Frequently Asked Questions
When do the new IDAPA rules go into effect?The Medicaid Reform Rules were implemented on May 08, 2009. Agencies need to develop policies and procedures based on the Medicaid Reform Rules as of May 08, 2009. Monitoring for compliance to these rules began on July 01, 2009.
Should I be concerned if our agency receives a missing information letter from BPA?
No. In fact, almost every provider receives at least one (1) missing information letter. You may receive up to two (2) missing information letters from BPA in an attempt to address and ensure all core issues are resolved prior to the onsite visit. When you receive your letter you may call BPA with questions or concerns or to simply clarify an issue.
Will all the issues my agency needs to address be in the missing information letters we receive?
No. BPA only addresses core issues and unanswered questions in the missing information letter. BPA will address any other deficiencies in the application report that is sent to the Department. The Department then sends a copy of the report to the provider letting them know what items needs to be addressed prior to the onsite visit. This process of addressing core issues in the missing information letter and then deficiencies in the report allows for a more expeditious credentialing program.
How often does Direct Care staff need a background check?
The rules regarding background checks are found under IDAPA 16.05.06 as well as the Idaho Criminal History Unit website located at: www.chu.dhw.idaho.gov. Agencies should reference IDAPA 16.05.06.300 specifically for the procedures for transferring background checks that have been completed within three years of employment.
Do RNs and PAs need to have background checks?
RNs and PAs do need to have background checks prior to providing services at your agency. Medicaid does not currently require MDs and DOs to obtain additional background checks as this is done prior to obtaining the medical license.
Does my agency need to pick one Code of Ethics or can each staff member follow their own Code of Ethics?
Medicaid stipulates (16.03.09.714.14 and 16.03.10.130.12) that all Medicaid providers must adopt, adhere to and enforce a Code of Ethics Model that all staff will follow.
What are the maintenance requirements for PECFAS certification?
Functional Assessment Systems does not have a booster for the PECFAS, at this time. The CAFAS must be renewed every two (2) years. If the CAFAS certification lapses, PECFAS is no longer valid and the staff member will have to be recertified in both the CAFAS and PECFAS to perform these assessments. You can access the Utilization Standards at: www.healthandwelfare.idaho.gov/DesktopModules/DocumentsSortable/DocumentsSrtView.aspx?tabID=0&ItemID=7971&MId=12504&wversion=Staging
How do I find the FAQs on the Department website?
The Department has updated their website. Follow the link below, the FAQs are in the right hand column. http://healthandwelfare.idaho.gov/Providers/MedicaidProviders/tabid/214/Default.aspx
How do I find or learn about IDAPA rule updates and changes?
Routinely check the Idaho Administrative Code website and Bulletin at:
www.adm.idaho.gov/adminrules/agyindex.htm and
www.adm.idaho.gov/adminrules/bulletin/mstrtoc.htm
How do I find old archived IDAPA rules?
The Idaho Administrative Code website keeps archived rules based on the year at: www.adm.idaho.gov/adminrules/agyindex_archive.html
Idaho Code, Section 72-203 states that my business is exempt for the requirement to obtain Workers Compensation Insurance. Why does this requirement exist for Credentialing?
Medicaid requires all agencies that have contracted to provide Medicaid reimbursable services to carry Workers Compensation Insurance. Because Medicaid providers are considered contracted to provide these services, Medicaid wants to ensure that workers are adequately covered in the event of an injury while providing Medicaid reimbursable services.
Why does Credentialing require policies and procedures for supervising staff that are licensed to practice independently?
This is a Quality Management policy rather than a licensing requirement. This type of supervision is recommended to ensure adherence to agency and Medicaid policies and procedures.
Why does the contract with the Directing Physician over clinic services need to have the EXACT verbiage outlined in IDAPA 16.03.09.714.06 & .07 and the Medicaid Provider Agreement Part 3?
