PERM Update

1. PERM Update NAMPI Conference August 27, 2008

2. Panel Members Kevin Jones � State of Ohio Douglas Nock � CMS Eppie Deitz � State of Illinois Jan Inglish � State of California Tom Welch � State of California

3. Agenda PERM TAG CMS Update FFY06 Lessons Learned/Best Practices FFY07 Lessons Learned/Best Practices Question and Answer

4. PERM TAG Membership Chair - Chuck Duarte � Nevada Region 1 (West) Regions 2 (Midwest) Region 3 (South) Region 4 (Northeast) CMS NASMD/APHSA

5. Working Groups EstablishedBy PERM TAG Difference Resolution Process Chair � Kevin Jones � Ohio Error Rate Reduction Committee Chair � Jan Inglish � California PERM Eligibility Review/MEQC Integration Chair - Bruce Truitt - Texas

6. Items TAG Currently Addressing Modifications to the MR1 and MR2 letters CMS-64 Reporting Pre-cycle timelines Unique claim identifier Beneficiary claims paid as an administrative claim CMS-64 Reporting Reversing an error/adjustment of claims, through the CMS-64 reporting process, will be refunded to the states. Pre-cycle timelines CMS is proposing to start with FY09 in July 2008 to increase preparation time for contractors to work with states. Requesting full claims details upfront to shorten the PERM cycle time. TAG members expressed concerns in ensuring all providers information is up-to-date for the whole universe. Unique claim identifier PERM ID - state, program (Medicaid or SCHIP), the fiscal year being sampled, what quarter or month of sampling, whether the sampling unit is a fee for service claim, managed care record, fixed payment, or eligibility sampling unit, and a sequence number to make it unique. This PERM ID will follow each sampling unit in the database and documentation contractor and review contractor systems Beneficiary claims PERM samples include claims for non-emergency transportation paid as offline administrative claims Administrative case management using state Medicaid agency staff.� These are not claimed through MMIS but are billed on the CMS 64 as an administrative expense other claim types may present problems in the future either because they are non-traditional payments for recipient services, or are paid as an offline administrative function.CMS-64 Reporting Reversing an error/adjustment of claims, through the CMS-64 reporting process, will be refunded to the states. Pre-cycle timelines CMS is proposing to start with FY09 in July 2008 to increase preparation time for contractors to work with states. Requesting full claims details upfront to shorten the PERM cycle time. TAG members expressed concerns in ensuring all providers information is up-to-date for the whole universe. Unique claim identifier PERM ID - state, program (Medicaid or SCHIP), the fiscal year being sampled, what quarter or month of sampling, whether the sampling unit is a fee for service claim, managed care record, fixed payment, or eligibility sampling unit, and a sequence number to make it unique. This PERM ID will follow each sampling unit in the database and documentation contractor and review contractor systems Beneficiary claims PERM samples include claims for non-emergency transportation paid as offline administrative claims Administrative case management using state Medicaid agency staff.� These are not claimed through MMIS but are billed on the CMS 64 as an administrative expense other claim types may present problems in the future either because they are non-traditional payments for recipient services, or are paid as an offline administrative function.

7. State Contacts States identified to NASMD a POC Medicaid SCHIP POC Updates Contact L�Ph�sha M Williams @ LWilliams@aphsa.org TAG uses state PERM POC to distribute information � please be sure to keep current

8. 8 Progress Update & Future Presented by Doug Nock, Director, Division of Analysis & Evaluation Program Integrity Group Office of Financial Management Centers for Medicare & Medicaid Services

9. Agenda Background/Overview Status of Measurement Operations High Level Findings from FY 2006 Measurement Current Issues Process Improvements Future Vision Q & A

10. PERM Overview CMS developed the PERM program to comply with the Improper Payments Information Act of 2002 (IPIA). PERM measures improper payments in Medicaid and the State Children�s Health Insurance Program (SCHIP). CMS uses a 17-state rotation for PERM. Each state is reviewed once every three years. This rotation allows states to plan for the reviews as they know in advance when they will be measured. PERM uses a national contracting strategy to estimate improper payments in Medicaid and SCHIP, including a statistical contractor (SC), documentation/database contractor (DDC), and review contractor (RC).

