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Wisconsin Department of Health Services

CRS Program Frequently Asked Questions (FAQ)

In order to be eligible for CRS, is a consumer required to have an assigned case manager or be receiving case management services?

Both the approved 1915(i) SPA and the proposed 1937 CRS Benchmark Benefit Plan require that CRS certified providers (counties and tribes) commit to performing certain duties related to CRS consumers on an ongoing basis. Many of these ongoing duties are within the realm of what is commonly referred to as "Case Management", and as such must be performed by qualified staff.

The ongoing duties specifically stated in the approved 1915(i) SPA and the proposed 1937 CRS Benchmark Benefit Plan are as follows:

  • Needs based evaluation and re-evaluation utilizing a person-centered approach,
  • Face-to-face assessment of an individual’s support needs and capabilities,
  • Development of an individualized plan of care,
  • Supporting the participant in the plan of care development,
  • Assisting participants such that they have an informed choice of providers,
  • Assuming primary responsibility for monitoring and acting upon incident reports,
  • Supporting the consumer on an ongoing basis in their plan of care.

Finally, both the approved 1915(i) SPA and the proposed 1937 CRS Benchmark Benefit Plan require that CRS certified providers provide consumers with a means to request changes and/or express their satisfaction or dissatisfaction related to their services should the need arise. Such access shall be both ongoing and readily available to the consumer.

Can an individual pay a portion toward their service cost if they choose to do so for CRS services?

As a general rule, Medicaid members should not be asked to contribute toward the cost of a Medicaid covered service. The reimbursement that is received from Medicaid is considered payment in full. With the exception of deductibles and co-payments as authorized in the member’s benefit plan, soliciting and/or receiving payment from a Medicaid member over and above the amount reimbursed by Medicaid for a covered service is not allowed, and carries significant penalties under federal and state Medicaid rules. Please consult the Forward Health Medicaid Provider Handbook, and DHS 104.01(12)(2)(d) “Freedom From Having to Pay the Difference Between Charges and MA Payment.”

What source does the Department use to define CRS terminology e.g., goals, interventions, outcomes, barriers, progress?

CRS requires the use of Person Centered Planning (PCP) as defined by the behavioral health model offered through Alipar, Inc. Training in this particular PCP model has been made available statewide. Terms used and defined in this model of PCP provide a bridge to use and define terms consistently in CRS even while Case Managers are Assessing and Planning through one or more of the State’s programs, e.g., Community Support Program (CSP), Comprehensive Community Services (CCS), Home and Community Based Waiver (HCBS), or Targeted Case Management (TCM).

How is the Recertification date determined?

Recertification should occur annually during the month in which eligibility was originally determined, often referred to as the “anniversary month”. Financial eligibility is key, thus we recommend that you check on financial eligibility at the beginning of the anniversary month and submit the recertification packet by the middle of the month. In this scenario, the State would use the original eligibility date, and the current year as the recertification date.

Can ordering the person’s medications from the pharmacy be billed to CRS as service facilitation?

Service facilitation cannot be billed to CRS. Service facilitation can be billed to other benefits e.g., Targeted Case Management (TCM), Comprehensive Community Services (CCS) or Community Support Services (CSP). The rules applying to these MA benefits should be followed.

When making changes/updates to the Functional Screen does the date change automatically?

When making edits to the Functional Screen, make the changes as needed. Use the drop down note box of that section and enter a notation that this is an edit. Also add the date the edit is made and the date of the original Functional Screen. DO NOT CHANGE THE COMPLETION DATE OF THE FUNCTIONAL SCREEN.

If the Functional Screen shows an individual being eligible for CRS during the first year but not during the second, due to the individual having made some improvements, but the underlying issues are still there and the need for service(s) still exist, might this individual still qualify for CRS?

If this situation were to occur it is our recommendation that the screener contact Bureau staff to review the screen data and interpretation of the data. The consumer with a service in place may function better. The level of functioning may not be a long term change but a result of the support provided. On the screen the consumer’s level of functioning should be assessed considering what the consumer would score without the service in place.

We discussed as a group that we need to take a look at creating a better way to describe the year prior on the outcomes page. Could you please comment on the matter?

The Outcomes form will be revised in the coming months. In the meantime, to record the person’s progress toward the goal in Box 6 under the original anticipated outcome, use bolded font and begin with the word “Progress”. Be sure to include the date that the progress was measured in Box 7.

If a person is eligible for COP, can they still be eligible for CRS?

