Proposed Language:

d. e. The yearly limit for mental health support skill-building services is 372 units. Only direct face-to-face contacts and services to the individual shall be reimbursable. One unit is at least one hour but less than three hours.

In the Economic Impact Analysis the following is quoted: The proposed regulations would change the unit structure to a 15 minute billing unit and decrease the number of units per day that an individual may receive the service (decreasing from seven hours to up to 5 hours allowable as a maximum of twenty 15 minute billing units per day) to ensure that the service is not over-utilized. The new unit value and new unit allowance would yield a maximum of 5 hours per day, 5 days per week for a total of 5,200 fifteen-minute units per year. The changes in the daily, weekly, and annual limits would stagger services so that they may be provided consistently over the course of a year. The current reimbursement rate is $91 per unit in urban areas and $83 per unit in rural areas. Under the new system, the rate for one 15-munite unit would be $14.77 in urban areas and $13.47 in rural areas. According to DMAS, under the new unit and rate structure, the total expenditures would increase if the maximum limits are billed. However, with the new daily and weekly limits in the unit structure maximum yearly limit would be more difficult to achieve.

Comment:

15 minute units are preferable, but the proposed language for regulations still reflects current unit structure.

Recommendation:

 Update to be consistent with EIA report.