming
The CLTS Waivers list "Foster Care" as a possible service. Allowable services under Foster Care for the CLTS Waivers are those supports that are supplemental for supporting a child with a disability in a foster care setting, not basic or routine expenses for general foster care services. Exceptional and supplemental foster care service costs may be claimed to the waiver if the child meets specific needs as identified in the "Determination of Exceptional Care Needs for Children in a Child Care or Foster Care Setting" checklist (Attachment C).
If supplemental and/or exceptional placement costs are determined to be appropriate for the CLTS Waiver, Title IV-E does not need to be claimed first for these costs, as the Center for Medicare and Medicaid Services (CMS) has approved this CLTS Waiver allowable service to be billed under the CLTS Waiver first.
Medicaid reimbursement claimed by the county agency under one of the CLTS Waivers for supplemental and/or exceptional placement costs must be documented in eWiSACWIS in order to offset the DHFS Title IV-E claim for placement costs and prevent double-billing to both Medicaid by the county and Title IV-E by the Department. Examples of when and how to document these claims are provided in the eWiSACWIS Placement Documentation Manual as noted below.
Attachment A: Children's Long-Term Support Medicaid Home and Community-Based Services Waivers (PDF, 26 kb)
Attachment B: Child Welfare Services (PDF, 21 kb)
Attachment C: Children's Long-Term Support Medicaid Home and Community-Based Services Waivers (PDF, 22 kb)