Obligation Entry in Financial Control MMIS for County Fiscal Staff

1. Obligation Entry in Financial Control MMIS for County Fiscal Staff Becky Path| Health Care Accounting Supervisor| Financial Operation Division and Health Care Administration Minnesota Department of Human Services | mn.gov/dhs

2. Presenters and Panel Participants • Becky Path, Jim Schorey, Ermias Kifle, Julie Spurgeon-Financial Operations Division • Geneva Finn and Joe Kempf – Special Recovery Unit (Estate) • Geralyn Soder – Member and Provider Services • Crate Darden – Medical Assistance Eligibility Policy • Bobbie Chapman – Health Insurance Recovery (CEHI) • Amy Gebhard – Health Care Eligibility Operations Minnesota Department of Human Services | mn.gov/dhs

3. OVERVIEW OFTOPICS TO BE DISCUSSED • Financial Control Subsystem in MMIS • Bulletin #15-21-06 Entering Recovery Obligations in MMIS • Types of recoveries –when to collect or not and hierarchy of collection • Outdated obligation codes and how to modify an obligation • Cost effective health insurance entered by counties • County billing – Health Care Accounting sends out bills to counties where there is a county share owed • County of Financial Responsibility issues and how to resolve them Minnesota Department of Human Services | mn.gov/dhs

4. Financial Control Subsystem in MMIS • The Financial Control Subsystem in MMIS is used by counties to enter obligations for overpayments counties have identified and for reimbursement for cost effective health insurance. • These obligations create claims in MMIS and are used to generate county billing which counties can see on their monthly Health Care Invoice report Infopac report MW0117 and MW0234 which shows claims detail. Minnesota Department of Human Services | mn.gov/dhs

5. Bulletin 15-21-06 Entering Obligations in MMIS • Bulletin 15-21-06 published in July 2015 is currently the best reference guide available for how to enter and correct obligations in MMIS financial control. • This bulletin includes a list of the current obligations that can be used for recovery along with those that are now obsolete. • Reminder – Estate recoveries should only be collected on deceased clients. Review the recovery and choose a different obligation type other than estate if recipient is still alive. • Contact phone numbers on the first page should be used for questions regarding obligations • The old MMIS II Quick Reference Guide from 1996 is outdated and the phone numbers in that document should not be used. The DHS Receipting center does not answer questions on MMIS obligation entry. Minnesota Department of Human Services | mn.gov/dhs

6. Types of Health Care Recoveries and when to collect or not to collect? • There are two major types of recoveries: • Estate recovery which is collected on a recipient’s estate after the recipient has passed away. • Recipient ineligibility which is when a recipient is found to be ineligible for programs and is being asked to return the funds expended on the recipient’s behalf to pay for health care. Minnesota Department of Human Services | mn.gov/dhs

7. The following program services are subject to estate recovery • MA services received by enrollees 55 years old or older who do not permanently reside in a medical institution: • Nursing facility services (NFS) • Home and community-based services (HCBS) • Hospital and prescription drug services received during the time the enrollee was provided NFS or HCBS • All MA services received by enrollees, regardless of age, whilepermanently residing in a medical institution Minnesota Department of Human Services | mn.gov/dhs

8. More program services subject to estate recovery • General Assistance Medical Care (GAMC) • Alternative Care (AC) services received on or after July 1, 2003 Minnesota Department of Human Services | mn.gov/dhs

9. Estate Collections Obligation type and Description and when to use: EA: Estate Affidavit – Use this obligation type to enter all recoveries the county makes that take place outside of a formal or informal probate process. These may include the recovery of non-probated assets using an affidavit of collection or other means that provides notice of an MA claim to the decedent’s estate or the decedent’s spouse’s estate. EP: Estate Probate – Use this obligation type to enter all recoveries the county makes in situations in which an estate has been formally or informally administered and is overseen by a judge, registrar, or other designated person. Minnesota Department of Human Services | mn.gov/dhs

