Legislative and Public Affairs
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FABA Legislative and Public Policy Committee
May 19, 2017 – Attention FL Medicaid ABA Providers!
Please find below some helpful resources, courtesy of AHCA.
The Medicaid Public Web Portal provides access to the Provider Services page where providers can obtain helpful information including:
- Electronic Data Interchange (EDI) including companion guides for the creation of claims, EDI software and manuals, EDI forms and agreements, and Submission Information such as an interactive Web site for testing claims transactions and sample files.
- Provider Enrollment guidance and forms.
- Provider support including alerts of policy or protocol changes, links to Medicaid handbooks and fee schedules, and contact information.
- Provider Training
- The Provider Electronic Solutions (PES) Web-based Training (WBT) is an interactive walk-through that introduces providers to the available menu items in PES and provides step-by-step instructions for completing and submitting claims via PES.
- The Web Portal WBT is designed to demonstrate various functionality of the Medicaid Web Portal through an interactive walk-through that introduces providers to the available menu items that provide important provider information such as provider demographics and recipient eligibility.
The Medicaid Provider Contact page provides links to contact information for the following:
- The Medicaid Fiscal Agent, DXC Technology, for claims and provider enrollment inquiries and assistance with access to the Medicaid Secure Web Portal.
- Recipient and Provider Assistance to contact a Medicaid representative.
- Fiscal Agent Field Representative Map
- Online tool for submission of and inquiry and to request a contact from the Fiscal Agent.
May 15, 2017 – Attention providers of Medicaid ABA services:
The FAQs for Behavior Analysis services have been posted to the AHCA website. They are located at the bottom of the page after the Enrollment Begins Now section. For your convenience, the link is Included below.
April 18, 2017 – Florida Behavior Analysis Month
The Florida Senate approved Resolution No. 1814 Commending FABA on its 37th Anniversary, and recognizing the month of October 2017 as “Florida Behavior Analysis Month”!!! The resolution was introduced by Senator Bean.
April 24, 2017 – ATTENTION MEDICAID PROVIDERS OF ABA SERVICES!
AHCA has reported a drop in authorization requests since the deadline was pushed back to May 15. It is important that providers keep sending their authorization requests during this transition period to avoid the last minute rush just prior to May 15. If too many requests come in at the last minute, it could delay authorizations for everyone.
March 23, 2017 – Important Updates/Clarifications
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:
For more information:
Medicaid Provider Type 39 enrollment number:
(option 4) for Provider Enrollment
March 15, 2017 – Behavior Assessments that are missing maladaptive behaviors
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 includes habilitative services according to EPSDT, are covered.
To help providers understand what is important to include in their authorization requests, Beacon has reported that the most common reasons that authorization requests have been denied include:
- Lack of parent/caregiver goals
- Service intensity is not justified
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: email@example.com
Please make sure to check the http://www.fabaworld.org website for important announcements and updates.
February 3, 2017 – 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
Link to the Beacon pre-recorded trainings:
Link to the most recent version of the proposed Behavior Analysis policy:
Link to the proposed Behavior Analysis billing codes and fee schedule:
Link to the AHCA Provider Enrollment Application:
Link to the AHCA Provider Enrollment Application Guide:
May 30, 2016 – Medicaid Policy on Behavior Analysis Coverage
- Link to most recent draft of the rule – –
- Link to most recent fee schedule for services – – https://ahca.myflorida.com/medicaid/review/Promulgated/Fee_Schedules/2016_01_01_Behavior_Analysis_Fee_Schedule.pdf
- Link to ACHA memo regarding provider enrollment – – http://www.fdhc.state.fl.us/medicaid/Policy_and_Quality/Policy/behavioral_health_coverage/bhfu/BA_Services.shtml
April 14, 2016, – New Insurance Coverage Law for Down Syndrome Treatment Includes Behavior Analysis Services
On April 14, 2016, Governor Rick Scott signed House Bill 221, which requires health maintenance organization contract and certain insurance policies to cover behavior analysis services for the treatment of Down Syndrome. Previously, Florida statutes provided that behavior analysis services were only mandated for the treatment of autism, however this change significantly expands the law. Thank you to Senate President Andy Gardiner who help shepherd this long-overdue amendment to the insurance law. This change is effective July 1, 2016, and FABA will be working with the Office of Insurance Regulation to make sure families can access this new insurance benefit.
April 7, 2016 – AHCA Holds Workshop On Medicaid Policy For Behavior Analysis Service & Contracts With Beacon Health Options For Utilization Management
On April 7, 2016, the Agency for Health Care Administration held its third workshop on the new policy for behavior analysis services. FABA participated in the workshop and commented on the need to include an accurate definition of behavior analysis as well other issues that should be addressed before the policy is finalized. AHCA is expected to publish a revised policy and a notice of hearing on the policy in the near future. AHCA also selected Beacon Health Options as its vendor to handle utilization management for behavior analysis services for the treatment of autism under the Medicaid program. FABA met with members of Beacon’s leadership team to discuss their role in authorizing and reviewing behavior analysis services for the Florida Medicaid program. Beacon has considerable experience working with BCBAs in other states and FABA looks forward to Beacon presenting at the Annual Meeting in September.