CCS Question and Answer
Following are questions posed to the Division of Mental Health and Substance Abuse Services (DMHSAS) Division of Quality Assurance (DQA), and/or the Division of Health Care Access and Accountability (DHCAA) by representatives of the CWHP Regional CCS Initiative, and corresponding responses.
If you have CCS-related questions, please submit questions by email to DHS DMHSAS CCS Support.
The DMHSAS website also has a webpage dedicated to CCS-related FAQ's: https://www.dhs.wisconsin.gov/ccs/expansion/faq.htm.
Regional Coordinating Committee Membership
Current policy is for our CCS Regional Coordinating Committee membership to include one consumer representative from each partnering county, each county's CCS service director, and a board member from each of the county's local CCS coordinating committee. Are board members considered county employees? The concern is that if they are, we would not be satisfying the minimum 1/3 consumer voice/membership.
I have a multi-part answer. 1) because the region is a shared services model and each county is separately certified each county has to have a coordinating committee that follows DHS 36 on the makeup. 2) The regional coordinating committee should ideally be comprised of members from the county coordinating committees, which it sounds like is the case. The rule committee makeup technically doesn’t apply to the regional committee, unless it is taking the place of a county committee. 3) county board members are technically not county employees, in the sense that the rule is trying to limit the number of providers – county or otherwise – on the committee. I would see the board members as community members in this case.
Provided by: Kenya Bright, Section Chief, Integrated Services Section, BPTR, DMHSAS on 9/11/15
Are CCS sites required to serve individuals who qualify for CCS who are not MA eligible?
DQA-certified CCS programs are able to limit enrollment in CCS to individuals with Medicaid only or, if serving those without Medicaid, up to their ability to financially provide services.
Provided by: Mark Hale, Chief, Behavioral Health Certification Section, BHS, DQA on 1/12/16
Does an individual have to be Medicaid eligible to receive CCS?
No. DHS Chapter 36, Wisconsin Administrative Code, does not require an individual to be Medicaid eligible to receive CCS services. Any individual who meets the CCS program eligibility requirements can participate in CCS. However, in order for Medicaid to reimburse for CCS services, the CCS member must be Medicaid eligible.
Provided by: Provided by: Mark Hale, Chief, Behavioral Health Certification Section, BHS, DQA on 1/12/16
Providing CCS Services to Consumers in Groups
How does a CCS provider document CCS services provided to groups of consumers on his/her time sheet?
For example, if a CCS provider provides skill development (let’s say a cooking class) for 4 CCS consumers and the session is 2 hours long, how does the CCS provider document his/her time for billing purposes? Would a provider in this type of situation document 2 hours on their time log? And if so, then do they document also that the service provided is a group service for 2 CCS clients; and the billing clerk would then be responsible for multiplying the number of individuals in the group (4) by the number of hours (2) and the group billing rate for MA billing purposes?
Each CCS county or region can implement their own time sheets and billing system. In general, the provider’s time sheet should indicate that a CCS group service was provided. For purposes of billing Medicaid and for cost reporting, the county’s records should indicate the number of CCS and non-CCS members in the group.
The county should bill Medicaid for the actual cost of providing the group service to the CCS Medicaid member. The interim claim would receive reimbursement at the statewide interim rate or the actual cost billed, whichever is lower. Note that the interim rate for a group service is 25 percent of the individual service interim rate.
In your example, (skill development provided during a 2-hour cooking class to 4 CCS consumers) the provider’s time sheet would show 2 hours for a CCS group session. The county would also have to document that the session had 4 members and then would bill MA for 2 hours of group service for each CCS Medicaid member. For CCS cost reporting, the county will be responsible for reporting two items – clinician hours and participant units.
- Total Clinician Group Service Hours: counties will need to indicate how many of the total hours of CCS services provided by clinicians at each professional level were provided in a group setting. Using your example, if the clinicians providing the group service were Bachelor’s Degree Level clinicians, you would report a total of two hours of CCS Group service provided by Bachelor’s Degree level clinicians.
- Participant Units: the total number of participant units in each CCS group session is needed to calculate the actual cost per 15 minutes. The total number of participant units provided to each group would include CCS and non-CCS members as well as Medicaid and non-Medicaid members. In your example the number of participants (4 individuals) would be multiplied by the number of CCS units (8 fifteen minute increments) to get a total of 32 participant units.
To summarize, if you are consistently tracking the clinician professional level, total session time and number of participants for each CCS group session you should be able to easily comply with the reporting requirements.
Provided by: CCS Help Desk, specific author unknown, 1/25/16.
Interim group rates can be found in Attachment 4 of the ForwardHealth Update, June 2014:https://www.forwardhealth.wi.gov/kw/pdf/2014-42.pdf
Other related information can be found in the “Comprehensive Community Services (CCS)— Frequently Asked Questions (11/2015)” document found on the DMHSAS website https://www.dhs.wisconsin.gov/ccs/expansion/faq.htm as follows:
In order for a CCS service to qualify as a group service, the service must meet the following criteria:
- The service must be included in the CCS Program Service Array found in Attachment 1 of Update 2014-42.
- The service must be provided to two or more members simultaneously.
- The service must be documented in each individual member’s service record.
It is important to note that a group service may include CCS members and non-CCS members. CCS programs should only bill for services provided to CCS members who participated in group services. Non-CCS members should not be included on CCS claims. Additionally, if one CCS member participates in a group service with other non-CCS members, the service should still be considered a group service for the one CCS member.
CCS-Related Training Expenses
White Pine has a contract with one of the six CCS-certified counties in our region (Adams County) to provide regional coordination activities related to the region’s CCS training plan (among other things). We invoice Adams County for costs related to our activities, and Adams County in turn divides the cost by six and bills each of the other certified counties. Each county, then is responsible for their own financial recordkeeping and submission of those activities for reimbursement from MA through the reconciliation process.
Let’s say White Pine organizes and facilitates a full-day CCS orientation training for providers in our region and provide handout materials, fruit and coffee in the morning, pizza for lunch, and cookies in the afternoon. I would typically invoice Adams County for White Pine staff time, mileage, the cost of the materials, and cost for refreshments and lunch. Adams County divides the cost six ways and invoices the other counties. What costs in this situation are eligible for reimbursement to each of the counties through their reconciliation process? It is my understanding that the handout materials and White Pine staff time and mileage, would be eligible for reimbursement; but that the costs associated with the fruit, coffee, pizza, and cookies would not…is this correct?
What if it were a situation where a CCS staff person from Adams County was participating in an all-day CCS training which cost $150 per person and that $150 included refreshments and lunch? Would the entire $150 registration fee be a reimbursable training expense for Adams County, or would they need to somehow separate out an amount for lunch and refreshments?
Based on the DHS’s interpretation of CMS guidelines, in practice the department provides guidance that meals provided at trainings are not a Medicaid-reimbursable expense. This guidance is consistent across all CCS and WIMCR providers.
In terms of your example of organizing a full-day CCS orientation training for providers within your region. It would be appropriate for Adams County to divide the cost four ways and invoice the three counties. Because the cost of meals and refreshments is not reimbursable, Adams County should subtract this cost before dividing the cost four ways in order to invoice counties the cost of the training net of meals and refreshments.
In your example of a registration fee of $150, the entire fee may be reported under the Overhead Non-Personnel section of the cost report. Since the $150 is a flat registration fee, the county would not need to separate out the amount for lunch and refreshments.
Provided by: Steven Kulig, Budget and Policy Analyst, DHS, DHCAA, BFM on 2/26/16