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DDES Memo Series 2004-05

April 1, 2004

STATE OF WISCONSIN
Department of Health and Family Services
Division of Disability and Elder Services

To:
Area Administrators/Assistant Area Administrators
Bureau Directors
County Departments of Community Programs Directors
County Departments of Developmental Disabilities
Services Directors
County Departments of Human Services Directors
County Departments of Social Services Directors
Licensing Chiefs/Section Chiefs
Tribal Chairpersons/Human Services Facilitators

From: 
Sinikka Santala, Administrator
Division of Disability and Elder Services

Kitty Kocol, Administrator
Division of Children and Family Services

Re: Human Services Random Moment Time Study (HS RMTS)

Document Summary

As a result of a federal directive, the Wisconsin Department of Health and Family Services (DHS ) is preparing to consolidate the Social Services Random Moment Time Study (RMTS) and the Community-Based Medicaid Administrative Claiming (CBMAC) RMTS into a single time study instrument, the Human Services Random Moment Time Study (HS RMTS). DHS will be implementing the HS RMTS beginning April 1, 2004. This memo is intended to provide counties with information regarding the transition to the HS RMTS.

Counties currently participating in the CBMAC program should complete the attached 2004 Administrative Claiming Agreement and return to DHS as soon as possible. Counties that want to begin participating in the CBMAC program effective April 1, 2004, should also complete and return the agreement. Additional information about the CBMAC program may be found in DSL Memo Series 2002-24 Community-Based Medicaid Administrative Claiming (CBMAC).

Background

The Department of Health and Family Services (DHS ) operates Random Moment Time Study (RMTS) sampling processes to allocate time and costs for federal reimbursement consistent with OMB A-87 for:

  1. Social Service (SS) to capture caseworker time devoted to out-of-home care and preventing out-of-home care activities eligible for reimbursement under Title XIX and Title IV-E; and to determine the proportion of information system activity related to out-of-home care and preventing out-of-home care activities which are eligible for federal IV-E reimbursement.
  2. Community Based Medicaid Administrative Claiming (CBMAC) to capture county staff time spent identifying clients that are "at-risk" of adverse health outcomes and linking them with Medicaid covered services which are eligible for reimbursement as Medicaid administrative activities.

Although the Random Moment Sampling and federal funds claiming processes are mutually exclusive, concerns were raised by county staff related to the efficiency of multiple time studies conducted by the DHS . Similar concerns were raised by the U.S. Department of Health and Human Services Division of Cost Allocation (DCA) related to the potential for confusion between the two time studies and a misunderstanding of the program structures, and mutual exclusivity. 

As a result of these concerns, DHS has agreed to consolidate the SS and CBMAC RMTS into a single time study instrument, the Human Services (HS) RMTS effective April 1, 2004

The intent of the consolidation is to alleviate the concerns of DCA regarding the operation of multiple time studies in counties, to eliminate potential misunderstanding between the IV-E and MA claiming processes, and to streamline the processes for sampling county staff for time study purposes.

Over the past several months, DHS staff have met with a workgroup of county representatives to obtain input and feedback on the approach to consolidate the SS and CBMAC RMTS into the HS RMTS. 

The workgroup has provided valuable assistance in the development of the time study instrument and the instructions that will be distributed to all counties. This process is expected to continue over the next several months as implementation of the HS RMTS progresses.

Impact of HS RMTS on IV-E and MA Revenue

It is not anticipated that the consolidation of the current SS time study into the new HS RMTS will impact the IV-E revenue received by counties. Most IV-E revenue is claimed at the state level based on time study results and costs reported by counties. 

IV-E funds claimed at the state level are allocated to counties through the Community Aids and Title IV-E Incentive programs. Counties may receive Title IV-E funds directly for WiSACWIS, foster parent training or child welfare legal services. The time study consolidation will not affect the reimbursement rates for the IV-E pass-through programs.

