Frequently Asked Questions are used to provide additional information and/or statutory guidance not found in State Medicaid Director Letters, State Health Official Letters, or CMCS Informational Bulletins. The different sets of FAQs as originally released can be accessed below.
Frequently Asked Questions
A Managed Long Term Services and Supports (MLTSS) plan may document the data elements required for MLTSS measures, but the information may be recorded in different locations or abstracted inconsistently from members' records. What can states and plans do to ease the potential burden of data collection and help standardize the data collection process?
Through our discussions with MLTSS plans, we learned that plans—particularly those operating in multiple states—can ease the burden of data collection by mapping their existing assessment and care plan tools to the standardized data elements and terminology in these measures, which would make it easier to abstract data and standardize the data collection process. It is also important for MLTSS plan managers to train staff to document assessment and care plan elements consistently, as well as train individuals responsible for collecting data on how to interpret each of the elements specified in each measure. Plans can also ease the burden of data collection by ensuring data from multiple sources are consolidated into a central data system.
FAQ ID:89041
SHARE URLHow should states validate plan-reported Managed Long Term Services and Supports (MLTSS) measure rates?
If MLTSS plans report measure rates directly to the state, the state should conduct an independent review of a sample of members included in the reported measures, for example, by the External Quality Review Organization or state-employed abstractors.
FAQ ID:89051
SHARE URLCan all eight Managed Long Term Services and Supports (MLTSS) measures be applied to members who receive LTSS benefits but do not receive a medical care benefit (for example, hospitalizations, primary and specialty physician care, and other outpatient services) through an MLTSS plan?
Four of the eight measures (LTSS Comprehensive Assessment and Update, LTSS Comprehensive Care Plan and Update, LTSS Shared Care Plan with Primary Care Practitioner (PCP), and Screening, Risk Assessment, and Plan of Care to Prevent Future Falls) apply to all members receiving a LTSS benefit through the MLTSS plan regardless of whether the MLTSS plan covers their medical care benefit. The remaining four measures (LTSS Reassessment/Care Plan Update after Inpatient Discharge, LTSS Admission to an Institution from the Community, LTSS Minimizing Institutional Length of Stay, and LTSS Successful Transition after Long-Term Institutional Stay) require members to receive a medical benefit through the MLTSS plan to be eligible for the measures (that is, the MLTSS plan is the primary payer for the medical care services, such as inpatient hospital stays and post-acute care). These four measures rely on inpatient claims (that is, hospital and skilled nursing facility), which may not be available to the MLTSS plan if the plan is not the primary payer for the service. Although members whose medical care benefits are not covered through the MLTSS plan are not eligible for the measure, we recommend MLTSS plans track members’ admissions or discharges from inpatient facilities where possible.
If MLTSS plans can obtain timely, complete, and accurate inpatient claims data for their members, then a state may choose to deviate from the measure specifications to require that MLTSS plans not providing medical benefits report these four measures.
FAQ ID:89056
SHARE URLDo Managed Long Term Services and Supports (MLTSS) measures apply to participants in Home and Community Based Services 1915(c) waiver programs?
The measures are intended for any MLTSS plan that covers Medicaid LTSS benefits. Federal regulations pertaining to 1915(c) waivers require person-centered service plans,1 but states can decide whether to require MLTSS plans participating in a state program operating under 1915(c) authority report these measures, and if they do, states can specify which types of plans and eligible members to which the measures apply.
1"In accordance with 42 CFR §441.301 (b)(1)(i), all waiver services must be furnished pursuant to a written service plan that is developed for each waiver participant." (1915c waiver application, Instructions, Technical Guide and Review Criteria (PDF, 2.29 MB), Appendix D-1: Service Plan Development, CMCS, DEHPG, November 2014.
FAQ ID:89061
SHARE URLWhat was the traditional Medicaid Eligibility Quality Control (MEQC) program based on and how has it changed?
The traditional MEQC program at 42 CFR § 431.810 through 431.822 was originally designed to implement sections 1902(a)(4) “Administration Methods for Proper and Efficient Operation of the State Plan” and 1903(u) “Limitation of FFP for Erroneous Medical Assistance Expenditures” of the Social Security Act (the Act). The program required annual state reviews of Medicaid cases identified through a statistically valid statewide sample of cases selected from the state’s eligibility files. The reviews were conducted to determine whether the sampled cases meet applicable Medicaid eligibility requirements. The program evolved over time to allow states the option of selecting specific areas of focus within the Medicaid program for their annual MEQC reviews.
On July 5, 2017, CMS published a final regulation entitled “Changes to the Payment Error Rate Measurement (PERM) and Medicaid Eligibility Quality Control (MEQC) Programs (CMS-Medicaid Coordination of Benefits8- F).” This final rule updated the MEQC and PERM programs based on the changes to Medicaid and Children’s Health Insurance Program eligibility requirements under the Patient Protection and Affordable Care Act. The new regulation has restructured the MEQC program into an ongoing series of pilots that states are required to conduct during the two off-years between triennial PERM review years. The MEQC portions of the regulation are now covered by 42 CFR §§ 431.800-820.
