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Certified Community Behavioral Health Clinic (CCBHC) Prospective Payment System (PPS) payment

FAQ August 14, 2020

Q: A letter dated 8/4/2020 recently received from DHS states that the state plan amendment (SPA) must be approved on Oct. 1st to expand beyond the original six clinics. What are the implications of this?
A: The SPA submission must occur during the calendar quarter of the effective date. In other words, CMS approval will be backdated to October 1st (the first day of the calendar quarter in which the change takes effect). DHS will have a draft SPA complete and posted for public comment by the end of August 2020. DHS expects to submit the state plan to CMS by October 1st.

Q: What happens if this SPA is not approved?
A: Once a state plan amendment is submitted to CMS they have 90 days to review and reach a decision. Typically we receive some informal questions after CMS has had the opportunity to review. CMS can also send the state a written request for additional information. The time period between receipt of a request for additional information from CMS and the state’s response do not count toward the 90 day review period.

Q: With the first draft of the Minnesota Medicaid Information Systems (MMIS) set up slated for mid-October with completion and changeover by Jan. 1st, what about the SAMSHA grantees who will need to go live with MMIS Oct. 1st?
A: DHS is working to ensure that HDC & Western receive the PPS beginning October 1, 2020. For more information, see answer below.

Q: You mentioned the possibility of wrap payments for three months and then changing over. We are worried about current issues with this payment methodology that are still not corrected and having a short term work around and then a change in how we’re paid for three months right at year end. The 8/4/2020 letter also stated that this wrap payment would not be an option for new or expanded clinics. Can you say more?
A: DHS resources remain limited due to COVID. We have received and appreciate feedback from clinics, and we are exploring all available options. DHS will discuss options at meetings between DHS, CCBHCs and MCOs throughout fall 2020.

Q: What about the extra work to set up with billing/EHR/accounting to do wrap for three months, and then moving to MMIS in Jan. 2021?
A: DHS appreciates this input and these concerns. We will take all of this into consideration when making the final determination.

Q: If changes need to be made in the Electronic Health Record (EHR) for MMIS, will we have adequate time to get this in our system to ensure proper billing/revenue, as EHR systems take a significant amount of time to make changes?
A: A provider’s claim entry into MMIS will work as it does now. Providers will continue to submit claims to DHS and MCOs the same way they do today regardless of whether the wrap payment or system generated PPS payment is utilized. Assuming State Plan amendment approval there are CCBHC-specific services which are billed with the Q2 modifier and described in the MHCP Provider Manual.

Q: Year-end time-frame payments as we will want to get these wrapped up by year end for auditing purposes as well as balancing and not having huge accounts receivable balances as of 12-31-20.
A: DHS appreciates this input and concerns. We will take this into consideration when making the final determination.

Q: If the demonstration project were to continue, can we still bill through MMIS, even though currently we are not eligible to participate due to not being one of the original six?
A: DHS and the MCOs are scheduled to begin paying the “expansion clinics” the full PPS payment directly from their systems as of January 1, 2021. DHS is also working to ensure that HDC & Western receive the PPS beginning October 1, 2020 (assuming State Plan amendment approval retroactive to that date). See additional information above.

Q: Contracts/payments from MCO’s – how and when does this contract get set up? Are we automatically included, etc.?
A: DHS has contracts with each managed care organization (MCO) that set forth the state’s expectations of how the MCOs provide services to people enrolled in Medicaid. Those contracts include information about requirements for the CCBHC program such as how payments should be made to the CCBHCs.

CCBHC providers that have existing contracts with Minnesota Medicaid MCOs for other behavioral health services should contact the person they worked with at the MCO for their current contract and ask about adding CCBHC services. As part of your discussions with each MCO, we recommend that you check with the MCO regarding any procedures they may require before you can bill the MCO for CCBHC expanded services using the Q2 modifier. CCBHC expanded services which are billed with the Q2 modifier are described in the MHCP Provider Manual. The information that DHS is providing to the clinics regarding the PPS rate will help inform the clinics as to what the expectations are in terms of MCO payment.

If a CCBHC does not currently contract with the MCOs and is having difficulty establishing a contract, please contact Alexis Stafford

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