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Home My WebLink Aboutbocc.packet.11192014 - NWCCOG MOU AGENDA ITEM SUMMARY REGULAR MEETING DATE: Wednesday,November 19, 2014 AGENDA ITEM TITLE: Resolution Approving Memorandum of Understanding with Northwest Colorado Council of Governments for the Colorado Medicaid Non-Emergent Medical Transportation Brokerage Program STAFF RESPONSIBLE: Mitzi Ledingham, Health and Human Services ISSUE STATEMENT: Northwest Colorado Council of Governments (NWCCOG) received approval in April, 2014 to proceed with a regional Non-Emergent Medical Transportation(NEMT) billing program for the seven counties in its region: Eagle, Garfield, Grand, Jackson, Pitkin, Routt and Summit. The Board of County Commissioners is asked today to approve a Memorandum of Understanding between NWCCOG and Pitkin County to proceed with implementing this billing program for Pitkin County. BACKGROUND: The Regional Transportation Coordinating Council (RTCC) of the NWCCOG is focused on coordinating existing public and private transit providers with other human services providers by promoting, enhancing and facilitating access to transportation services through a coordinated system that is easily available to customers from anywhere in the region. The NEMT program has been a project of the RTCC since its beginning three years ago, receiving high interest and support from members,particularly the Health and Human Services representatives on the RTCC. The (NEMT) is a Colorado Department of Healthcare Policy&Financing Program(HCPF) whereby the Department of Human Services in each county is required to provide transportation for any Medicaid client with no other means of transportation to and from medical appointments. As a component of service delivery outlined in the intergovernmental agreement between Eagle and Pitkin Counties, Eagle and Pitkin health and human services (HHS) staff have worked together on a method for administering this program since 2007. The development of a single entry point for NEMT scheduling and billing through NWCCOG is seen as a significant savings of staff time and effort, as well as offering the potential of an efficient Regional Medicaid Billing mechanism developed by NWCCOG's Mobility Management program. To date,NWCCOG reports that Routt, Summit and Grand have completed the Memorandum of Understanding (MOU)process and their NEMT programs are being administered by NWCCOG. Eagle County's MOU is in process currently, to be scheduled shortly with the Eagle Board of County Commissioners. LINK TO STRATEGIC PLAN: Livable and Supportive Community 1 1 KEY DISCUSSION ITEMS: This change is revenue neutral, as no costs are involved in this MOU transaction. NWCCOG will be the billing agent for both Eagle and Pitkin's NEMT customers. Transfer of management of this program will relieve HHS staff of the administrative duties associated with all aspects of this transportation program. BUDGETARY IMPACT: None RECOMMENDED BOCC ACTION: Approve the resolution approving the MOU for NWCCOG to administer the NEMT program for Pitkin County and authorizing the Chair of the Board of Pitkin County Commissioners to sign. ATTACHMENTS: • Resolution • Memorandum of Understanding between Pitkin County, Colorado and the Northwest Colorado Council of Governments 2 2 RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF PITKIN COUNTY, COLORADO APPROVING A MEMORANDUM OF UNDERSTANDING BETWEEN PITKIN COUNTY, COLORADO AND THE NORTHWEST COLORADO COUNCIL OF GOVERNMENTS (NWCCOG) FOR IMPLEMENTATION OF THE COLORADO MEDICAID NON- EMERGENT MEDICAL TRANSPORTATION BROKERAGE PROGRAM RESOLUTION NO. , 2014 RECITALS 1. The Non-Emergent Medical Transportation program(NEMT) is a Colorado Department of Healthcare Policy&Financing Program(HCPF)whereby the Department of Human Services in each county is required to provide transportation for any Medicaid client with no other means of transportation to and from medical appointments. Northwest Colorado Council of Governments (NWCCOG)has received approval by HCPF to enter into agreements with smaller counties outside of the front range for NWCCOG to implement and administer the NEMT program as authorized by Colorado Medicaid. 2. NWCCOG will act as an authorized agent of Pitkin County Health and Human Services in ensuring that NEMT program activities including approvals for transportation,billing, reimbursement of transportation providers or Medicaid recipients, and retention of appropriate records of said services are provided. 