11. PERM Cycle Timeframes

12. PERM Cycle Updates FY 2006 & FY 2007: Reported FY 2006 preliminary Medicaid fee-for-service (FFS) error rate of 18.5% in the FY 2007 Performance and Accountability Report (PAR) or its equivalent Preliminary rate based on Quarter 1 and Quarter 2 of FY 2006 Measurement process is complete for FY 2006 and FY 2007, annual error rates to be calculated and reported in the FY 2008 PAR or its equivalent Annual error rate measurement report and analysis: in progress State Corrective Action Plans/National Error Rate Reduction Plan: December 2008

13. Error Rate Rollout The following dates represent the general timeframes associated with the rollout of PERM error rates: Late summer: CMS calculates state and national error rates Fall: Internal clearance process begins CMS reports state error rates on the review contractor�s website for each state�s information National error rates reported in the PAR or its equivalent

14. Cycle Updates Continued FY 2008: Quarter 1-Quarter 3 FFS and managed care universe data due as of 7/15; the following represent the number of complete universes to date: 46% of Quarter 1 25% of Quarter 2 20% of Quarter 3 Medical record request process and data processing reviews underway States performing eligibility case and payment reviews Next Steps: Complete FY 2008 measurement FY 2009: Cycle kicked off in late July Eligibility sampling plans due August 1 Intake calls to begin in September Pre-cycle: in progress

15. Draft Findings: Subject to Change 15 FY 2006 High Level Findings Medical Review No Documentation Insufficient Documentation Policy Violation Data Processing Pricing Error Logic Edit Error Third Party Liability Error

16. Draft Findings: Subject to Change 16 FY 2006 Findings Continued Comparisons: States with highest error rates had significant insufficient documentation errors, more than 5 times the rate of lower error rate states Overall cost per error is significantly higher ($300+) among smaller-sized states compared to larger states The larger the state, the more hospital service errors occurred The smaller the state, the more long term care errors occurred The average cost per error for both hospital and long term care services were greater than $1,500 regardless of state size All other service types ranged in costs less than $500 per error

17. Draft Findings: Subject to Change 17 CAP Focus: Large States

18. Draft Findings: Subject to Change 18 CAP Focus: Medium States

19. Draft Findings: Subject to Change 19 CAP Focus: Small States

20. Current Issues PERM contractor changes Statistical contractor: Lewin to Livanta Transition-Lewin is performing the following activities for FY 2008, which will transfer to Livanta for FY 2009 Universe Data Collection Eligibility Implementing state corrective action plans (CAP)/internal management Finalizing outstanding PERM policies and procedures

21. Process Improvements

22. Process Improvements Continued Website improvements New PERM 101 documents available on CMS PERM website at http://www.cms.hhs.gov/PERM/03_permprocess.asp to assist states in educating stakeholders Improved contractor website capabilities: secure website allows states to track the status of medical record requests Communication Cycle Managers Monthly cycle calls with affected states Quarterly face-to-face meetings between CMS and PERM contractors Expanded Technical Advisory Group (TAG) capacity by establishing the Error Rate Reduction Subcommittee, Eligibility TAG (MEQC/PERM), and the Difference Resolution Committee Increased involvement from CMSO Quarterly senior leadership meetings Monthly meetings with CMSO ARAs Ad hoc workgroups on future corrective actions at a national level

23. PERM Pre-Cycle For FY 2009, CMS is implementing a �pre-cycle� timeframe Phase One (August/September): Orientation calls and visits with state Medicaid/SCHIP program staff Phase Two (September/October): Intake calls with state Medicaid/SCHIP PERM staff to explain PERM data submission requirements Phase Three (October/December): Test Data Voluntary participation of up to 9 states States to create test data files and send to contractors to quality control and review in advance of first quarter data submission

