INARF at Work to Enhance the Service Model for Group Home Providers 

Recently, INARF convened a meeting between industry consultants, the Indiana Office of Medicaid Policy and Planning (OMPP) and Myers & Stauffer to discuss audit specific issues.

Specific Issues include the following:

• Treatment of OTC drugs; skin protectants, sealants, moisturizers and ointments; dietary supplements; and other supplies procured from pharmacies. While no changes were achieved in OTC drugs, we have seen clear changes for all other categories except dietary supplements. Based upon direction received during the meeting, we have filed a request with the Medicaid Policy Team to make dietary supplements explicitly allowable. It should be noted that providers need to be separately identifying these items in their trial balances to reduce the exposure to audit adjustments. If they are grouped into one supplies account then if audit sample testing identifies non-allowable items, it could lead to extrapolation adjustments of large amounts as the percentage of non-allowable items would be applied to the entire account.
• Mental Health Services including behavior management, psychiatric and psychological services which were clearly stated as allowable items in the all-inclusive rate.
• Electric wheelchairs and wheelchair repairs for which there is conflicting information. Repairs are included in the LTC Per Diem Table and should be allowable. Electric wheelchairs themselves are currently not on the list but we are to present examples of dis-allowances and non-coverage for the DME billing.
• Administration costs included in day services cost and the home office allocation that Myers & Stauffer consider a double allocation. There was not movement on this issue.
• Cost of professional services that are considered related to patient care including program consultants (allowable), human resources/benefits consultants (allowable), board consultants (allowable depending on the issue) and investment advisory fees (not allowable).
• Calculation of weighted medians and the exclusion of providers that have closed or undergone a change of ownership. There was agreement that closed facilities should be excluded. Relative to change of ownerships, there was no movement and OMPP has included this in an update of the reimbursement regulations that should be coming out in the next few weeks.
• Request to change the capitalization policy amount from $500 per item to $1,000 per item consistent with the nursing homes. There was no movement but we can file a request with the Medicaid Policy team to review this issue.

In the next few weeks, OMPP should be issuing some changes to the group home reimbursement rules which in addition to some verbiage cleanup should include the following: 

• Department Head will be defined as an individual responsible for the supervision and management of a ICF/IIF or CRF/DD department. Home office personnel responsible for the supervision and oversight of these department heads will be subject to the Owner/Related Party/Management Limit. Practically speaking depending on your structure this may or may not be a change. Rule now will clearly include vice presidents and regional supervisors as subject to the limit
• Information for field audits must be provided 30 days prior to the audit field date. Failure to provide this information could lead to a 10% rate penalty for each facility for each month until the information is provided.
• In the event of a change of ownership or control, require the filing the Checklist of Management Representations Concerning Change in Ownership as is current practice. Allows OMPP to assess a 10% penalty if the Checklist has not been submitted within 90 days of the transaction date.
• For purposes of determining medians, providers whose most recently completed rate is an initial interim rate (e.g. will file a 9 month historical cost report) shall be excluded from the determination.
• Sunsets all rate reductions effective June 30, 2016 including the .09% rate reduction currently in place. As a result, group home rates will be adjusted effective July 1, 2016 to restore the .09% rate reduction currently in place. Rates will be issued in the next few months depending on CMS approval of the state plan amendments and the status of provider rates. For example, all providers with rates usually effective on 10/1 will receive new 7/1 rates all at one time. Those providers that have 4/1 rates will receive their revised 7/1/16 rates only after their 4/1/16 rates are issued.

If you should have any questions regarding any of these issues, please do not hesitate to contact the INARF office or Sarah Chestnut.