Virginia Regulatory Town Hall
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Department of Medical Assistance Services
 
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Board of Medical Assistance Services
 

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9/21/17  5:20 pm
Commenter: Maureen Hollowell, Virginia Association of Centers for Independent Living

DME, Chapter IV
 

DME, Chapter IV, Page 4, paragraph 4 includes the following statement: Costs incurred for shipping and handling, except when otherwise noted, are considered to be a part of the DME provider’s overhead/business expenses.

VACIL Comment: Clarify if the “shipping and handling” costs are related to the items being sent to the provider or the items being sent to the individual. Also clarify if “shipping and handling” is considered part of the allowable 30% mark-up.

DME, Chapter IV, Page 5, paragraph 1, line 8 includes the following statement: requires a wheelchair for the school environment.

VACIL Comment: Will there be a requirement that items needed in the school environment be on the person’s individual education program (IEP) in order to be covered as Medicaid DME? What if the person does not have an IEP, but rather a 504 plan; will they be required to have the item on their 504 plan? Does “school” refer only to public school or does it include private school, homeschool and/or college environments?

DME, Chapter IV, Page 16, paragraph 2, line 5 includes the following statement: The reimbursement amount is determined by adding 30% to the providers cost for the item, unless this amount exceeds MSRP. DMAS will not reimburse over MSRP.

VACIL Comment: DME providers should ensure delivery, set up and demonstration of DME, as needed by the individual. The Manual should have an allowance if the DME provider’s cost to perform these tasks exceeds the manufacturer’s suggested retail price (MSRP).

DME, Chapter IV, Page 31, paragraph 2 references the Technology Assisted Waiver.

VACIL Comment: References to the previous Technology Assisted Waiver should be changed to the Commonwealth Coordinated Care (CCC) Plus Waiver throughout the Manual.

DME, Chapter IV, Page 31, paragraph 5, line 3 includes the following statement: Exceptions include those individuals authorized through the Medicaid Technology-Assisted Waiver.

VACIL Comment: This exception should continue for individuals enrolled in the CCC Plus Waiver.

DME, Chapter IV, Page 33, paragraph 4, line 1 includes the following statement: Children under the age of five (5) who receive Medicaid through a Managed Care Organization (MCO) will receive medical formula and nutritional supplements through DMAS enrolled DME providers. The provision of medically necessary formula and medical foods for children under the age of 5 is not required of DMAS contracted MCO’s, this service is carved out from the DMAS Managed Care Contract.

VACIL Comment: Clarify if this reference to managed care organizations includes CCC Plus managed care.

DME, Chapter IV, Page 33, paragraph 4, line 5 includes the following statement: Medical formula and nutritional supplements must be practitioner recommended to correct or ameliorate a health condition that requires specialized formula and medical foods to supplement diet due to metabolic limitations or provide primary nutrition to individuals via enteral or oral feeding methods.

VACIL Comment: Amend this sentence to add the word “maintain”. The new sentence would read as follows: Medical formula and nutritional supplements must be practitioner recommended to correct, maintain or ameliorate a health condition that requires specialized formula and medical foods to supplement diet due to metabolic limitations or provide primary nutrition to individuals via enteral or oral feeding methods.

EPSDT includes maintaining a child’s condition, if the condition cannot be corrected or ameliorated.

DME, Chapter IV, Page 66 references the practice of authorizing services for individuals enrolled in the Technology Assisted Waiver.

VACIL Comment: Clarify that individuals enrolled in the CCC Plus Waiver who are not enrolled in the CCC Plus managed care program will continue to have their authorizations submitted to the “DMAS services authorization contractor”.

Clarification should also be made about the role of the health care plans for individuals enrolled in CCC Plus managed care.

DME, Chapter IV, Page 72, paragraph 4 directs the provider to make a request to the Services Authorization contractor for replacement of specific DME following a natural disaster.

VACIL Comment: Clarify whether providers should send the request to the Services Authorization contractor or to the CCC Plus managed care plan, if the individual is enrolled in CCC Plus managed care.

DME, Chapter IV, Page 74, paragraph 1 includes the following statement: This includes individuals enrolled through the Commonwealth Care Program (CCC) as well.

VACIL Comment: Clarify whether individuals enrolled in the CCC Plus managed care program will use the single vendor for specific incontinence supplies.

CommentID: 62820