DDES INFO MEMO 2004-06
August 17, 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
Section Chiefs/Licensing Chiefs
Tribal Chairpersons/Human Services Facilitators
From:
Sinikka Santala
Administrator
Re: Update Reimbursement for Health Insurance Portability and
Accountability Act
The purpose of this memo is to provide information to counties
regarding the status of the Department’s efforts in obtaining approval
from the Federal Department of Health and Human Services for the
reimbursement of county cost required under the Health Insurance
Portability and Accountability Act.
A number of questions have been raised by the Federal Department of
Health and Human Services (DHHS) Division of Cost Allocation of the
Department of Health and Family Services (DHFS) methodology and timing
for claiming Health Insurance Portability and Accountability Act (HIPAA)
costs incurred by the counties. The counties, as business associates of
DHFS, must comply with the requirements of HIPAA dealing with: 1) the
confidentiality of health or health related information, 2) the
standards for the security of individual health information that is
electronically maintained or transmitted, and 3) the standards for
electronic transactions.
The Department originally proposed to DHHS that on a monthly basis,
the counties will identify their 100% HIPAA direct dedicated
expenditures and submit them to the State of Wisconsin via the
appropriate Community Aids Reporting System (CARS) profile. The Division
of Disability and Elder Services (DDES) Office of Operations will then
apply the counties’ Medicaid Eligibility Rate (MER) to the eligible
100% direct dedicated HIPAA compliance expenditures. The result will be
claimed at 50% Federal Financial Participation (FFP). This position now
has been revised.
The original submission to DHHS for allocating the cost was based on
the MER. Based on further review, DHFS believes that using the number of
insurance claims processed is a more equitable basis for allocation of
HIPAA costs. This allocation basis is also in accordance with the
original HIPAA law pertaining to Administrative Simplification. The
purpose of the provision was to reduce the costs of health care
administration by encouraging an expansion of automated billing. Based
on this position, the DHFS plan to DHHS was revised under the Claiming
Methodology category. The revised methodology states: "On a
quarterly basis, the counties will identify their 100% HIPAA direct
dedicated expenditures and submit them to the State of Wisconsin’s
DHFS via the appropriate CARS profile. Also on a quarterly basis the
counties will report the number of insurance claims processed for
Medicaid eligible and non-Medicaid eligible recipients. The DHFS DDES
Office of Operations will, on a quarterly basis, apply the counties’
percentage of Medical Assistance claims processed to all eligible 100%
direct dedicated HIPAA compliance expenditures for the quarter. The
result will be claimed at the 50% FFP."
Currently, we are waiting for the approval of our revised plan from
DHHS. The DHHS is also questioning our starting date of calendar year
2002. Depending upon DHHS decision, the DDES Office of Operations will
need the total claims processed for Medicaid and non-Medicaid eligible
recipients for calendar year 2003 and possibly 2002 for each of these
years.
Summary Statement
The Department is addressing the issues raised by the Department of
Health and Human Services Division of Cost Allocation in our plan to
claim HIPAA expenditures counties have incurred to comply with the
requirement. As soon as we are given the approval to submit a claim for
HIPAA under the Medicaid program, the DDES Office of Operations will
inform you of the process and methodology.
Central Office Contact:
Dennis Dombrowicki
DHFS/DDES/Office of Operations
PO Box 7851
Madison, WI 53707-7851
608-266-3057
Email: dombrdh@dhfs.state.wi.us
MEMO WEB SITE:
http://dhfs.wisconsin.gov/partners/local.htm
Return
to Info Memos Index
|