10. Hierarchy in Estate Recovery • Counties need to be aware of the order that recovery obligations should be entered. The recovery collection hierarchy is determined by state law. • Claims for Alternative Care (Major program AC) are prioritized first under Minnesota law – Minnesota Statutes, section 524.3-805, paragraph (b). Minnesota’s requirements for MHCP estate recovery in general are found under Minnesota Statutes, section 256B.15.   Minnesota Department of Human Services | mn.gov/dhs

11. Order of collection of recoverable services for an Estate Claim • Payments for Alternative Care services received on and after July 1, 2003. 2. Payments for General Assistance Medical Care (GAMC) services GAMC member received at any age. 3. Payments for MA long-term services and supports (LTSS) a member received at age 55 or older. 4. Payments for MA services a member received at any age while permanently residing in a medical institution without expectation of returning home, as certified by the treating physician. Minnesota Department of Human Services | mn.gov/dhs

12. Recipient Ineligibility Obligation type and Description and when to use: • IA: Ineligibility Appeal– Use this obligation type to enter recoveries described in the following situation: A client files a timely appeal and requests continued benefits pending the appeal’s outcome. The client loses the appeal. Any benefits paid during the time in which the client was not entitled to benefits (as determined by the appeal results) are an appeal overpayment. • IC: Ineligibility Count Ordered – Use this obligation type to enter recoveries when an obligation resulting from the successful court action described in the following situation: A financial worker determines a recipient is ineligible and refers the case to the local agency fraud unit or the local agency attorney, who then establishes a court action. The court action is successful in securing a repayment schedule, and the financial worker sets up an obligation in MMIS. • IV: Ineligibility Voluntary – Use this obligation type to enter recoveries for an obligation resulting from an overpayment the financial worker has calculated. Minnesota Department of Human Services | mn.gov/dhs

13. Situations were counties should not make recoveries based on MA policy • The overpayment is the result of agency error • When the enrollee reports a change timely • Eligibility was determined using the enrollee’s estimate of expected income and the enrollee’s actual income was later found to be higher than the original estimate • There is suspected fraud or unreported information that has not yet been verified or confirmed • This policy can be found in the Healthcare Programs Eligibility Policy Manual under Overpayments 1.3.2.5. Minnesota Department of Human Services | mn.gov/dhs

14. How is the overpayment amount for recipient ineligibility calculated? The overpayment amount: • Is the amount the health care program paid for benefits on behalf of the enrollee, either through fee-for-service claims or managed care payments, minus premiums paid for the overpayment period. • The amount MHCP paid for benefits is compared to the benefits the enrollee should have received. The overpayment amount may be reduced or eliminated if the enrollee would have been eligible for the same program under a different basis. Minnesota Department of Human Services | mn.gov/dhs

15. Who do I contact if I have questions about Recovery policy? • Health Quest questions regarding MA eligibility policy related to recoveries should be directed to your county financial worker/supervisor who can contact the state Medical Assistance policy team through System Information Repository (SIR). • Contact Benefit Recovery Help Desk at 651-431-3100 regarding questions on other recovery policy Minnesota Department of Human Services | mn.gov/dhs

16. Examples of types of inquiries that can be sent through health quest to the MA policy team • Questions about county of financial responsibility policy • Questions about how to determine if the overpayment was county error or client error • Policy questions around American Indian and Alaska Native recovery exemptions • Questions about recovering assets on a case that has designated additional protected assets under a Long Term Care partnership policy • Questions about MA eligibility policy in relation to estate recovery or overpayments • Where to find Policy in the Healthcare Programs Eligibility Policy Manual or State Statues Minnesota Department of Human Services | mn.gov/dhs

17. Outdated Obligation types • NN – Non-recipient Non-TEFRA • EG – Estate General • EV – Estate Voluntary • If a county worker tries to enter an obligation type that is no longer valid, the following message will appear: THE OBLIGATION TYPE YOU SELECTED WAS REMOVED JULY 1, 2015. • Please refer to the bulletin 15-21-06 first page for phone numbers to be directed to further assistance. Minnesota Department of Human Services | mn.gov/dhs