3. Pitkin County Board of County Commissioners recognizes the importance of a single access point for transportation resources for Medicaid qualified recipients and agrees that the NWCCOG Mobility Management Program is well suited to undertake this task as a billing agent for Pitkin County; NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Pitkin County, Colorado: that the Board approves the attached Memorandum of Understanding with Northwest Colorado Council of Governments for the Colorado Medicaid Non-Emergent Medical Transportation Brokerage Program. INTRODUCED, FIRST READ, AND SET FOR PUBLIC HEARING ON THE DAY OF 2014. NOTICE OF PUBLIC HEARING AND TITLE AND SHORT SUMMARY OF THE RESOLUTION PUBLISHED IN THE ASPEN TIMES WEEKLY ON THE DAY OF , 2014. NOTICE OF PUBLIC HEARING AND THE FULL TEXT OF THE RESOLUTION POSTED ON THE OFFICIAL PITKIN COUNTY WEBSITE (www.aspenpitkin.com) ON THE DAY OF 2014. ADOPTED AFTER FINAL READING AND PUBLIC HEARING ON THE DAY OF 2014. 1 3 PUBLISHED BY TITLE AND SHORT SUMMARY, AFTER ADOPTION, IN THE ASPEN TIMES WEEKLY ON THE DAY OF , 2014. POSTED BY TITLE AND SHORT SUMMARY ON THE OFFICIAL PITKIN COUNTY WEBSITE (www.aspenpitkin.com) ON THE DAY OF 2014. ATTEST: BOARD OF COUNTY COMMISSIONERS By By: Jeanette Jones Robert A. Ittner, Jr., Chair Deputy County Clerk Date: APPROVED AS TO FORM: MANAGER APPROVAL John Ely, County Attorney Jon Peacock, County Manager 4 Memorandum of Understanding between Pitkin County, Colorado and the Northwest Colorado Council of Governments This is a Memorandum of Understanding (MOU) hereby entered into by and between Pitkin County, Colorado (the "County") and the Northwest Colorado Council of Governments ("NWCCOG") (each a "party" and collectively referred to as the "parties") regarding the Colorado Medicaid Non-Emergent Medical Transportation Brokerage Program. I. Purpose and Scope The purpose of this MOU is to clearly identify the roles and responsibilities of each party as they relate to the implementation and administration of Non-Emergent Medical Transportation (NEMT) billing services as authorized by Colorado Medicaid. The intent of this MOU is to set forth the provisions by which NWCCOG will provide 2 distinct levels of support to the Pitkin County Department of Health and Human Services,including: 1. The timely processing and administration of NEMT billing services for the County,the coordination of transportation providers providing Medicaid covered transportation services (mobility vehicles, wheelchair vans, ambulance, taxi, stretcher van, train, airplane, bus, private vehicle). 2. To provide Medicaid qualified recipients with a single access point for transportation resources as administrated through the NWCCOG Mobility Management Program. II. MOU Terms The term of this MOU is effective as of November 1, 2014 and shall remain in effect until October 31, 2015. This MOU may be extended for additional one year periods upon written agreement of the parties. III. MOU Provisions The parties agree to the following provisions: 1. To ensure that NEMT program activities will be conducted in compliance with all applicable Colorado laws, rules and regulations as outlined by The Colorado Department of Health Care Policy and Financing. 2. To ensure that NEMT program activities will be conducted in compliance with HIPPA Privacy Practices,the Colorado Medicaid Privacy Practices standards,and as an authorized agent of Pitkin County Health and Human Services. 3. That NEMT Claims will be filed in accordance with the timely filing requirements outlined by The Colorado Department of Health Care Policy and Financing. 4. That NEMT Claims reimbursement to transportation providers and Medicaid recipients will occur in a timely fashion not to exceed 15 days from receipt of claim from Medicaid. 5. Prior Authorization (PAR) and eligibility determination will be completed by NWCCOG Mobility Management Program prior to approval or denial of service. 6. Any denial of service will be made in writing, in the client's primary language,and delivered to the client and to the Pitkin County Department of Health and Human Services with the appropriate information concerning the reason for denial,the "Client Right to Appeal" language and instructions in the same language that is included on the back of all formal claim denials sent from the County's fiscal agent. See Appendix 1 Denial of Service Letter,Appendix 11 Client Right to Appeal. 