24. Proposed Process Improvements The following process improvements have been proposed in the past year: Sampling and reviewing at the claim level Creation of a forum for states to discuss state-specific PERM issues and best practices Standardizing requirements for state provider appeals on recovery decisions Consolidation of PERM contractor websites PERM conferences/focused trainings Lessons learned from Lewin interviews

25. Corrective Actions

26. CAP Contact Information

27. Future Vision Provider Education Contractor Electronic Health Records Demo Minimum Data Set Decreased Operational Timeline Current environment: 26 month cycle FY 2012: 18 month operational cycle FY 2015: Annual measurement for all states

28. Payment Error Rate Measurement (PERM)Lessons Learned for FFY 2006 Illinois Department of Healthcare and Family ServicesOffice of Inspector General

29. Data and Policy Collection What worked best included: Core staff assigned to identify policy and data Lessons learned included: Setting up a file to track each sampled service

30. Medical Record Collection What worked best included: Translating the federal PERM letter for our providers Determining the right provider contact Initial contact with the providers by audit staff Subsequent follow up with providers Facilitate record collection with providers utilizing field staff

31. Medical Record Collection (Cont.) Lessons learned included: Not to rely solely on providers to respond to a letter Review medical records to determine if the providers complied with the record request Some larger providers (Walgreens) established PERM contacts

32. Data Processing Review What worked best included: Program and policy staff being readily available to assist contractors with questions Lessons learned included: Contractors needed assistance in navigating systems and understanding Illinois data

33. Medical Record Review What worked best included: Establish review group consisting of policy, program, audit, peer review, and clinical staff Clearly state response (minimize wording) Keep policy on hand to support dispute

34. Medical Record Review (Cont.) Lesson learned included: Have policy on hand and readily accessible There are discrepancies in how Medical Necessity policies are applied There are discrepancies in how LTC policies are applied Some errors required a clinical evaluation and response

35. Recoveries Lessons learned included: Notify provider as soon as an error is finalized Provider will appeal higher dollar errors

36. Contact: Eppie Dietz, Chief Bureau of Information Technology Office of Inspector General Illinois Department of Healthcare and Family Services 404 N. 5th Street Springfield, IL 62702 voice: 217/782-9841 fax:: 217/782-1745 email: Eppie.Dietz@illinois.gov

37. The California ExperienceLessons Learned & Best Practices California Department of Health Care Services Jan Inglish, N.P., Chief Audits & Investigations, Medical Review Branch Tom Welch, Chief Medi-Cal Eligibility Division

38. The Beginning of PERM in California PERM Design: 4/1-07� -� 6/01/07 PERM Universe: 7/1/07 � 7/15/08 PERM Sample: 2/1/08 � 7/15/08 States were not provided access to the contractor databases until the sample data was submitted. Prior training or a preview to the database was not provided, potentially slowing down the state�s ability to react as necessary for documentation requests, dispute resolution, and other CMS requirements. PERM Design: 4/1-07� -� 6/01/07 PERM Universe: 7/1/07 � 7/15/08 PERM Sample: 2/1/08 � 7/15/08 States were not provided access to the contractor databases until the sample data was submitted. Prior training or a preview to the database was not provided, potentially slowing down the state�s ability to react as necessary for documentation requests, dispute resolution, and other CMS requirements.

39. The PERM Claim Review Process Sample All sample claim data had to be verified by all agencies who are part of the Medi-Cal program. Multiple agency involvement California Department of Health Care Services (DHCS) Electronic Data Systems (EDS) Medi-Cal Dental Program (Denti-Cal) California Department of Mental Health (DMH) California Department of Social Services (DSS) California Department of Developmental Services (DDS)

40. The PERM Claim Review Process Sample Multiple Fiscal Intermediary Involvement Electronic Data Systems (EDS) Delta Dental Services Providers contacted by both DHCS and the CMS contractor Verification of mailing address and contact information Dual submission of claim documentation DHCS nurse review of claim documentation DHCS doctor, DMH psychiatrist, Denti-Cal dentist, or DSS representative reviewed/refuted each claim found to be in error by the Review Contractor. Only billing providers were contacted and requested to submit documentation. To truly measure fraud and abuse and medical necessity, the prescribing providers should have been contacted, as well.

