school-based access program (sbap) breakout session...
TRANSCRIPT
School-Based ACCESS
Program (SBAP)
Breakout Session C:
Compliance
FY2017-2018 Statewide Training
1
2
Compliance Training Objective
• Learning Objective: Upon completion of this session, participants
will be able to successfully prepare and respond to an SBAP Audit.
• Key Topics:
• Common Audit Findings
• Prescribed vs. Documented Services
• How to Survive an Audit?
• Self-Audits
• Deleted Logs
• Self-Disclosures
• Documentation and Storage
• Documentation Reminders
• Medical Practitioner Authorization Forms (MPAF)
• Evaluation Documentation
• Exception Reports
• Preclusions/Exclusions
3
Bureau of Program Integrity
• The Bureau of Program Integrity (BPI) is housed within the
Pennsylvania Department of Human Services (DHS).
• BPI includes medical professionals responsible for preventing,
detecting, deterring, and correcting fraud, abuse, and wasteful
practices by providers of MA services, including LEAs,
applying administrative sanctions, and referring cases of
potential fraud to the appropriate enforcement agency.
4
Common Audit Findings
• Services billed were not in IEP
• Precluded providers
• Lack of required supervisory signatures
• Documentation not maintained
• Gaps in Medical Practitioner Authorization Form (MPAF)
• More units of service billed than in the IEP
Prescribed vs. Documented Services
• Units of service billed must be equal to or less than the units of
service authorized on the Medical Practitioner Authorization Form
(MPAF).
• BPI continues to find instances where there are more units of service
billed than are authorized.
• You are highly encouraged to verify through the self-audit process
that the duration and frequency of the services billed are equal to or
less than the duration and frequency recommended in the IEP and
authorized on the MPAF.
5
6
How to Survive an Audit?
• LEA is notified of Records Request – PAUSE AND TAKE A DEEP
BREATH!
• Open a line of communication (SBAP vendors and/or DHS)
• Make a copy of the documentation for LEA’s records
• If LEA cannot meet timeframe given, reach out to the auditor
requesting records
• Preliminary Findings – LEA is notified of any potential violations.
This is an opportunity to provide any additional information or
clarification that may change the outcome of the initial findings.
• Final Findings – LEA is notified of overpayment and appeal rights
are given.
• Payback & Correction Action Plan (CAP)
7
Prepare ahead of Audits
• Reduce Risks with Preparation!
• Stay up to date with changes to rules and regulations
• Train all staff for compliance
• Take advantage of training opportunities (vendors, annual SBAP, etc.)
• Regularly conduct self-audits
8
Self-Audits
• Best Practice: Perform periodic self-audits on your LEA’s direct
service and transportation compliance data and documentation to
ensure services were rendered and billed correctly.
• The Self-Audit Tool provides checklist of documents/records
required for SBAP billing.
• Mock Self-Audit
NOTE: Just because you find an error on a log doesn’t mean it
was a paid claim! Be sure to check with BPI or PCG on whether
the log resulted in a paid claim to determine next action.
Deleted Logs
• Reminder: Requesting deletion of logs through EasyTrac does not automatically void paid claims in DHS’ PROMISe™ system.
• Active Claiming Periods: LEAs may request to delete service logs directly through EasyTrac. If service logs have been paid, PCG will submit these to DHS for void processing (quarterly).
– Example: Date of Service March 1, 2017 is an active claiming period/not cost-settled
• Non-Active Claiming Periods: EasyTrac prohibits LEAs from requesting deletion of service logs from prior claiming periods. LEAs will need to contact PCG or BPI to submit service logs for voids processing. Effective April 2017, LEAs requests for deletion of service logs from prior claiming periods will be provided to BPI.
– Example: Date of Service March 1, 2016 is a non-active claiming period/cost-settled
9
Self-Disclosures
• Providers have a legal and ethical commitment to return
inappropriate Medicaid payments.
• LEAs are encouraged to self disclose billing errors and violations
identified.
• Disclosures should be made directly to the BPI SBAP Coordinator at
(717) 705-6873
10
11
Documentation and Storage
• Scanning – Must maintain originals
• Electronic Records/Storage
• EasyTrac Export – Backup
• Physical Records/Storage
• Retain records for at least six (6) years from date of service
NOTE: Discontinued participation in SBAP doesn’t avoid the
LEA’s obligation as an MA Provider to follow the records retention
requirement.
12
EasyTrac Export - Backup
Users have
the ability to
create a
document that
displays all
service logs
entered into
EasyTrac.