It is anticipated that consolidation of the current CBMAC time study will have a minimal impact to the revenue received by counties currently participating in CBMAC. Counties that begin participating April 1, 2004, will share in 50% of the net federal revenue claimed under the CBMAC program. In order for those counties not currently in the CBMAC program to begin participating in the April-June 2004 quarter, counties must sign the attached agreement and submit the agreement to the appropriate Area Administrator

If a county wishes to participate at a later date, the agreement must be signed 45 days prior to the beginning of the next quarter. For example, if a county wishes to participate beginning with the July-September 2004 quarter, the agreement must be submitted to the Area Administrator by May 15, 2004.

Through the implementation of the HS RMTS, the Department will be able to differentiate medical from non-medical case management activities. As such, activities and corresponding costs associated with performing medical case management for children who are in placement and have been determined to be eligible for Title IV-E will be excluded from the state’s IV-E claim. 

Because the state is able to segregate this claim, it will be possible for counties to claim TCM for medical case management performed by any of the agency staff, including child welfare staff, for the Title IV-E eligible children in out-of-home care who are eligible for TCM. The DCFS Numbered Memo #2002-09 and related MA Provider Handbooks will be updated and reissued to reflect this change.

HS RMTS Process

The two key components of the HS RMTS are Time Reporting and Financial Data Collection. Instructions and training will be provided to the counties. A brief description of these components follows:

Time Reporting

The time reporting process, the random moment sample, measures the work effort of county and applicable contract staff performing either child welfare (defined as: out-of-home care or preventing out-of-home care activities) or Medicaid outreach or administrative activities by sampling and analyzing the activities of randomly selected staff within the statewide participant group. 

Employees are polled at random moments over a given time period. The results of the polling are used to determine the percentage of time spent by staff on either IV-E, MA or CBMAC eligible activities. The polling will be performed via phone calls to randomly selected staff participating in the HS RMTS. The number of samples per worker will depend on the number of eligible workers participating in the HS RMTS. 

It is anticipated that responding to the call will take approximately two minutes per call and that a worker would receive a maximum of 1-2 calls per quarter for a total of 2,500 to 3,000 random moments per quarter. This method provides a statistically valid means of determining the work effort eligible for both IV-E, MA and CBMAC reimbursement.

The Roster is the list of staff who will participate in the time study random moment sample and who potentially perform federally reimbursable activities. These staff are identified by the county agency based on the expectation that they perform the activities for which federal costs are reimbursable as part of their job function. 

Full time and part time staff, both contracted and employed, may be listed on the roster for participation in the HS RMTS. The following selection criteria will be used when selecting participants for the HS RMTS roster:

  • Social Services Staff: Social Workers, Case Workers, Social Service Aids, and Child Care Workers. Because of the diversity of county organizational structures, "social services" is intended to define the type of services provided regardless of whether those services are provided by a Department of Social Services, a Human Services Department or other organizational unit.
  • Other Human Services Staff: Workers providing services authorized under Chapter 51, Wisconsin Statutes whose job expectations include activities such as the following:
    • Participating in community outreach and public awareness;
    • Seeking out clients that are medically at risk, linking clients with health services, facilitating clients application to Medicaid; and
    • Assisting clients in accessing Medicaid services, participating in client care planning, and performing quality assurance.

Counties are responsible for assigning an HS RMTS Coordinator, identifying county staff and contract personnel to participate in the time study, and training participants. The county HS RMTS Coordinators review the job descriptions and functional expectations of potential participating staff to determine which positions are Social Services or are positions expected to perform allowable Medicaid administrative activities, and submit a roster identifying these staff for participation in the HS RMTS time study. 

The county HS RMTS Coordinator is responsible for updating the HS RMTS roster for additions, deletions and corrections each quarter. Updated rosters are due 45 days before the start of each quarter via e-mail to hsrmts@maximus.com.

Contract staff may be included on the HS RMTS roster. Counties may review their contract staff and determine that selected contract staff perform allowable administrative activities and should be included on the HS RMTS roster. 

Counties should sign an Administrative Claiming Agreement with their contract agencies which documents performance of administrative activities and full participation in training and the sampling process as contract requirements. Once an agreement is in place, selected contract staff from the contract agencies may be added to the counties' HS RMTS roster.