41. California�s Workload Hours Expended for PERMAs of August 10, 2008

42. The California Experience Both Livanta and DHCS called each provider to verify contact and mailing information. Providers were required to submit all documentation to both CMS and DHCS Initial review of documentation by DHCS nursing staff Error review Multiple agency involvement Dispute prepared by a doctor, pharmacist, psychiatrist or dentist.

43. California�s Fall From Grace The universe was pulled from the DHCS PAID CLAIMS Encounter System (PCES) The PCES is used by DHCS to collect claim records from all agencies who are part of the Medi-Cal program. While the PCES is a good source to pull the universe, the PCES is not the system of record and does not store adequate data needed for the system of record to identify and populate the sample claim data. California received its sample last, on March 3, 2008 Due to the delay in populating the sample, the PERM Documentation/Database Contractor (DDC) requested documentation based upon the unverified data. Providers were requested to submit documentation based upon erroneous data. The verified data was submitted to the DDC in batches. Rather than repopulating their system with the verified data, the DDC wrote over the old data. No reconciliation was made between the sample and the verified data once it was submitted. PAID CLAIMS Encounter System (PCES) The Department of Health Services (DHS) manages California's Medi-Cal program� and the program's eligibility, scope of benefits, reimbursement, and related components. DHS contracts with Fiscal Intermediaries (FIs) to process fee-for-service claims and requires the Managed Care contractors to provide encounter records.� To obtain Medi-Cal funding, the waiver programs and Departments of Mental Health and Alcohol and Drug must submit claim records. DHS collects and processes all of these records for the various purposes outlined later in the Paid Claims Encounter System (PCES).� The current DHS FIs are Electronic Data Systems (EDS) and Delta Dental. Records for the services paid for in part with federal financial participation funds (FFP) are collected. This includes claims processed by Electronic Data Systems (EDS), Delta Dental Services, the Departments of Mental Health (DMH) and Alcohol and Drugs, services provided under such managed care (capitation) models as County Organized Health Systems (COHS), geographic managed care (GMC), and two-plan counties. The following list indicates uses of Paid Claim/Encounter data: Research - Public Health Analysis & Policy Setting - Program Management and Control - Budgeting (Local Assistance and Admin Support) - Rate Setting - Fraud and Abuse (Surveillance, Restricted Services, Case Finding, Case Building, Court Documents, etc.) � Audits - Third Party�Collections (Auto accidents, Estates, etc.) - Medicaid funding for other Departments/Programs - Mental Health/ADP - Short Doyle - Waivers for DDS, AIDS etc. - State and Federal Reporting - Drug Rebate - Volume purchase information - Comparing Health Models (FFS vs. Managed Care) - Data Warehousing, Data Mining and drill downPAID CLAIMS Encounter System (PCES) The Department of Health Services (DHS) manages California's Medi-Cal program� and the program's eligibility, scope of benefits, reimbursement, and related components. DHS contracts with Fiscal Intermediaries (FIs) to process fee-for-service claims and requires the Managed Care contractors to provide encounter records.� To obtain Medi-Cal funding, the waiver programs and Departments of Mental Health and Alcohol and Drug must submit claim records. DHS collects and processes all of these records for the various purposes outlined later in the Paid Claims Encounter System (PCES).� The current DHS FIs are Electronic Data Systems (EDS) and Delta Dental. Records for the services paid for in part with federal financial participation funds (FFP) are collected. This includes claims processed by Electronic Data Systems (EDS), Delta Dental Services, the Departments of Mental Health (DMH) and Alcohol and Drugs, services provided under such managed care (capitation) models as County Organized Health Systems (COHS), geographic managed care (GMC), and two-plan counties. The following list indicates uses of Paid Claim/Encounter data: Research - Public Health Analysis & Policy Setting - Program Management and Control - Budgeting (Local Assistance and Admin Support) - Rate Setting - Fraud and Abuse (Surveillance, Restricted Services, Case Finding, Case Building, Court Documents, etc.) � Audits - Third Party�Collections (Auto accidents, Estates, etc.) - Medicaid funding for other Departments/Programs - Mental Health/ADP - Short Doyle - Waivers for DDS, AIDS etc. - State and Federal Reporting - Drug Rebate - Volume purchase information - Comparing Health Models (FFS vs. Managed Care) - Data Warehousing, Data Mining and drill down

