MR/DD Update — Active Treatment/Day Program

Since the passing of House Bill 66 (HB66) and the elimination of the CAFS program, funding for active treatment and day program services has changed. ICF/MR providers are now receiving an active treatment add-on that is added onto their current Medicaid rate setting. By now, all providers are aware of this add-on, but are you aware of the components that make up the rate and the cost of each component per day? This will become more important as we move through this new mechanism of reimbursement for active treatment or day programming.

The following are the rates per day for each component of the active treatment add-on:

The total add-on rate of $32.48 is then adjusted by a factor relating to cost of doing business that is specific for each county. We are finding that the way transportation is handled in contracts or internal protocols can have a significant impact on bottom-line results.

Some ICF/MRs are continuing to contract with their local county boards of MR/DD, while other have decided to create their own program to provide active treatment for their residents as well as other residents within the county. Yet a third option has been to contract with another provider who is offering day program services. Under each situation, there are some items that should be considered as we move though the second half of this fiscal year.

• Conduct an analysis of the profit or loss in your active treatment or day program services. Whether you have continued to contract with your local county board, another provider, or have developed a program in house, it will be important to monitor the programs financial results. This will supply valuable information to either renegotiate county or provider contracts, or it will supply information to the state of the adequacy of the rate add-on.
• If providing the services internally, breaking up the cost of the program into the various components above will be important as well. This will give the provider associations and ODJFS valuable information on how adequate the add-on components are and what revisions may be necessary.

Definition of “off-site” was established in a re-filed rule in January 2006, which slightly broadened the definition. This allows providers to deliver on-site services or continue to provide active treatment in their facilities. According to OAC Rule 5123:2-3-24, “off-site” is defined as:

• Not in the same building as the ICF/MR; and/or
• Not in any residential facility; and/or
• Not within two hundred feet of the building housing the ICF/MR

There are three exceptions to the “off-site” definition.

1. If the service plan indicates that providing the services off-site would be contraindicated for the individual, services can be provided on-site.
2. If a provider was offering on-site active treatment or day program services prior to July 1, 2005, they are grandfathered and can continue to offer on-site services.
3. If a provider was using an outside entity to perform services and the outside entity notifies the ICF/MR that they can no longer carry out those services, an ICF/MR may provide those services for an 18-month period.

The 2005 cost report has added a cost line item, account 9775, that is to be used to capture all costs associated with active treatment or day programming. If a provider contracts with the county board for active treatment services, then the contract costs would be recorded in this line item.

If a provider is performing services internally, the costs attributed to the program would be recorded on this line. It is important to understand that if a provider has an active treatment program, there may be some costs that are shared by the ICF/MR and the active treatment program that need to be allocated to account 9775.

It will also be important to further break down those costs in account9775 to the various components discussed above. Although this is not a requirement for the cost report, it will become important when analyzing the adequacy of the Medicaid add-on to the rates.

We have developed a tool that helps providers analyze their active treatment or day program and assists them in allocating costs to account 9775 which further breaks down costs into the components for an easy analysis of cost per rate by component. This tool was distributed to numerous ICF/MR providers throughout the state. If you did not receive a copy of the Excel-based tool or have questions about your day program, please contact Patrick McCormick at 216.274.6524 or Roy Cherry at 419.842.6108.