Important Updates/Clarifications as of 3.23.2017
Many of us have heard in the Beacon trainings (regarding the Medicaid Behavior Analysis Services Policy) that clients must have maladaptive behavior to be approved for Behavior Analysis services. In a recent meeting between the FABA Legislative Committee and AHCA, we were told that Behavior Assessments that are missing maladaptive behaviors will not be denied for that reason alone. Instead, they will be escalated to a higher level review to determine medical necessity. Medically necessary services, which include habilitative services according to EPSDT, are covered.
To help providers understand what is important to include in their authorization requests, Beacon has reported some trends in the Behavior Plans received from Lead Analysts. These include:
- Lack of parent/caregiver goals
- Service intensity not justified in the plan
- Group code requested but no group goal addressed
- Plan not individualized to the recipient
However, to date, Beacon has not denied any authorizations. Please make sure to pay close attention to the above trends to help facilitate the authorization process.
Many of our members have contacted FABA to ask for help because their Type 39 Provider application has still not been approved. AHCA has been informed about this urgent issue and is looking into options to remedy the situation. In the meantime, they have suggested that those who need help with applications should contact the following:
Additionally, if applicants need assistance beyond that provided by the call center representatives, they may request a visit with a field representative who will work one-on-one with them via the following contact number: 1-800-829-7799, Option 4.
AHCA Agrees to Delay Implementation of Behavior Analysis Policy Until March 1, 2017.
The implementation of the new Medicaid Behavior Analysis Policy for children age 0-20 was planned to start on February 1, 2017. As of that date, many ABA agencies and individual providers had not yet received their new Type 39 provider number. This would have meant that many providers would not be able to get reimbursed for their services until their application was approved. Since many providers would not be able to continue providing services without pay, resulting in loss of services for many recipients, the FABA Legislative Committee brought these concerns to AHCA. After some deliberation, AHCA agreed to delay the requirement to begin using the new billing codes (which can only be provided by Type 39 providers) until March 1, 2017.
The requirement to have an authorization from Beacon prior to April 3, 2017 is still in place, so all providers planning to provide services for recipients age 0-20 on or after April 3 will need to request an authorization.
FABA Successfully Challenges AHCA Policy on Behavior Analysis Services & Encourages Its Members to Immediately Enroll In The BA Services Program
As we previously reported, on November 14, 2016, the Florida Association for Behavior Analysis filed a petition with the Division of Administrative Hearings in Tallahassee, challenging the Agency for Health Care Administration’s (AHCA) adoption of Proposed Rule 59G-4.125, F.A.C., regarding its Behavior Analysis Services Policy.
FABA’s challenge to the published policy focused on preserving positive changes to the policy achieved during the workshop and hearing process, as well as making sure that the policy is limited to behavior analysis services, not services that have no connection to behavior analysis. For example, it was important the policy was clarified that psychological testing, neuropsychology, psychotherapy, cognitive therapy, sex therapy, psychoanalysis, hypnotherapy, and long-term counseling are not to be reimbursed under the behavior analysis policy. Further, it was essential that the policy require that lead analysts who are not BCBA’s but who are licensed under Chapter 490 or 491, have training and expertise in the field of behavior analysis.
A link to the second notice of change for the policy is found here: http://www.ahca.myflorida.com/medicaid/review/Rules_in_Process/NOC/59G-4.125_BA_Coverage_Policy_afterNOC2_trk_chgs.pdf and incorporates revisions made in each of the workshops and the final proposed rule hearing. FABA and AHCA filed a joint motion to dismiss the petition based upon AHCA’s changes to the behavior analysis policy, which has been accepted by the administrative law judge.
With the major policy considerations resolved as a result of the litigation, FABA encourages its members to ENROLL IMMEDIATELY in the behavior analysis provider program at the Florida Medicaid Web Portal. As most of you know, ABA services for Medicaid recipients under the age of 21 will soon be required to be provided under the new Medicaid Behavior Analysis policy, and ABA services provided through all other Medicaid funding streams (e.g., Early Intervention, Community Behavioral Health, iBudget Waiver, “state plan” Autism services) will be discontinued.
Although the policy is expected to be officially promulgated in mid-February, the implementation of the new policy starts February 1, 2017, which is only a week away. According to AHCA and Beacon, all services provided on or after that date will have to be billed under the new policy’s service codes and limits, and only agencies and individuals with Type 39 provider numbers will be able to provide those services. If you are currently providing ABA services under another Medicaid policy and have not received your Type 39 provider number yet, you will not be able to be paid for services after 2/1/17. All ABA provider types (BCBA “Lead Analyst,” BCaBA “Assistant Behavior Analyst,” and RBT) are required to obtain an individual provider number, even if providing services under a Type 39 group.
Between 2/1/17 and 4/2/17, providers need to be submitting authorization requests for ABA services to Beacon because all services provided on or after April 3, 2017 will be required to have an authorization from Beacon in order to be paid. Only approved Type 39 providers will have access to the Beacon system to submit authorization requests. Beacon has pre-recorded trainings to explain the authorization process and the elements required in the Behavioral Assessment and Reassessment.
Link to AHCA Behavior Analysis Services Provider Information: http://ahca.myflorida.com/medicaid/Policy_and_Quality/Policy/behavioral_health_coverage/bhfu/BA_Services.shtml
Link to the Beacon pre-recorded trainings: http://fl.beaconhealthoptions.com/provider/prv-archive.html
Link to the most recent version of the proposed Behavior Analysis policy: http://ahca.myflorida.com/medicaid/review/Rules_in_Process/NOC/59G-4.125_BA_Coverage_Policy_afterNOC2_trk_chgs.pdf
Link to the proposed Behavior Analysis billing codes and fee schedule: http://ahca.myflorida.com/medicaid/review/Rules_in_Process/Develop/2016-08-01_BA_Fee_Schedule.pdf
Link to the AHCA Provider Enrollment Application: https://portal.flmmis.com/flpublic/Provider_ProviderServices/Provider_Enrollment/Provider_Enrollment_EnrollmentApplication/tabid/67/Default.aspx?desktopdefault=%20,
Link to the AHCA Provider Enrollment Application Guide: http://portal.flmmis.com/FLPublic/Portals/0/StaticContent/Public/Public%20Misc%20Files/Guide_for_App_for_2015_Final_2015-02-27.pdf
Providers need to submit their applications by February 1, 2017, before providing any ABA services (for recipients age 0-20) dated on or after February 1, 2017. Failure to submit an application will result in no reimbursement for services rendered on or after February 1, 2017.