DDES INFO MEMO 2005-11
September 21, 2005
To:
Area Administrators/ Human Services Area Coordinators
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:
Health Insurance Portability and Accountability Act Reimbursement Update
The purpose of this memo is to provide information to counties and
tribes regarding the status of the Department's efforts in obtaining
approval from the Federal Department of Health and Human Services (DHHS)
for the reimbursement of county and tribal costs required under the
Health Insurance Portability and Accountability Act (HIPAA) retroactive
to 2002 and then on an ongoing basis. The Department submitted an
amendment to the cost allocation plan that would allow the Department to
claim and reimburse counties and tribes for the federal share of
expenditures counties incurred in coming into compliance with federal
HIPAA regulations, retroactive to 2002.
The plan amendments have not been approved. The Division of Cost
Allocation (DCA) and the Centers for Medicare and Medicaid Services
(CMS) indicated that federal rules only allow retroactive claiming when
a State can demonstrate a significant inequity unless such retroactive
claiming is allowed. To assert significant inequity we would need to
demonstrate that the retroactive amount is extremely large either in
absolute dollar amount or as a percentage of overall Medicaid costs. The
Department has been unable to convince DCA or CMS that this request
meets those tests.
DCA and CMS have also raised questions on the appropriateness of
breaking HIPAA related costs out from other program related costs for
claiming purposes.
The Department at this point will not continue attempting to obtain
separate reimbursement for county HIPAA expenditures. The Department has
determined that we cannot meet DCA's suggestions on demonstrating a
"significant inequity" and that federal approval of separate
allocation and claiming of HIPAA costs is unlikely. If you have any
questions, please call Dennis Dombrowicki.
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
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