44. The Overall Impact of PERM The Error Rate Is Underestimated PERM focuses on the billing provider and does not include a review of the prescribing provider. The Error Rate Is Overestimated Documentation was either not submitted or not reviewed Pitfall Of All Error Rate Studies The errors not related to medical necessity are counted as if the claim should not have been paid. However, proof that the service was medically necessary would discount this error. The Medi-Cal Payment Error Study (MPES) 2006 1,147 claims in the sample Errors for medical necessity accounted for 2.51% of the overall payment error rate of 7.27% 1 claim out of 1,147 in the sample was deemed an error because the document could not be obtained from a closed pharmacy. Can not be counted as savings. PERM Stats as of 8/22/07 IHSS EDS Dental T19 Dental T21 DMH TCM DDS TOTALS Total # of Claims 76 772 15 28 84 3 51 1029 Total Docs Rec'd/CMS 74 740 14 27 83 2 33 973 Total Docs Rec'd/DHCS 24 292 14 11 64 1 34 440 Percent Received/CMS 97.37% 95.85% 93.33% 96.43% 98.81% 66.67% 64.71% 94.56% Percent Received/DHCS 31.58% 37.82% 93.33% 39.29% 76.19% 33.33% 66.67% 42.76% Can not be counted as savings. PERM Stats as of 8/22/07 IHSS EDS Dental T19 Dental T21 DMH TCM DDS TOTALS Total # of Claims 76 772 15 28 84 3 51 1029 Total Docs Rec'd/CMS 74 740 14 27 83 2 33 973 Total Docs Rec'd/DHCS 24 292 14 11 64 1 34 440 Percent Received/CMS 97.37% 95.85% 93.33% 96.43% 98.81% 66.67% 64.71% 94.56% Percent Received/DHCS 31.58% 37.82% 93.33% 39.29% 76.19% 33.33% 66.67% 42.76%

45. Eligibility Reviews Overview Similarities between MEQC and PERM Sample process developed in advance with minimal changes after the eligibility plan was approved in May 2007. Samples are month specific and sequential. Samples are limited to persons in receipt of Medicaid benefits during the sample month. Overview Similarities between MEQC and PERM: Field staff were able to adapt to the new review format with minimal impact. Although our state PERM eligibility plan was not approved until May 2007, staff were able to anticipate data system needs and developed the sample process in advance. Only minimal changes were required for the final process to be implemented. Although similar, PERM had definitive differences that required specialized data file extraction. PERM and MEQC samples are month specific and sequential, thus samples for January 2007 are followed by February 2007. PERM and MEQC samples are limited to persons in receipt of Medicaid benefits during the sample month. Persons with a share of cost must have met that share of cost in order for the person to be considered in receipt of Medicaid.Overview Similarities between MEQC and PERM: Field staff were able to adapt to the new review format with minimal impact. Although our state PERM eligibility plan was not approved until May 2007, staff were able to anticipate data system needs and developed the sample process in advance. Only minimal changes were required for the final process to be implemented. Although similar, PERM had definitive differences that required specialized data file extraction. PERM and MEQC samples are month specific and sequential, thus samples for January 2007 are followed by February 2007. PERM and MEQC samples are limited to persons in receipt of Medicaid benefits during the sample month. Persons with a share of cost must have met that share of cost in order for the person to be considered in receipt of Medicaid.