18. How to enter an obligation in MMIS Financial Control • Always enter an obligation maximum (MAX) in OBLG screen in MMIS when the debt is established, not just when a payment is made. Local agencies are billed only for the amounts collected, not for obligations owed but not collected. • Collections should be entered within one month of receiving the payment. Minnesota Department of Human Services | mn.gov/dhs

19. How to correct an obligation entry in MMIS Financial Control • Can an obligation be deleted? No • To reverse an obligation entry, enter the amount to be reversed in parentheses. • If a collection is made on an already existing obligation that now has an obsolete obligation type, the recovery should be reviewed. If it is still permissible to collect on this obligation, a new obligation type will need to be set up. • Stop recovering the collection and notify the recipient if there is no longer a current valid obligation for collection. • Please contact the Special Recovery Unit if a refund needs to be completed. If appropriate, the refund will be completed by the state through MMIS. Minnesota Department of Human Services | mn.gov/dhs

20. Tips on how to enter Cost Effective Health Insurance in MMIS Financial Control • Workers should complete the TPCO screen once a policy has been determined cost effective. If the policy is in a non-reviewed status, the Health Insurance Recovery Unit will review and a obligation ID will be assigned. If TPCO screen information is added after the policy has been reviewed, (hit F3 once complete), an obligation ID will be assigned. • The obligation ID number is used in financial control to bill the state for the cost effective insurance premium reimbursement • Make sure the correct eligibility span in RELG in MMIS is used as this affects the Federal Financial Participation for the claim. • Cost effective health insurance reimbursement is only available for Medical Assistance recipients. Do not enter cost effective health insurance reimbursement for MinnesotaCare or CHIP recipients. Minnesota Department of Human Services | mn.gov/dhs

21. When is a new obligation ID needed for Cost Effective Health Insurance Reimbursement? • Open a new obligation ID if financial control transactions have taken place and any of the following occur: • The obligation ID hits the total activity amount in financial control • The premium/pro-rated premium amount changes • Premium NPI number (County of financial responsibility) changes • Obligation recipient ID changes Minnesota Department of Human Services | mn.gov/dhs

22. Do Not Enter Cost Effective Health Insurance reimbursements for MinnesotaCare Recipients • Do not submit cost effective health insurance obligations for recipients with MinnesotaCare/Basic Health Plan eligibility. • MinnesotaCare major programs are identified in MMIS as BB, FF, JJ, XX, KK, or LL. Having cost effective employer subsidized health insurance is generally a bar to MinnesotaCare enrollment. • If a recipient is identified as currently on MinnesotaCare with cost effective health insurance, notify the County Relations Resource Center (formerly known as the MMIS Help Desk)to review METS eligibility which should have a field for other insurance completed which may change the eligibility of the recipient. Minnesota Department of Human Services | mn.gov/dhs

23. Do not enter Cost Effective Health Insurance Obligations for certain CHIP kids • Certain CHIP kids under age 2 whose household income is from 275% - 288% Federal Poverty Level who are identified by major NM and Eligibility type CB in MMIS are NOT allowed to have access to Third Party Liability Insurance as a condition of CHIP eligibility. • Eligibility results for METS cases are automated so there was likely TPL not listed in case which yielded CHIP NM CB results. The child with same age and income with access to TPL would still be eligible for MA. • If you are asked to submit cost effective health insurance reimbursement for a recipient with major program NM and eligibility type CB do NOT enter the request, go back to your county eligibility worker to have the eligibility reviewed. If the eligibility worker cannot get different eligibility results on a METS case, the county eligibility worker should contact the County Relations Resource Center (formerly known as the MMIS Help Desk)MMIS help desk to get the eligibility corrected. Minnesota Department of Human Services | mn.gov/dhs

24. County Billing When a county share is involved, Health Care Accounting sends out bills to counties, near the start of each month, based on expenditures and recoveries reported in the MW0117 report. What is meant by a county share? In state statute there are several services that are funded by the county paying a portion of the claim. The county is not billed for all of them, County payments for county provided Targeted Case Management (TCM) and Vulnerable Adult Developmentally Delayed (VADD) services are not billed, the county share is obtained through a cutback of the payment to the county. How is it determined which county is billed? The recipient’s County of Financial Responsibility (CFR) at the date the service is provided. See Minnesota Unitary Residence and Financial Responsibility Act MS 256G.01 & MS 256G.01, Subd .4 County of Financial Responsibility Minnesota Department of Human Services | mn.gov/dhs