The exact verbiage for the contract with the agency's Directing Physician is specified in IDAPA 16.03.09.714.06. If the Directing Physician is also acting as a Supervising Physician for the agency, the contract must include the verbiage in IDAPA 16.03.09.714.07. If the agency chooses to have additional Supervising Physicians, the affiliation agreement must include the verbiage outlined in IDAPA 16.03.09.714.07.
We don't see any references to Risk Management or Adverse Incident Reviews in Medicaid rules and regulations. How can this be a Credentialing requirement if it isn't in rule?
Risk Management and Adverse Incident Reviews are Quality Management Activities that enable providers to monitor the services to ensure quality care. By developing a formal system for monitoring participant risk factors and for reviewing adverse events, the agency is able to modify services accordingly.
- Rules and regulations regarding these important Quality Management activities are woven throughout rule and the provider agreement. Reference IDAPA 16.03.09.714.02, 714.08, 09, 11, 13-15 and 716.05 and 16.03.10.112, 116.05, 128.04, 05, 129.07, 130.02, 06, 07, 10 & 12 and the Medicaid Provider Agreement Appendix A-5.1, 5.5, 5.6 and 5.7 {E-1, E-5, E-6 and E-7 for the PSR Provider Agreement} for more information regarding Risk Management and Adverse Incident Review rules and regulations.
- Another resource published by Centers for Medicare & Medicaid Services (CMS): "Risk Management and Quality in HCBS: Individual Risk Planning and Prevention, System Wide Quality Improvement" at http://www.cms.hhs.gov/HCBS/downloads/qualityriskmgmt.pdf.
If the agency provides any services in the office setting to Medicaid Mental Health Participants, regardless of whether they are Medicaid billable services, per IDAPA 16.03.10.130.12 the agency must have policies and procedures that adhere to the building guidelines outlined in IDAPA 16.03.09.714.15.
Where do I find information regarding Cultural Competence?
The first place to look is in the Code of Ethics your agency has adopted (IDAPA 16.03.09.714.14.d and 16.03.10.130.09 and the Medicaid Provider Agreement Appendix A-2 {B in the PSR Provider Agreement}). Some professions have limited information regarding cultural competency in their code of ethics. The US Department of Health and Human Services Health Resources and Services Administration has information available at:http://www.hrsa.gov/culturalcompetence. Cultural competency goes beyond determining if the provider can speak the participant’s language and making referrals. We encourage providers to incorporate a cultural competency workshop into their annual CEU requirements to expand their understanding of this concept so they can build agency policies and procedures that are responsive to the needs of the various cultures living within their community.
Where can I find resources for developing HIPAA policy and procedures?
CMS has developed a website that is full of information, training materials and compliance checklists for developing HIPAA policies and procedures. The website address is: www.cms.hhs.gov/MMIS/03_MedicaidHIPAASim.asp . The PDF version of the regulations can be found at: http://www.hhs.gov/ocr/privacy/hipaa/administrative/privacyrule/adminsimpregtext.pdf
Sections VII and VIII appear to repeat the same questions in the self-study section. What is the difference between Section VII and VIII of the self-study section of the application?
Section VII and VIII requests Utilization Management and Quality Management policies and procedures. The self-study enables the providers to provide examples of how the policies and procedures are implemented. The self-study also requires the provider to analyze the effectiveness of their Utilization Management and Quality Management policies and procedures. Note: It is not unusual for a provider to identify a policy or procedure that needs some fine tuning while completing the Self-Study section of the application. This is a good thing. This means providers are critically analyzing their Utilization Management and Quality Management policies and procedures to ensure participants are receiving the highest quality of services while appropriately managing Medicaid funding.
Will the credentialing program change next year as the government changes? It has been hard keeping up with Medicaid and the Department over the years.
There are two parts to this answer. First, the credentialing program is continually updated to reflect the most current IDAPA rules. Providers are expected to make appropriate changes to their policies and procedures as the regulations and rules change. The Idaho Department of Health and Welfare, Division of Medicaid offers newsletters and other educational materials on their website at: http://www.healthandwelfare.idaho.gov
Second, the credentialing program continues to evolve through our own Quality Improvement activities. We continually strive to develop a program that provides an accurate and fair assessment of each provider’s ability to provide quality services to Medicaid participants while adhering to State and Federal Medicaid regulations.
