May 11, 2009
A key topic of discussion during the most recent OKDHS Director/Provider meeting on March 9th was the importance of timely submission of service plans. At that time almost 40 percent of Reassessment plans were being submitted late making it very difficult to have new plans approved prior to expiration of those members' existing service plans. At the meeting providers were informed that plans needed to be received by the ADvantage Administration Unit (AAU) at least 30 calendar days before the ending date of the current service plan.
This standard is intended to allow enough time for the AAU to review the plan, interact with Case Manager (if necessary) and authorize the services on the proposed plan before expiration of the current plan, thus preventing a gap in member services.
CMS is very clear in stating that federal funds are not availabel for waiver services that have been delivered without being listed on an approved service plan. In accordance with 42 CFR 441.301(b)(1)(i) (Link opens in new window) states are required to assure that services are furnished under a written plan of care subject to approval by the Medicaid agency or the waiver program Operating Agency. If services are provided that are not on an approved service plan, federal Medicaid funds for those services may be disallowed and must be returned to the federal government.
On April 14th and 15th, the AAU met with providers to discuss and clarify expected standards for submission of service plans. During the meeting AAU staff emphasized that Case Management agencies needed to systematically reset their deadline date for completion and submission of reassessment service plans in order to meet the requirement of AAU receipt of the reassessment plan at least 30 days prior to the existing plan end date.
This letter is to re-assert directives provided during these most recent AAU meetings with agency representatives that effective June 1, 2009, an ADvantage Program member's reassessment service plan is to be received at the AAU at least 30 calendar days before expiration of the current service plan. In addition, service plan amendments should be submitted as soon as possible in advance of the service change begin date (14 days prior to initiation of the new service if possible).
If your agency will not be able to meet the reassessment plan delivery to AAU standard by June 1, contact the AAU. Our staff will be available to work with case managers to prevent service gaps and ensure that members do not go without vital services. However, a lapse in service plan authorization may be unavoidable when plans are submitted late by the Case Manager.
Within the next couple of months, the AAU will be developing and distributing Case Manager Performance Standards designed to enable and support good Case Management practice. A key component of the Case Manager Performance Stnadards will be timely submission of service plans. Consequences for failure to meet standards will also be developed and implemented. In addition, the AAU will continue to distribute reassessment reports monthly as an agency specific reference for implementing improvement strategies.
Thank you for the service that you provide to Oklahoma's elders and adults with disabilities. If you have questions about the general service plan process and timeframes please contact us via email at Provider Questions.