FAQ ID:93416
SHARE URLWhat deliverables must states furnish to the Centers for Medicare & Medicaid Services (CMS) per the new Medicaid Eligibility Quality Control (MEQC) regulation?
The regulation requires states to submit a pilot planning document to CMS by November 1 of the year in which each state’s PERM review year ends. The pilot planning document must describe how states will conduct their active and negative case reviews and must be approved by CMS before the MEQC pilots can begin. In addition, the regulation requires states to submit case-level reports and corrective action plans to CMS by August 1 of the year after the MEQC review period ends. The specifications for the MEQC pilot planning documents are provided in the MEQC sub-regulatory guidance effective August 29, 2018. More details on the specifications of the case-level reports and corrective action plans are included in a second round of guidance, MEQC sub-regulatory guidance effective October 22, 2018.
FAQ ID:93421
SHARE URLHow will the Medicaid Eligibility Quality Control (MEQC) program be realigned under the final regulation issued July 5, 2017?
As reconfigured under the final regulation of July 5, 2017, MEQC will work in conjunction with the Payment Error Rate Measurement (PERM) program. In those years when states undergo their triennial PERM reviews, the states will not conduct MEQC pilots. The latter will only be required in the two off-years between PERM review years. CMS has restructured the MEQC program so that it more effectively complements the PERM program and provides states with the necessary flexibility and opportunity to target specific problems or high-interest areas during the two off-years of the PERM cycle.
FAQ ID:93146
SHARE URLHow does Medicaid Eligibility Quality Control (MEQC) differ from Payment Error Rate Measurement (PERM)?
The MEQC requirements on active case reviews generally mirror the requirements of the eligibility component of PERM reviews. The regulation requires that states perform reviews of a sample of active Medicaid and Children’s Health Insurance Program (CHIP) cases to identify new eligibility approvals and renewals that were made in error. As in PERM, states will be required to submit case-level reports on the sampled cases they review and corrective action plans that describe steps taken to remediate the errors found.
However, in contrast to PERM, when states identify errors in their active Medicaid and CHIP cases, they will be required to undertake a payment review. This will consist of a review of all claims paid over the first three months after an erroneous eligibility determination was made, and a summary of the overstated or understated liability. States will in turn be required to submit adjustments to the amount of federal financial participation (FFP) claimed through the CMS-64 reporting process for Medicaid and the CMS-21 reporting process for CHIP. The adjustments are required for identified claims in which too much or too little FFP was received. There is no payment review or re-crediting requirement in PERM, although disallowance of FFP can be taken in states whose PERM error rate exceeds the national threshold of 3% based on a formula described at 42 CFR 431.1010. MEQC contains no such disallowance provision.
The MEQC program also contains one other significant element that is not found in PERM. Besides the requirement that states review at least 400 cases in their active case universe (including a minimum of 200 cases), MEQC requires states to review at least 400 negative case actions. At least 200 of these must be Medicaid and 200 must be CHIP. Negative case actions involve erroneous denials of Medicaid or CHIP eligibility or erroneous terminations from Medicaid or CHIP. This is an area with no PERM counterpart in which states will be developing case-level reporting and corrective actions. Negative case action reviews will not be triggered by PERM findings. Largely for this reason, the regulation requires that states pull their sample of these from the entire Medicaid and CHIP universe of cases. By sampling from the full range of Medicaid and CHIP cases, states should be able to obtain an overview of those sectors in their programs that may be especially vulnerable to improper denials or terminations.
FAQ ID:93196
SHARE URLIs there a simplified Payment Error Rate Measurement (PERM)/Medicaid Eligibility Quality Control (MEQC) timeline with milestone dates/cycles that can be provided to states (all cycles)?
The PERM/MEQC dates/cycles are as follows:
PERM Cycle* | PERM Review Period | MEQC Planning Document Due to CMS | MEQC Review Period | MEQC Case-Level Report on Findings and CAP Due to CMS |
---|---|---|---|---|
Cycle 1 | July 1, 2017 – June 30, 2018 | November 1, 2018 | January 1 – December 1, 2019 | August 1, 2020 |
Cycle 2 | July 1, 2018 – June 30, 2019 | November 1, 2019 | January 1 – December 1, 2020 | August 1, 2021 |
Cycle 3 | July 1, 2019 – June 30, 2020 | November 1, 2020 | January 1 – December 1, 2021 | August 1, 2022 |
*??
CMS = Centers for Medicare & Medicaid Services
CAP = ??
FAQ ID:95156
SHARE URLWhat is reuse?
The Centers for Medicare & Medicaid Services expects states receiving Federal Financial Participation to share with other states project artifacts, documents and other related materials, and systems components and code for leverage and reuse.
Read the state Medicaid director letter (SMD #18-005) on reuse (PDF, 70.77 KB). Reuse can be accomplished through sharing or acquiring:
- An entire set of business services or systems, including shared hosting of a system or shared acquisition and management of a turnkey service
- A complete business service or a stand-alone system module
- Subcomponents such as code segments, rule bases, configurations, customizations, and other parts of a system or module that are designed for reuse
FAQ ID:93631
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