How long does the credentialing process take from start to finish?
The time line for credentialing varies from agency to agency. An outline of the credentialing process is available under the "tools" tab on the Medicaid Mental Health Provider Credentialing website labeled 'What to expect during credentialing'.
It appears like this credentialing process is for big agencies. Why do small agencies have to go through this?
The Idaho Department of Health and Welfare, Division of Medicaid determines which providers will go through credentialing and in what order. The Department believes that credentialing is important to ensure that Medicaid participants are receiving the best care possible. All agencies are expected to follow IDAPA rules applicable to the services they provide regardless of size.
What are the most commonly cited issues in Credentialing?
- The most commonly cited issues in the credentialing application are:
- Background checks. Providers are encouraged to reference the Idaho Administrative Code website at: www.adm.idaho.gov/adminrules/agyindex.htm and the archived codes from previous years at: www.adm.idaho.gov/adminrules/agyindex_archive.html to ensure documentation of background checks are in compliance with IDAPA at the time of each employee's date of hire. If the agency identifies that they misunderstood the requirements when any of the staff were hired, please submit an explanation of the discrepancy and documentation of any steps taken to resolve those discrepancies to avoid having to address this issue in a follow-up letter.
- Physician contracts and documentation procedures for medical oversight. The agency is needs to review IDAPA 16.03.09.714.06 & .07 for the supervising physician contract requirements. Reference IDAPA 16.03.09.716.05.c and the Medicaid Provider Agreement: 5. Recordkeeping for the documentation requirements for the participant’s meeting with the supervising physician to determine the medical necessity of clinic services.
- Lack of formal written policies and procedures. Writing a short response to each question does not constitute policy and procedures. Providers are need to write formal policy and procedures that operationalize how the agency implements Medicaid requirements (Medicaid Provider Agreement Appendix A-1.3 {A-3 for PSR}).
An outline of the on-site review protocol is available under the "tools" tab on the Medicaid Mental Health Credentialing website labeled 'What to expect during your onsite visit'.
Our agency provides different programs to Medicaid participants (i.e. Developmental Services, IBI, etc). Who do I need to list on the staff roster?
The Medicaid Mental Health Credentialing Program only assesses for compliance with Basic and Enhanced rules for Medicaid Mental Health Services. The agency should only reference staff and subcontractors that provide services to Medicaid Mental Health participants in the Credentialing application.
Our agency has not received our invitation to go through the Credentialing program, but we want to get prepared for our invitation now. Can we get a copy of the Credentialing application so we can get prepared?
A sample of the current version of the credentialing application is available on our website under the "tools" tab. We strongly discourage filling out the application unless you have been formally invited. The applications are periodically updated to reflect changes in rules and as we continue to refine the credentialing process.
Why do we need to send two copies of the application and self-study?
One copy of the application is kept at BPA until the agency completes credentialing and the second copy is sent to storage as a back-up.
If we receive a missing information letter, do we need to send two copies of our response?
No. We only need one copy of any information requested after the original application submittal.
My agency has Malpractice Liability Coverage under the Federal Tort Claims Act (FTCA). Do I still need to have Professional Liability Coverage for staff?
No. The coverage provides immunity from lawsuit for the health center, employees and eligible contractors. If the agency contracts with staff members who have FTCA coverage, the agency needs to contact the group that manages FTCA to verify the coverage extends to the work done at your agency and submit documentation of this verification with the credentialing application.
My agency is applying for CARF accreditation. Do we need to go through the Medicaid Credentialing Program?
If your agency is applying for or has CARF accreditation, please notify BPA and Medicaid so we can assist you with determining the next steps of the Credentialing process for your agency.
Should we follow the format of the application in our submission?
Yes. Please follow the format of the application. Policies and procedures can be sectioned into appendices, but you will need to reference where to find these to ensure easy accessibility and a more expeditious review of the application.
Note: If you have a question that you think we should post to our FAQ Tab please email us at: mail@idmhc.com