Behavioral Health Partnership Oversight Council

Provider Advisory Subcommittee

Legislative Office Building Room 3000, Hartford CT 06106
(860) 240-0321 Info Line (860) 240-8329 FAX (860) 240-5306
www.cga.ct.gov/ph/medicaid

Draft Meeting Summary: December 6, 2006
Co-Chairs: Susan Walkama & Dana Marie Salvatore
January 2007 meeting date TBA

Intake Billing 90801
CCPA had identified billing issues for behavioral health and psychiatric medical evaluation within a year (code: 90801). As discussed at the November 1, 2006 Subcommittee meeting, a state plan amendment is needed to allow more than one diagnostic evaluation per client per year. Approximately 40-45% of the HUSKY children that receive BH services also require a psychiatric medication evaluation that currently cannot be billed as the 90801. Dr. Schaefer stated that the history of the one 90801/year was based on past expectations that clinic services include an MD evaluation. DSS anticipates publishing the amendment in the Law Journal in December 2006, which would allow implementation in January 2007.

Residential Care Team (RCT) Update
Dr. Karen Andersson stated the transition of the RCT (previously the CPT team) to CTBHP/ValueOptions (VOI) was implemented December 1, 2006. DCF and VOI are working together to implement the more systematic approach to managing residential referrals through review and prioritization of residential/group home level placement or alternative community-based placement. Key points:

o 135 children/youth were referred under the CPT process and that process will be used for these clients. Beginning Dec. 1 new referrals will have a completed CANS packet by the DCF area offices that will now be automated within the VOI system. These referrals will be reviewed by the DCF/VOI team for treatment decisions.
o Current providers for this level of care MUST COMPLETE THE PROVIDER VALIDATION FORMS (provider information about the type services provided) and SEND WEEKLY CENSUS DATA (open beds) to VOI in order to be able to receive referrals from the RCT. Questions can be directed to:
Lynne Ringer (VOI) at 877-552-8247. Also see VOI provider website for validation forms and other information about the RCT: www.ctbhp.com
o The RCT will be aggregating data on the number of referrals, time from the referral to the point of disposition (authorization and actual placement), level of care determinations and number of denials. The SC suggested, given the concern about the number of existing residential beds (315), that the RCT team also track the alternative care authorizations and actual access to these services.

Enhanced Care Clinic (ECC) Status
Lois Berkowitz, DCF, reviewed the current status of the ECC RFA responses. About 42 applications have been received. The BHP committee anticipates completed the scoring of the responses by mid-December. Responders with minor deficiencies may be considered. Responder notification is expected in January 2007. Key discussion points:

o What is the effective date for the retroactive reimbursement at the ECC rate? DSS needs to determine the granted ECC's prior billing rates: if the clinic had billed at the Usual & Customary Rate (UCR), the ECC rate methodology can be applied. If the clinic billed at the contracted managed care fee schedule, the clinic would have to resubmit claims based on the UCR. DCF will look at methodology applied to other past retroactive reimbursement, which may reduce the need for resubmissions.
o The RFA stipulated that the ECC criteria would be applied 6 months from the point of the award. The retroactive rates would be applied earlier than the criteria start point.

Home-based Services
The Subcommittee reviewed the draft level of care (LOC) guidelines for these home-based services. Dr. Lois Berkowitz (DCF) described these services as less intensive in-home services to support clients/families, perhaps as a step-down LOC for the more intensive services, including the intensive home services such as IICAPS, MFT, etc. Susan Walkama reviewed the process for LOC guidelines: LOC guidelines, developed in the BHP Clinical Management Committee, are sent to the subcommittee for review/recommendations. These are presented to the full BHP OC for approval and sent back to the Clinical Management Committee for consideration. The BHP Committee has adopted about 100% of the SC & BHP OC LOC guideline recommendations.
Key discussion points:

• Home care agencies requested information these entities' participation in delivery these services. Drs. Schaeffer & Andersson noted:

o DCF licenses OP child BH clinics that may have primary, satellite and off-site services as part of their license.
o Home care agencies can seek licensing with DCF as an entity seeking license as an OP clinic server.
o Federal law defines delivery of care with the type of licensure model and would not preclude an agency from seeking licensure as a clinic. Federal law allows rehab. services and case management for Medicaid clients under age 21 years under EPSDT medical necessity. Conceptually the KidCare model had focused on increasing accessibility to services outside the clinic site, including in the home.

• There currently is a code under the Emergency Psychiatric Services (EMPS) model reimbursement for crisis care off-site from the clinic.
• CMS will be issuing regulations for rehab and care management services, perhaps by 12/8/06. The regulations could require service provision by licensed providers. This could significantly restrict the provision of off-site BH services, requested by licensed practitioners but provided by non-licensed providers under the supervision of the licensed staff.
• It is possible for a clinic to receive concurrent authorization for rehab, case management and clinic-based services and medical management if this is well documented in the client's service master plan.

DSS will be providing a policy transmittal clarifying the level of care definition, services and billing process once the federal regulations are released.

The Chair asked the subcommittee to review these LOC guidelines, bring comments to the January meeting.