The State will administer the HS RMTS and apply the HS RMTS results.

All telephone polling will be conducted from the DHS State Office Building located at 1 West Wilson Street in Madison, Wisconsin. The following staff will be conducting the telephone polling interviews:

Sarah Cannon, DHS , Bureau of Fiscal Services
Chapman Holbrook, MAXIMUS, Inc.

Back up polling will be provided by:

John Kallas, DHS , Bureau of Fiscal Services
Mary Ritchie, DHS , Bureau of Fiscal Services
Todd McMillion, MAXIMUS, Inc.

Monthly Financial Data Collection

To calculate the IV-E and Medicaid administrative costs and to assure that there is no duplication of federal funds for the same services, monthly reporting of financial information by the counties using the Community Aids Reporting System (CARS) is required. A new profile will be added to the CARS system and will be used to identify all costs allocable to county and contractor staff included in the HS RMTS sample population. 

Allowable costs include all costs attributed to the participants subject to the time study sample population, costs of non-sampled supervisory and clerical staff that provide 100 percent direct support to the participants, direct costs that relate solely to expenditures of the participants identified by the county, and attributable indirect costs. Through the CARS system counties will offset federal funds that support staff costs included in the time study.

The financial reporting process and the time reporting ensures that federal funds and unallowable costs are excluded from the claim calculation model. As state policies and practices change, the financial reporting process can be easily amended to address changes.

Required County Actions

Responsibilities of the County Department of Human Services, Social Service, and Community Programs, the Bureau of Milwaukee Child Welfare and the State Special Needs Adoption Program participating in the HS RMTS include:

  1. Provide personnel to submit rosters, distribute instruction, provide training, and assist with quality assurance and submission of requested information.
  2. Assure participating staff attends the required training prior to inclusion in the HS RMTS sample.
  3. Participate in HS RMTS using random moment sampling and attend ongoing training as required.
  4. Prepare and submit monthly expenditure reports through CARS following instructions provided by DHS .

The Department has entered into an agreement with MAXIMUS, Inc. to assist with the implementation of the HS RMTS including providing training to the counties, assisting DHS with operating the Random Moment Sample system, and assisting with preparation of the federal claim.

Timeframe for Implementation

DHS has resolved to implement the consolidated time study instrument, the Human Services (HS) RMTS effective April 1, 2004. A summary of the important dates and deadlines follows:

April 1, 2004 HS RMTS Polling Begins
April 19-23, 2004 Financial Training for County Financial Managers
May 28, 2004 Financial Data for April 2004 Due

REGIONAL OFFICE CONTACT:
Area Administrator

CENTRAL OFFICE CONTACTS:

Dennis Dombrowicki
DDES/OO
dombrdh@wisconsin.gov

Paul Minkus
DCFS/AO
minkupm@wisconsin.gov

Catherine Lorence
DMT/BFS Federal Funding Accountant
(608) 267-7846
Lorencm@wisconsin.gov

Sally Acuff
DMT/BFS Special Services & Financial Statements Section Chief
(608) 266-9576
acuffsa@wisconsin.gov

MEMO WEB SITE: 
http://www.dhs.wisconsin.gov/partners/local.htm

Attachment - 2004 ADMINISTRATIVE CLAIMING AGREEMENT (below):

_____________________________________________________________________________

2004 ADMINISTRATIVE CLAIMING AGREEMENT

INTERAGENCY AGREEMENT

Between the
Wisconsin Department of Health and Family Services
And

_________________________________________

For participation in the
COMMUNITY BASED MEDICAID ADMINISTRATIVE CLAIMING PROGRAM

THIS agreement is made and entered into and effective the _______ day of ________, 2004, by and between the DEPARTMENT OF HEALTH AND FAMILY SERVICES, (hereinafter referred to as DHS ), and _______________________________, (hereinafter referred to as COUNTY).

