1. Manual Submission. The proposed regulations require manual submission of the CMS-1500  claims. The manual submission places an administrative burden on the Provider and the available staff resources are not sufficient to meet the volume of TDO’s that will be required to be manually submitted. Requesting the electronic submission is allowed and electronic billing platform with DMAS is established to submit the CMS -1500 claims.

1. The claim CMS-1500 needs to be manually entered and hard copy rather than an electronic submission (pages 22-28) In the “Professional Billing and CSU per diem billing instructions”  page 22 through 28, there are several areas on the CMS- 1500 claim form that require manual entry rather than retrieval from the Electronic Health Record, such as 9, 10d and 11c. Provide clarification whether electronic submission is allowed.

2. Requesting clarification regarding CMS-1500 Instructions

1. Box 1a page 22 is required to be blank. This creates difficulties as a required field cannot be left  blank on electronic fields;  Box 23, page 25 indicates prior authorization number is being utilized instead of the TDO/ECO number. Requesting change to the explanation - use of the TDO/ECO number should be used in box 1a instead of  box 23 as an authorization number and elimination of box 23.

2. Box 9 page 23 is required and cannot be configured to pull in electronically. It would have to be entered manually and this indicates that ECOs are billable. The content of the Draft indicates  that ECOs are not reimbursable through this fund. Provide clarification  whether ECO’s are billable through the TDO reimbursement process.

3. Page 5  reads: “TDO claims submitted by CSUs will not be processed by the FFS contractor, Medicaid MCOs or PACE.  Providers of TDOs in CSU settings are not required to first submit claims to the FFS contractor, MCO or PACE prior to mailing the claim to the TDO Program.” This seems to imply that the provider can submit the claims directly to the TDO program. The fact that the claims would not be processed by the FFS contractor or MCOs, also implies that the TDO services are not covered by Medicaid, Medicaid MCOs. Provide clarification whether the forms can be submitted directly to the TDO for reimbursement.

4. Page 6 it reads: “TDO Claims are processed by DMAS when: The TDO is not covered by the FFS contractor, Medicaid MCOs, PACE (see charts in previous sections of this supplement or other third-party insurance”;  Does this apply to both the uninsured and the forementioned groups on page 5? Provide clarification  regarding whether this applies to uninsured individuals.

5. Page 6 reads:” TDO days have been reimbursed by a primary insurance and are subject to secondary coverage by the TDO Fund.” Confirmation from the primary payer prior submitting and filing the TDO funds, which could delay reimbursement. This will delay the reimbursement process because the billing department must wait for the response from the primary payer.  Eliminate the step to submit the claim to FFS contractor, Medicaid MCOs, PACE since these entities do not reimburse for TDO’s.

6. Page 5 reads: “Charges must be submitted on a UB-04 (CMS -1540) claim form or CMS-1500 (08-05) claim form. DMAS will accept only the original claim forms. Photocopies or laser-printed copies will not be accepted because the individual signing the forms is attesting to the statements made on the reverse side of the forms. These statements become part of the original billing invoice.” Box 12 on page 24 indicates the signature is not authorized and it is contradictory to statements on page 5 requiring patient signature for attestation. This presents burden on the Provider-  the billing department fills out the CMS-1500 form when the original claim form is required, and the billing department has no direct contact with the patient.

Remove contradictions in the document pertaining to patient signature and permit acceptance of an electronic copy of the completed form.