3 5 7. NWCCOG shall retain 15% of the transportation claims reimbursement to cover administrative expenses associated with the NEMT Services provided by NWCCOG. The remaining 85%of the claims reimbursement will be paid to the transportation provider.Transportation providers are identified as any person or entity other than the qualified Medicaid recipient. When transportation is provided by the Medicaid recipient, spouse of a Medicaid Recipient or parent/guardian of a minor Medicaid recipient, NCCOG will waive the 15% administration fee and will remit full reimbursement directly to the Medicaid recipient,spouse,or their legal parent/guardian as required by Medicaid policy. 8. NWCCOG shall retain on file appropriate Certification of Transportation Providers in accordance with the NEMT Billing Program. Certifications will include copies of vehicle registrations,appropriate vehicle insurance,and copy of a valid driver's license for the vehicle operator. IV. Individual Party Responsibilities 1. NWCCOG will act as the NEMT Services Broker and facilitate the management of NEMT Services throughout Pitkin County. 2. NWCCOG,through the Mobility Management Program will approve, refer for transportation,verify receipt of services, bill for approved services, reimburse transportation providers or Medicaid recipients for approved Medicaid NEMT services, and retain appropriate billing records of said services. 3. The County,through its Department of Health and Human Services,will refer all individuals requesting NEMT services to the NWCCOG Mobility Management Program. 4. The County,through its Department of Health and Human Services,will forward any Medicaid request for NEMT reimbursement paperwork to NWCCOG within one week of receipt to facilitate timely processing of Medicaid Claims. 5. NWCCOG shall provide a written report of accountability for paid NEMT services on a monthly basis to the Director of Pitkin County Health and Human Services.This accountability report will be available by the 16th of each month and account for the activity processed in the prior calendar month. V. MOU Operational Framework The following describes how NWCCOG and the County will work together on the MOU scope and activities. 1. The County,through its Department of Health and Human Services,will direct any individuals requesting NEMT services to NWCCOG Mobility Management Program. The Department of Health and Human Services will forward any Medicaid Transportation Reimbursement Forms to NWCCOG Mobility Management Program for processing. 2. NWCCOG Mobility Management Program will verify eligibility for NEMT services,obtain prior authorizations where required,verify appropriateness of service, refer approved recipients to transportation providers as needed, process all NEMT billing functions after proper documentation is received from the transportation recipient, make timely reimbursement to the transportation provider or Medicaid recipient following payment of claims,and submit a monthly accountability report to the County Department of Health and Human Services on all claims processed. See Appendix III:NEMT Flow Chart,Appendix IV:NEMT Accountability Report. 4 6 VI. Budget NWCCOG shall retain 15%of the transportation claims reimbursement as stated in Section III, Number 7, above, to cover administrative expenses associated with the NEMT Services provided by NWCCOG. The remaining 85% of the claims reimbursement will be paid to the transportation provider. When transportation is self-provided by the Medicaid member the 15%administrative fee shall be waived as outlined in Section III, Number 7, above. There will be no additional cost to the Colorado Medical Assistance Program. See Appendix V: NEMT Sample Budget. VII. Forms The following describes the forms utilized in the NEMT Work Flow Form 1: Medicaid Trip Request Checklist. Appendix VI Form 2: Medicaid Transportation Reimbursement Form. Appendix VII Form 3: Monthly Accountability Report Sample. Appendix IV Form 4: Denial of Service Letter and Client Right to Appeal. Appendix I, Appendix II Form 5: NEMT Services Flow Chart. Appendix III VIII. Modification and Termination 1. Modification of this agreement can be made by mutual consent of NWCCOG Mobility Management Program Manager with approval of the NWCCOG Executive Director, and the Director of Pitkin County Department of Health and Human Services,with approval of the Pitkin County Board of County Commissioners. All modifications will be made in writing and signed by both parties. 