46. Eligibility Reviews Overview Differences between MEQC and PERM Overview Differences between MEQC and PERM: A case for PERM is a person � a case for MEQC is all reviewable family members of a physical case. PERM cases are stratified into three categories � MEQC cases have no stratification PERM cases are reviewed based on the most state action to establish/redetermine eligibility � MEQC cases are reviewed based on eligibility for the sample month. Actual field work did not commence until June 2007, which required staff to complete two months of reviews for each month throughout the balance of the PERM review period. The reviews were completed in January 2008. Although the differences in PERM required adaptation for staff, the differences also allowed the staff to complete the reviews successfully in the shortened review time frame. This was due primarily to the final difference, as noted. Because of the stratification, the reviewers evaluated the most recent state action. California administers the Medicaid program through the 58 County Welfare Departments (CWDs). The CWDs use one of 4 automated eligibility systems to collect eligibility data and for the majority of the Medicaid eligibility determinations. Many of the 58 CWDs also utilize imaging systems for storing eligibility documentation. Reviewers were able to limit the field review to the automated systems and paper case files for the last CWD action in most of the completed reviews. This allowed us to minimize time required to contact beneficiaries to obtain missing documentation.Overview Differences between MEQC and PERM: A case for PERM is a person � a case for MEQC is all reviewable family members of a physical case. PERM cases are stratified into three categories � MEQC cases have no stratification PERM cases are reviewed based on the most state action to establish/redetermine eligibility � MEQC cases are reviewed based on eligibility for the sample month. Actual field work did not commence until June 2007, which required staff to complete two months of reviews for each month throughout the balance of the PERM review period. The reviews were completed in January 2008. Although the differences in PERM required adaptation for staff, the differences also allowed the staff to complete the reviews successfully in the shortened review time frame. This was due primarily to the final difference, as noted. Because of the stratification, the reviewers evaluated the most recent state action. California administers the Medicaid program through the 58 County Welfare Departments (CWDs). The CWDs use one of 4 automated eligibility systems to collect eligibility data and for the majority of the Medicaid eligibility determinations. Many of the 58 CWDs also utilize imaging systems for storing eligibility documentation. Reviewers were able to limit the field review to the automated systems and paper case files for the last CWD action in most of the completed reviews. This allowed us to minimize time required to contact beneficiaries to obtain missing documentation.

47. Eligibility Reviews Results Active Case Reviews 504 active cases were reviewed 3 Cases resulted in total ineligibility with payment errors 1 Case resulted in total ineligibility without payment error 1 Understated Share of Cost for an otherwise eligible beneficiary with payment error. 1 Overstated Share of Cost for an otherwise eligible beneficiary without payment error. The initial active case error rate was 0.8%. The active payment error rate was 3.9%. Cases with identifiable findings were the result of erroneous data entries by CWD staff or misunderstanding in eligibility procedures. RESULTS Active Case Reviews Because of the stratification, the reviewers found few eligibility issues. The CWD cases were documented, verifications were available and the automated systems documentation was relatively consistent. Our initial Active Case error rate is 0.8% and Active Payment error rate is 3.9%. Those cases with identifiable findings were the result of erroneous data entries by CWD staff or misunderstanding in eligibility procedures. 504 Active Cases Reviewed 3 Cases resulting in total ineligibility with payment errors 1 Case resulting in total ineligibility without payment error 1 Understated Share of Cost for an otherwise eligible beneficiary with payment error 1 Overstated Share of Cost for an otherwise eligible beneficiary without payment errorRESULTS Active Case Reviews Because of the stratification, the reviewers found few eligibility issues. The CWD cases were documented, verifications were available and the automated systems documentation was relatively consistent. Our initial Active Case error rate is 0.8% and Active Payment error rate is 3.9%. Those cases with identifiable findings were the result of erroneous data entries by CWD staff or misunderstanding in eligibility procedures. 504 Active Cases Reviewed 3 Cases resulting in total ineligibility with payment errors 1 Case resulting in total ineligibility without payment error 1 Understated Share of Cost for an otherwise eligible beneficiary with payment error 1 Overstated Share of Cost for an otherwise eligible beneficiary without payment error