In general, a person can be eligible for, and receive services from, more than one program. In the case of COP, a county could use COP funding (state revenue) to pay for the non-federal share for a CRS client. In that instance, the person could be in both programs, as long as the person met the criteria for both programs.

Can a person be enrolled in both CCS and CRS?

Yes

Our original impression was that eligibility for CRS would be limited to adults.  However, I understand that children are also covered under this program.

CMS requires that 1915i services be provided to eligible individuals across all ages (keeping in mind that the individual must need and choose the service). Wisconsin cannot set different eligibility criteria as to age.

Are counties required to provide all three services to each CRS consumer?

CRS enrollees would receive only those CRS services where their comprehensive assessment determines there is a need, and where the client and care manager determine the service is the best approach to meet that need. So no, not every CRS client will receive all three services.

Does CRS apply only to Fee for Service MA recipients?  What about people enrolled in MA HMOs or BadgerCare?

CRS applies to anyone who has Medicaid and is at or below 150% of the federal poverty level. People enrolled in MA HMOs or BadgerCare are eligible as long as they meet the income test.

What screening tool would be utilized for children?

The screening tool for children is the Children’s Long Term Functional Screen.

Can a person concurrently be on CRS and other MA programs like Medicaid Waivers, CSP, or CCS?  Can CRS pay for Supported Employment services for a CSP consumer?

A person can be on COP, CSP, or CCS and receive CRS services. For a service such as supported employment which could be covered under CSP or CRS, the primary concern is that it is only billed to one program. Individuals must meet CRS functional criteria. If the individual meets the MH / AODA functional screen criteria and the financial eligibility criteria, they could receive CRS services.

The services described in CRS appear to be geared toward adults and our kids system is not really set up to provide these services.  For example, teenagers might benefit from Supported Employment, but younger children likely would not.  Peer Supports is also difficult to envision for children.  Would parent peer support, meaning parents of kids with MI/SED providing support to other parents of kids with MI/SED, qualify as Peer Support? 

CRS services are provided as needed and appropriate for an individual. There is no expectation that supported employment would be provided to young children. We did not put family / parent peer support in the application. Until an amendment is done to add parent peer support to the definition, we are not able to cover it.

During the December 11, 2009 conference, I seem to remember you saying that assessment and planning activities on the part of the care manager would NOT be billable to CRS.  Is that correct?  If so, is there another way to recoup the cost of providing assessment / planning?

Assessment and planning activities are expected to be covered by Targeted case management or CSP if the individual receives CSP services.

It seems duplicative to develop a separate plan for a consumer in CCS or CSP when one already exists for these programs.  Can the CCS/CSP Recovery Plans be used instead of the State ISP if they contain all of the required elements. (we have done this for COP)

The agency does not need a separate CRS plan (a single coordinated plan is the standard best practice), when a CCS plan or CSP plan is in place, as long as the CRS services are designated as such and include the required CRS federal and state CCS & CSP components.  This also assumes that a person centered planning process was used for the CCS/CSP recovery plans.

It seems duplicative to conduct a separate assessment for CRS, when an assessment is on file for CCS or CSP.  The CCS and CSP rules do not require an annual assessment, but require that the assessment be updated when appropriate.  We have this update included in the Recovery Plan Review.  Would this be acceptable?

We have provided a list of assurances to the Centers for Medicare and Medicaid Services which are detailed below regarding the independent assessment.  For this program, we would need an assessment within the last year that is a comprehensive look at an individual’s current situation.  An update of an old assessment does not meet this criterion.

These are the assurances provided in the Federal application regarding assessments:

There is an independent assessment of individuals determined to be eligible for the State plan HCBS benefit. The assessment is based on:

An objective face-to-face assessment with a person-centered process by an agent that is independent and qualified as defined in 42 CFR 441.568;

Consultation with the individual and if applicable, the individual’s authorized representative, and includes the opportunity for the individual to identify other persons to be consulted, such as, but not limited to, the individual’s spouse, family, guardian, and treating and consulting health and support professionals caring for the individual;

An examination of the individual’s relevant history, including findings from the independent evaluation of eligibility, medical records, an objective evaluation of functional ability, and any other records or information needed to develop the plan of care as required in 42 CFR 441.565;

An examination of the individual’s physical and mental health care and support needs, strengths and preferences, available service and housing options, and when unpaid caregivers will be relied upon to implement the plan of care, a caregiver assessment;

A determination of need for (and, if applicable, determination that service-specific additional needs-based criteria are met for), at least one State plan home and community-based service before an individual is enrolled into the State plan HCBS benefit.

Last Revised: March 27, 2014