25. What is the county being billed for? Counties are billed for claims for which the county owes a share. The county is billed for its portion as determined by law. The state initially pays the county share and then bills the county for its portion. County shares are determined by a percentage of the non-federal share. What claims have a county share that we bill for (examples below)? • Targeted Case Management- contracted vendor (TCM-CV)- county is billed for nonfederal share- Minnesota Statutes 256B.0924 Subd. 6 (e) • Long Term Care Services (LTC) under age 65 > 90 days stays – county is billed for 20% of nonfederal share- MS 256I.08 County share for Certain Nursing Facility stays & 256B.19 Subdivision 1. (2) Division of Costs • Intermediate Care Facility Developmental Disabilities > 90 day stays- county is billed for 10% of nonfederal share- 256B.19 Subd.1 (3) Division of costs Counties are also billed for the state and federal share of recoveries collected based on the MW0117 report. Counties collect the recoveries and then report the funds collected to the state through county obligation/financial control section of MMIS. See Minnesota Statutes (MS) 256D.09 Payment; Assessment; Overpayment, Subd. 6 Recovery of overpayments and MS 256.019 Subd.2(c) Recovery of Money; Apportionment. Minnesota Department of Human Services | mn.gov/dhs

26. How is it determined which county is billed? • For recoveries the county billed is the county that initiated the recovery in Financial Control in MMIS. • For expenditures that have a county share, the county billed is the County of Financial Responsibility identified in MMIS. Minnesota Department of Human Services | mn.gov/dhs

27. How can a county find the financial participation rates? • A good reference is Bulletin #16-32-08 Calendar Year 2017 Participation Rates which gives a breakdown of state, federal, and county shares for services and eligibility types. • Participation rates for AX, NA and CHIP % are based on claim date of service Minnesota Department of Human Services | mn.gov/dhs

28. County of Financial Responsibility (CFR) Issues • Why is the county of financial responsibility (CFR) important? The CFR determines which county pays in situations where the county has a share in paying for services by law. • The CFR is not always the same as the county of residence. • When a public program recipient moves from one county to another for 60 days following the move the county that the recipient came FROM remains the county of financial responsibility (CFR). There are exceptions for excluded time. • After 60 days the county financial worker of the receiving county changes the CFR to the new county of residence. Claims are now the responsibility of the new county. Minnesota Department of Human Services | mn.gov/dhs

29. County of Financial Responsibility Policy • County of Financial Responsibility • The county of financial responsibility is the county where the person lives on the day the county receives a written request for assistance. The county of financial responsibility is responsible for paying the county share of MA services. • When a person moves to a different county, the new county becomes the county of financial responsibility after two months, not including the month of the move. • When a person lives in an excluded time facility or receives excluded time services, the county of financial responsibility is the county in which the person lived immediately before the excluded time started. • This policy can be found in the Healthcare Programs Eligibility Policy Manual under 2.1.2.3 MA County Residency Minnesota Department of Human Services | mn.gov/dhs

30. What is considered Excluded Time? • Excluded time facilities and situations include: • Hospitals • Long-Term Care Facilities (LTCF) • Shelters (other than emergency shelters) • Halfway houses • Foster homes for children receiving Title IV-E and Non-Title IV-E Foster Care • Homes for children receiving Title IV-E and Non-Title IV-E Kinship Assistance • Board and lodging facilities Minnesota Department of Human Services | mn.gov/dhs

31. More Excluded time situations • Maternity homes • Battered women's shelters • Correctional facilities • Regional treatment centers (RTC) • Placement in a facility based on an emergency hold • Placements in day training and habilitation programs • Assisted living services • Placements with an indeterminate commitment, including independent living Minnesota Department of Human Services | mn.gov/dhs