2. This agreement can be terminated according to the following provisions. - Either party may terminate this agreement upon 30 days written notice to the other. - The action of termination has been preceded by reasonable efforts on the part of both parties to address whatever problems or barriers have emerged that have threatened the integrity of this MOU. IX. Effective Date and Signatures This MOU shall be binding upon the signatures of the County and NWCCOG. It shall be effective as of November 1, 2014. XI. Independent Contractor This MOU is not intended to create any agency or employment relationships between the parties nor is it intended to create any third party rights or beneficiaries. XII. Applicable Law This MOU and the parties' conduct hereunder shall be subject to local, state and federal laws and regulations, including requirements associated with confidentiality of information and HIPPA privacy requirements. 5 7 Signatures and Dates: COUNTY OF PITKIN, STATE OF COLORADO, By and Through Its BOARD OF COUNTY COMMISSIONERS By: Robert A. Ittner, Jr., Chair Attest: By: Jeanette Jones, Clerk to the Board Northwest Colorado Council of Governments(NWCCOG) Liz Mullen, Executive Director Date 6 8 exvillik. 'o ci v N T PO Box 2308 s 249 Warren Ave s Siverthorne,CO 80498s 970-468-0295 s Fax 970-468-1208•www.nwccog.org Appendix I MEMBER [Date] JURISDICTIONS City of Glenwood Springs [Name of Client] ress I] City of Steamboat Springs [[Address II] [City, State,Zip] Town of Carbondale EAGLE COUNTY Ms.[Name]: Basalt GEagle n yp Following your request for Non Emergent Medical Transportation Services a review of your case was Mintum conducted.You are currently not eligible to receive Non Emergent Medical Transportation Services Red Cliff for the following reasons Vali GRAND COUNTY I. [list mason here] Fraser Granby Grand Lake Should you feel this determination to be in error,please consult the Client Appeal Rights process Hot Sulphur Springs included with this letter. Kremming Writer Park Sincerely, JACKSON COUNTY Walden PRIM COUNTY Aspen Snowmass Vllage Laurie Patterson SUMMIT COUNTY Mobility Program Assistant F'lon isco Northwestern Colorado Council of Governments Montezuma 970-468-0295 ext 105 Shrerthome Enclosures): Client Appeal Rights 9 Appendix II CLIENT APPEALS RIGHTS If you agree with the decision,you do not need to take any further action.If you think the decision is wrong,you can appeal and ask for a hearing.You may have to appeal hearing with an Administrative Law Judge.You may represent yourself,or have a lawyer,a relative,a friend or other spokesperson assist you as your authorized representative. How to Appeal: 1.You must ask for a hearing in writing.This is called a LETTER OF APPEAL. 2.Your letter of appeal must include: a.Your name,address,phone number and Medicaid number; b.Why you want a hearing;and c.A copy of the front page of the notice of action you are appealing. 3.You may ask for a telephone hearing rather than appear in person. 4.Mail or fax your letter of appeals to: OFFICE OF ADMINISTRATIVE COURTS 633 17TH STREET,SUITE 1300 DENVER,CO 80202 FAX 303-866-5909 5.Your letter of appeal must be received by the Office of Administrative Courts no later than thirty(30)calendar days from the date of this notice of action.The date of the notice of action is located on the front of this notice. 6.The Office of Administrative Courts will contact you by mail with the date,time and place for your hearing with the Administrative Law Judge. Continued Benefits:To continue receiving the denied services listed on the notice,you must file your request for a hearing in writing before the effective date on the front of this notice.You may continue receiving services while you are waiting for a decision on your appeal.If you lose your appeal,you must pay back the cost of the services you received during the appeal.If you win your appeal,the State will pay your provider for the service(s)you received during your appeal process.Your provider is responsible for reimbursing you for the amount you paid them during your appeal. If you have questions about this process,please call: CUSTOMER SERVICE: 303-866-3513(within the Denver Metro area) 1-800-221-3943(outside the Denver Metro area) Se Habla Espanol DISCRIMINATION If you believe that you have been discrimination against because of race,color,sex,age,religion,national origin,or disability, you have the right to file a complainant with:the U.S. Department of Health&Human Services,Office for Civil Rights.999 18th Street,Suite 417, Denver,CO 80202.Voice phone:303-844-2024 or TDD 303-844-3439. If you have any questions,or need help to file your complaint,call OCR toll-free at 1-800-368-1019(voice)or 1-800-537-7697(TDD).You may send an email to OCRcomplaint@hhs.gov. STATEMENT OF PENALITIES If you make a willfully false statement or representation,or use other fraudulent methods to obtain public assistance or medical assistance you are not entitled to,you could be prosecuted for theft under state and/or federal law. If you are convicted by a court of fraudulently obtaining such assistance,you could be subject to a fine and/or imprisonment for theft. 