13
Documentation Reminders
• Speech Supervision: SBAP services provided by a PDE-certified
speech pathologist are only compensable under supervision and
must include a supervisory signature by a licensed speech
pathologist or speech pathologist with an ASHA CCC on all SBAP
documentation including logs. Refer to Section 3.15 Speech and
Language Services in the SBAP Handbook for more details about
the requirement.
• Medication Administration: When documenting services provided for
Medication Administration, the Medication Name and Dosage are
required. The Medication Name and Dosage should be documented
in the SBAP Nursing log and/or in the Daily Progress Note section of
EasyTrac.
14
Documentation Reminders (cont.)
• Use of “Daily” in IEP examples:
• Personal Care services up to 5 hours daily throughout the school day
• Personal Care services up to but not to exceed 6 hours daily when
school is in session
• Electronic Signature Verification Statement : LEA is responsible
to maintain forms. Do not share sign on/password information!
• "On behalf of" Permission Agreement : LEA is responsible to
maintain forms when a designated user(s) is logging on behalf of
providers.
Medical Practitioner Authorization Form
15
Reminder:
MPAF =
Medical
Necessity!
Medical Practitioner Authorization Form
16
Sharing MPAFs:
IUs and School
Districts may share
MPAF so long as
both entities are
listed on the form
and one entity
retains the original.
Must coordinate so
no duplication of
billing!
Evaluations Documentation
• How to properly document multiple dates of service for evaluations
17
Exception Reports
• How to use monthly exception reports to optimize billing?
18
Report
Date IEP
PA
Secure
ID MPAF
Prim
Disability
Prov
Certif
Parental
Consent
Jan 2017 5,534 9 8,268 1,314 5,077 1,793
Feb 2017 7,375 805 11,815 842 5,647 3,329
Mar 2017 23,902 3,748 38,410 3,209 20,338 12,544
Apr 2017 35,868 2,620 75,223 3,089 28,447 17,232
May 2017 26,847 1,862 68,789 1,948 21,360 14,223
June 2017 21,757 1,650 60,060 4,748 15,703 10,872
July 2017 28,194 1,151 80,112 4,036 32,249 14,656
Aug 2017 22,179 1,093 228,051 13,160 15,058 10,837
Sept 2017 24,409 1,161 179,376 3,272 13,634 10,481
Provider Screenings (Preclusions/Exclusions)
• LEAs as MA Providers are required to screen employees and
contractors for exclusion from participation in federal health care
programs, prior to hire then on an ongoing monthly basis.
– An excluded/precluded individual or entity cannot be part of
a task that is reimbursed by Federal healthcare program
dollars.
• LEAs must use all 3 preclusion websites:
– Office of Inspector General (LEIE)
– System for Award Management (SAM)
– Medicheck (DHS)
19
Provider Screenings (Preclusions/Exclusions)
• This requirement includes all employees, vendors, contractors and
service providers whose functions are a necessary component of
providing items and services to MA beneficiaries and who are
involved in generating a claim to bill for services.
• For example, in SBAP this includes all individuals listed on the LEA’s
staff pool lists, supervisors or teachers permitted to sign logs,
physicians and/or CRNPs signing medical authorizations, and
superintendents if he/she signs IEPs or has any association with
SBAP. Refer to Section 5.4 Preclusion/Exclusion Checks in the
SBAP Handbook for more details about the requirement.
• Helpful tip: LEAs can consider modifying their contracts to reflect the
exclusion prohibition and require the contractor or vendor to check
their own employees.
20
DHS Preclusion Actions
• 2017 YTD 191
• 2016 total 295
• 2015 total 232
*Selection of provider types that
could work within the SBAP
21
*Provider Type YTD 2017 2016 2015
RN 16 38 34
CRNP 1 5 3
LPN 13 23 23
OT 1
PT 2 4 1
PCA 16 43 33
HOME HEALTH AIDE 5 14 4
PHYSICIAN 64 74 93
PSYCHOLOGIST 3 6 6
SOCIAL WORKER 3 2 1
COUNSELOR 6 3 1
INDIVIDUAL 19 34 19
CORPORATIONS 19 9 13
SPEECH 4 1
DENTIST 4 7
PODIATRIST 8 1
CHIROPRACTOR 2 6
MT/TSS/CPS/BSC 7 8
PHARMACIST 3 9
EMT 2
OPTOMITRIST 2
Presenter Contact Information
Pam Tressler
Bureau of Program Integrity
(717) 705-6873
22
SBAP Training Survey
We want to hear from you!
Please provide feedback on the Compliance session by completing this short survey:
https://www.surveymonkey.com/r/C58NP22
23