32. Some other unique excluded time situations to consider • A person may receive excluded time services while living at home or in a group living situation. Excluded time services include: • Participation in a rehabilitation facility which meets the definition of a long-term sheltered workshop • Receipt of services from a Semi-Independent Living Services (SILS) Program • Day training and habilitation programs • Safe at Home • When a person is a Safe at Home (SAH) program participant, they use a PO Box address assigned to them. SAH provides a mail forwarding service. The county of financial responsibility and county of residence are the county in which the person lives. More information about SAH Address Confidentiality Program is available from the Minnesota Secretary of State. Minnesota Department of Human Services | mn.gov/dhs

33. What to do if a recipient moved and the new county does not change the CFR? • If a recipient should have gain settled (60 days in new county with no excluded time provisions) and the receiving county has not changed the CFR in MMIS recipient RELG screen, and the eligibility for the case was determined in MAXIS, contact the receiving county worker and request the change. • If the receiving county is unable to make the change, then contact the MMIS help desk to request help to make the change. • County eligibility workers cannot make the change of CFR on METS cases. METS cases all begin with the number 1. Other case numbers are MAXIS cases. • If the previous county has already received bills for recipient claims while the recipient was the CFR of another county, pay those bills. • After the CFR change has been made in MMIS contact DHS Financial Operations Health Care Accounting to request that claims be reprocessed. • Claims reprocessing will result in a credit to the previous county for claims paid. The credit will be applied to the current county’s invoice. Correct CFR county will be billed. Minnesota Department of Human Services | mn.gov/dhs

34. METS vs MAXIS • Minnesota Eligibility Technology System (METS) is the name for the newer eligibility system used by recipients and navigators to enter information used to determine eligibility for Minnesota health care programs for single adults, families, children, and MinnesotaCare/Basic Health Plan recipients. • MAXIS is the legacy eligibility system where information is entered by counties to determine eligibility for Seniors and Disabled applicants. • County of Financial Responsibility is determined by the value in the Financially Responsible Agency Evidence field in METS and this information is put over to MMIS CFR field through a system’s interface. • METS will overwrite changes made to MMIS RELG so even if a CFR was manually corrected, it can be overwritten by METS if the CFR is not corrected in METS as well. • In MAXIS cases, the MMIS RELG CFR is manually updated by the County financial worker. Minnesota Department of Human Services | mn.gov/dhs

35. Questions about Health Care/county financing? • Contact information: • Rebecca Path – Health Care Accounting Supervisor • 651 431 3771 • Rebecca.path@state.mn.us Minnesota Department of Human Services | mn.gov/dhs

36. -Questions about Estate Recoveries? • Contact information: • Greg Lulic – Special Recovery Unit county liaison • 651-431-3152 • Geneva Finn - Manager • 651 -431-3108 or Geneva.Finn@state.mn.us • Joseph Kempf – Statute interpretation • 651-431-5805 or Joseph.Kempf@state.mn.us Minnesota Department of Human Services | mn.gov/dhs

37. Questions about getting eligibility/CFR on METS/MMIS cases corrected? • Contact the County Relations Resource Center (formerly known as the MMIS Help Desk). • The County Relations Resource Center phone number is 651-431-3930 or 1-800-366-7894 and are staffed from 8:30 – 3:30 for county calls. • Corrections needed on MAXIS/MMIS cases that the county financial worker cannot correct, should be referred to the TSS help desk. • TSS Help Desk phone number is 651-431-4100 or 1-800-383-7987 Minnesota Department of Human Services | mn.gov/dhs

38. Questions about Cost Effective Health Insurance? • County workers should call 1-800-657-3963 or 651-431-3100 and push option 3 for Counties then option 3 for again for Cost Effective Health Insurance questions. • Cost effective questions can also be sent by SIR email to : • dhs.hco.brs-health@state.mn.us Minnesota Department of Human Services | mn.gov/dhs

39. MMIS Financial Control Obligation Training Becky Path Rebecca.Path@state.mn.us 651-431-3771 Minnesota Department of Human Services|mn.gov/dhs