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Frequently Asked Questions

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.

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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

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How 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

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Can 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

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Do 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

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When a facility has been in operation for the dates of service covered by the Upper Payment Limit (UPL) demonstration, can a state demonstrate the UPL by using less than 12 months of data?

In accordance with Medicare cost reporting, the state must use 12 months of cost data reported by each facility. With regard to payment data, the state should use actual amounts, to the extent available, then calculate a claims completion factor based on historic utilization. The state’s UPL submission must include an explanation of its methodology to estimate payments. The use of a claims completion factor provides a reasonable estimate of the amount that Medicare would pay for these services, consistent with the UPL as defined at 42 CFR 447.272.

FAQ ID:92446

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What data should my state provide to the Centers for Medicare & Medicaid Services (CMS) for the annual Upper Payment Limit demonstrations?

Effective state fiscal year 2020, each state must submit a complete data set of payments to Medicaid providers, including providers paid at cost, as well as critical access hospitals. This would require states to submit cost and payment data to CMS that previously was not requested.

FAQ ID:92456

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How will the Centers for Medicare & Medicaid Services (CMS) disseminate the list of Healthcare Common Procedure Coding System (HCPCS) codes subject to the federal financial participation (FFP) limit each year?

Annually, CMS will request a list of covered durable medical equipment HCPCS codes from the Medicare Pricing, Data Analysis and Coding Contractor. Once the list is received, CMS will distribute the list through the CMS Regional Office Associate Regional Administrator.

FAQ ID:93671

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States have raised concerns around the federal financial participation (FFP) limit demonstration due date because they may not have received all durable medical equipment (DME) claims from providers at the point demonstrations are due. How may a state ensure compliance with the FFP limit without allowing for a claims run-out period.

To address claims run-out and ensure compliance with the FFP limit, we recommend states with these concerns conduct interim FFP limit demonstrations for DME no later than three months after the end of the calendar year for the previous calendar year (that is, January 1-December 31). The interim DME FFP limit demonstration will be due by March 31 of each calendar year and will contain data for the period of January 1 to December 31 of the preceding year. The final demonstration would be due one year later on March 31 and include all claims received during the run-out period dates of service within the interim demonstration period. The interim demonstration process should provide states with an understanding of potential violations of the FFP to make any necessary budgeting and rate changes. This method is being used to allow provide for a reasonable claims run out period as allowed under 42 CFR 424.44, which states that claims must be filed no later than one calendar year after the date of service.

FAQ ID:93676

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Can you explain the difference between a prospective Upper Payment Limit (UPL) and a retrospective UPL?

The difference between a prospective and retrospective UPL is in the relationship between the UPL demonstration period and the date when the UPL is submitted. For a UPL demonstration period of 7/1/2018 to 6/30/2019, a UPL is considered retrospective when it is submitted on or after the start of the demonstration period (on or after 7/1/2018). Using the same UPL demonstration period (7/1/2018 to 6/30/2019), a UPL is considered prospective if it is submitted prior to 7/1/2018.

FAQ ID:92431

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When is the federal financial participation (FFP) limit demonstration due? And for what period of time? Why is the Centers for Medicare & Medicaid Services using calendar year for this demonstration?

Federal financial participation (FFP) limit demonstrations for durable medical equipment (DME) will be due 3 months after the end of the calendar year for the previous calendar year (i.e., January 1-December 31). The first DME FFP limit demonstration will be due by March 31, 2019 and will contain data for the period of January 1, 2018 to December 31, 2018. This reporting period was selected to coincide with the effective date of the statute (January 1, 2018).

FAQ ID:93486

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