10 Appendix III NEMT Services Flowchart Initial NEMT request Info collection Confirm Medicaid appointment/PAR Referral/direct checklist Complete client Medicaid Checklist Denial Letter Deny Sent Cole Client Referral for Transportation Transportation occurs scheduling Reimbursement �, ~ Request form Received Post Billing entered to from either Medicaid Appointment Web Portal Recipient (self- confirmation provided) or Transportation Provider Billing Processed by Medicaid Paid claims Claim Payment requests Reimbursement deposited to reconciliation/ to NWCCOG check cut and mailed NWCCOG Authorization for ` Financial to Transportation payment department Provider Reconciliation and client accountability shared 411, monthly with contracted organization 11 APPENDIX IV NEMT Billing Accountability Report I X Month County Date claim amount of Amount Administration Client Identifier received claim paid Fee Date Paid Paid To Check# Medicaid# 2/15/2014 31.78 I 27.oi 4.77 02/29/2014 ABC Transportation 29528 12 D iii. NEMT Sample Budget Q Based on Medicaid rates effective o7/1o/2012 Code Description ount Billed to Amount Paid to Amount Paid PA Medicaid Transport Provider Administrative Fee %85 %15 Nonemergency transportation, per mile-vehicle provided by volunteer(individual or Aoo8o organization),with no vested interest $0.36 $0.31 $0.05 NO PAR Nonemergency transportation, per mile-vehicle provided by individual (familymember, self,neighbor) Aoo90 with vested interest $0.36 $0.31 $0.05 NO PAR Aoloo Nonemergency transportation; taxi _ $46.96 $39.92 A $7.04 NO PAR Nonemergency transportation and bus,intra-or Aollo interstate carrier Manually Priced Manually Priced Manually Priced NO PAR Nonemergency transportation: mini-bus,mountain Ao12o area transports, or other transportation systems $15.01 $12.76 2.25 NO PAR Ao13o Nonemergency transportation:wheelchair van $18.69 $15.89 $2.8o NO PAR Nonemergency transportation and air travel(private Ao14o or commercial), intra-or interstate i Manually Priced Manually Priced Manually Priced ALWAYS PAR Nonemergency transportation: ancillary:lodging- Aoi8o Recipient $34.76 $29.55 $5.21 ALWAYS PAR Nonemergency transportation: ancillary:meals- Ao190 Recipient $15.30 $13.01 $2.3o ALWAYS PAR Nonemergency transportation: ancillary:lodging- A0200 Escort $34.76 $29.55 $5.21 ALWAYS PAR Nonemergency transportation: ancillary:meals- A0210 Escort $15.30 $13.01 $2.3o ALWAYS PAR So2o9 Wheelchair van,mileage,per mile $0.75 $0.64 $o.11 NO PAR Nonemergency transportation; patient attendant/ T2001 escort Manually Priced Manually Priced Manually Priced NO PAR T2oo3 Nonemergency transportation; encounter/trip $1.63 $1.39 $0.24 NO PAR 1 T2005 Nonemergency transportation; stretcher van $18.69 $15.89 $2.8o NO PAR ------------------------------------------ 13 APPENDIX VI Medicaid Trip Request Checklist Client Information Appointment Confirmation CD__ Date of of Request: Client Name: Confirmed By: Client Telephone: Date of call: Client Address: Spoke with: City, State, Zip: Is the visit a benefit of Medicaid? County of Residence: Is the visit medically necessary? Date of Birth: Medicaid #: Referring Doctor: Address: Phone: Comments: Appointment Information Appointment Date: Appointment Time: Appointment Place: Appointment Address: City, State, Zip: Functional Status Circle one: Ambulatory Wheelchair Means of Transportation Circle One: Self Family Friend Medicaid Trip Approved [ ] Denied [ ] Reason: 14 APPENDIX VII Medicaid Transportation Reimbursment Form -a For Month of ,20 Prior Authorization by: I m Client Name: Medicaidkf: Date: Q- x Client Address: Date of Birth: _PAR Date Range: from to < City,State,Zip Units/miles of service total: Client Phone# _ Transportation Provider Information Name, Mobility Van/Wheelchair Van,Over the Cap, Transportation Provider Address,Phone Oxygen _ Signature of Provider: PAR Date Span,units,and days authorized: Special Request or Need Client's Signature To Be Completed By Medical Provider Appt Appt Number Medicaid provided Signature of medical provider&date Trip Origination Address Destination Date Time of miles service?Yes/No of service 15