48. Eligibility Reviews Results Negative Case Reviews 204 negative cases were reviewed 17 Cases with Negative actions correct but invalid Notice of Action compliance 2 Cases with Negative actions incorrect regardless of Notice of Action compliance 3 Cases with Negative action correct, but notices not timely The initial negative case error rate was 10.88%. Although the termination and denial actions were correct in almost 99% of the cases (202 out of 204) reviewed, there were some problems in notice issuances. The majority of problems occurred in Termination Actions or due to CWD staff not responding to automated system alerts and not understanding processing procedures. There was no case in which beneficiaries received benefits erroneously and only 2 cases in which benefits were erroneously withheld. RESULTS Negative Case Reviews Our initial Negative Case error rate is 10.88%. Although the termination and denial actions were correct in almost 99% of the cases (202 out of 204) reviewed, there were some problems in notice issuances. The majority of problems occurred due to CWD staff not responding to automated system alerts and understanding of processing procedures. The majority of problems occurred in Termination Actions. There was no case in which beneficiaries received benefits erroneously and only 2 cases in which benefits were erroneously withheld. 204 Negative Cases Reviewed 17 Cases with Negative actions correct by invalid Notice of Action compliance 2 Cases with Negative actions incorrect regardless of Notice of Action compliance 3 Cases with Negative action correct but notices not timely RESULTS Negative Case Reviews Our initial Negative Case error rate is 10.88%. Although the termination and denial actions were correct in almost 99% of the cases (202 out of 204) reviewed, there were some problems in notice issuances. The majority of problems occurred due to CWD staff not responding to automated system alerts and understanding of processing procedures. The majority of problems occurred in Termination Actions. There was no case in which beneficiaries received benefits erroneously and only 2 cases in which benefits were erroneously withheld. 204 Negative Cases Reviewed 17 Cases with Negative actions correct by invalid Notice of Action compliance 2 Cases with Negative actions incorrect regardless of Notice of Action compliance 3 Cases with Negative action correct but notices not timely

49. Eligibility Reviews Data Sampling PERM Design February 2007 through June 2007 Developed the process to extract the sample. Extracted and formatted the sample data. April 2007 through June 2007 Developed the process with the CMS contractors. July 2007 through March 2008 Developed the process to extract and send the data universe, which included trends, formatting, and validation. Additional programs were written to analyze this data. Prior training or review of the contractor�s database was not permitted.

50. Error Rate Reduction Committee Met for the first time on March 4, 2008 30 states volunteered as members. Committee members provided short and long term recommendations regarding: How to reduce the error rate Develop a PERM Standard Operating Procedure (SOP) manual. Specific timeframes States are allowed to submit late documentation. All letters from the DDC should be addressed to the billing provider. Maintain this manual in one location. Jan Inglish is the Chair - 30 states volunteered as members. Committee members provided short and long term solutions regarding: How to make the Corrective Action Plan tool more effective How to reduce the error rate EligibilityJan Inglish is the Chair - 30 states volunteered as members. Committee members provided short and long term solutions regarding: How to make the Corrective Action Plan tool more effective How to reduce the error rate Eligibility

51. Error Rate Reduction Committee Committee members provided short and long term recommendations regarding: Develop one website for use by the Contractors and States and include search capability. Hold three cycle calls per month on a weekly basis. Dedicate one hour per call for specific topics, such as eligibility, data processing review, medical review, etc. Provide an option for those states with available resources to request documentation directly from the provider and forward the documentation to the DDC. Include language in the contract that compensation will be provided to the DDC for requesting documentation from providers only in those instances where the State does not undertake this responsibility. Where the State undertakes this responsibility, develop a process to compensate the State. All information disseminated to State Medicaid directors regarding PERM should also be provided to State PERM managers.

52. Error Rate Reduction Committee Committee members provided short and long term recommendations regarding: How to make the Corrective Action Plan tool more effective How to improve the eligibility process

53. Questions