WHEREAS, authority and responsibility for the administration of the Wisconsin State Medicaid program has been delegated to DHS as the Single State Agency. DHS , in its capacity as the Single State Agency, is responsible for insuring the quality and cost effectiveness of the Medicaid programs in Wisconsin;

WHEREAS, DHS has determined a need to facilitate Title XIX reimbursement to Counties for eligible Medicaid Title XIX outreach and administrative services;

WHEREAS, The Community Based Medicaid Administrative Claiming Program (CBMAC) will provide a method of federal reimbursement for eligible Medicaid Title XIX outreach and administrative services currently performed by County Departments of Human Services, Social Services, and Community Programs for individuals who need or are potentially at risk of needing health related services. Eligible administrative functions are primarily to locate, identify and refer individuals needing health/mental health related services, to assist families in accessing Medicaid services through education, public awareness, and seeking appropriate providers and care for individuals. The primary benefit to individuals is to assist families and adults in identifying and accessing Medicaid through education and awareness;

WHEREAS, DHS and/or its authorized agent has developed a detailed methodology to assess the reimbursable contribution from the COUNTY and to determine and administer the process for calculating and collecting allowable claims for reimbursement of Medicaid administrative outreach activities;

NOW, THEREFORE, in consideration of mutual promises of the parties contained in this agreement, the parties agree as follow:

  1. TERM. The term of this agreement is made and entered into for the period of _________________, 2004 through December 31, 2004.
  2. The COUNTY agrees to:
  1. Perform Medicaid Title XIX outreach and administrative services.
  2. Provide personnel to submit rosters, distribute instruction, provide training, and assist with quality assurance and submission of requested information.
  3. Assure participating staff attend the required training prior to inclusion in the HS RMTS RMS sample.
  4. Participate in time studies using random moment sampling and attend ongoing training as required.
  5. Prepare and submit monthly expenditure reports through CARS following instructions provided by DHS .
  6. Submit with monthly financial information through CARS reporting system certification in the format requested by DHS attesting to the use of local mill levy or county aide funds of not less than fifty percent (50%) of the amount expended for Medicaid Administrative activities.
  7. Maintain documentation related to Medicaid Administrative claiming for a minimum of five (5) years after the date the financial expenditure costs are reported.
  1. The Department of Health and Family Services (directly and/or through its agents) agrees to:
  1. Provide and complete the quarterly telephone survey for the RMS time study.
  2. Do a complete analysis of all data acquired from the County by the methodology developed and approved by the Division of Cost Allocation (DCA) and will verify the contribution from the County for Medicaid reimbursement through this program.
  3. Provide appropriate training materials and initial and ongoing training for the use of the HS RMTS and CBMAC methodology developed and approved by DCA to the County.
  4. Provide and maintain financial reporting instructions to the County.
  5. Provide initial and ongoing financial reporting training to the County regarding compilation of expenditure data for reporting through CARS.
  6. Provide technical assistance to the County to support participation in the HS RMTS and the CBMAC program.
  7. Make payment to the COUNTY after receiving federal revenue by either check or by direct deposit to the designated financial institution based on the share or proportion of new revenue the state authorized by state policy or statue to distribute to counties.
  8. Provide and maintain a toll-free number to facilitate response to queries from the COUNTY
  1. AUDIT DISALLOWANCES. In the event that a state or federal audit discloses unallowable costs, recoupment of the County share of the disallowance will be treated as a reduction of subsequent payments of the County proportion of federal revenues received for CBMAC activities.
  2. AUTHORIZATION. This agreement is contingent upon authorization of Wisconsin and United States law and any material amendment or repeal of same affecting relevant funding to, or authority of, the Department shall serve to terminate this agreement except as further agreed by the parties hereto.
  3. TERMINATION OF THIS AGREEMENT. This agreement may be canceled by either party by providing written notice thereof at least ninety (90) days in advance of the effective date of the termination.
  4. AMENDMENT. The parties agree that any amendments to this agreement shall be by mutual agreement and shall be in writing.

IN WITNESS WHEREOF, the parties hereto affix their signatures to this agreement.

_____________________________                     ______________________________
County Executive, Board Chairperson,             DHS Deputy Secretary
Or Designee
(Designee Authorization attached if Designee)

_____________________________                     ______________________________
Date                                                                             Date

______________________________________________________________________________

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