Florida Agency for Health Care Administration/Managed Care Behavioral Health Discussion Meeting Report: March 2, 2011

The Florida Agency for Health Care Administration (“AHCA”) held a workshop on March 2, 2011, during which representatives of Medicaid managed care companies and behavioral health providers discussed topics of concern and worked to identify ways to enhance behavioral health services to Medicaid recipients.   To view the meeting notice, click here.

Discussion touched on the topics listed below:

• Standard authorization protocol
• Standard format for the “Functional Assessment Rating Scale (“FARS”) and Children’s Functional Assessment Rating Scale (“CFARS”) forms submission based on queries from multiple providers
• Standardized approval of targeted case management training curriculum
• Standardized protocol for Baker Act / emergency services
• Billing for treatment services to members diagnosed with co-occurring disorders
• Standardized provider site visit and medical record audit tools
• Behavioral health and medical integration
• Appropriate use of Medicaid reimbursable services (provider documentation – Targeted Case Management (“TCM”) and Psycho Social Rehab (“PSR”)
• Reduction and/or loss of day treatment and Integrated Care Management in some areas
• Standardized protocol for detoxification

Standardization of practices and documentation was a common thread in all the discussions. 

Insofar as FARS and CFARS submission, one participant noted that an array of different formats is being used for the submissions, including a Florida Department of Children and Families’ format, an AHCA template, a text-only format and an Excel format.  In some instances, providers are submitting information through a Web portal, but are still having to copy it manually and then submit it in another format to AHCA.  The existing system sometimes requires providers to submit information multiple times, thus creating a time-consuming task.

“Is there a way we can all come together and agree on one format?” asked one participant.  “We need to work with the providers.   If they want to submit (information) electronically instead of manually, we have to give them that option.”

Another concern focused on privacy issues related to Health Insurance Portability and Accountability Act (“HIPPA”) laws and sending out secure files.  One managed care representative said unsecure files have occasionally been sent, thereby causing a HIPPA violation.  The provider related that, in these instances, a spread sheet containing the relevant information ultimately was faxed, but then had to be reloaded electronically by recipient staff members.

Another concern focused on standardized approval for targeted case management training curriculum, which requires the submission of training module requirements and qualifications.  It was related  that AHCA has had difficulty obtaining the corresponding documentation in many instances.  This was problematic, since proof of training and certification of case managers is checked during an audit.

Discussion then turned to standardized protocol for Baker Act/Emergency services.  An AHCA official related that the agency had recently met with legal counsel to discuss necessary requirements for emergency services and admission.   Based on those discussions, a health plan contract change was proposed and an amendment to it is being prepared.  A second meeting has been scheduled on March 14 to discuss some of the concerns that health providers continue to express in regard to the above-mentioned requirements.

“We have taken the specific questions you all have asked in regard to Baker Act and medical necessity, and we will be addressing those along with a couple others with our legal counsel,” the AHCA official said.  “This is a hot topic for us and I know it’s a hot topic for the managed care companies and I certainly know it’s a hot topic for the providers.”

Other discussion focused on:

• Billing treatment services to managed care members diagnosed with concurring disorders:  Providers treat a patient who might have both a mental health component and a substance abuse component, so how do they bill if there are two different disorders?  Participants agreed the issue is troublesome and that problems arise when a provider uses the wrong billing code.
• Appropriate use of Medicaid reimbursable services:  Individualization of care in treatment is important, but documentation must be accurate.  It was noted that proper training on necessary services and related documentation is often missing.
• Problems obtaining patient documentation from state hospitals:  Many state facilities have refused to share information once a patient is released, making it difficult to address those patients, an AHCA official explained.  In fact, one state hospital refused to do a cooperative agreement, she related. “It’s a systemic issue,” she added, also saying that the issue needs to be addressed because AHCA is charged with “keeping track of these folks.” 

Workshop participants agreed to use the aforementioned topics to create a “priority list” for future discussion.

With no further business to discuss, the meeting was adjourned.

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