The Illinois Department of Human Services/Division of Substance Use Prevention and Recovery (IDHS/SUPR) has established a Quarterly Technical Assistance (QTA) conference call to consistently offer an opportunity for Illinois providers to ask IDHS/SUPR staff questions about administrative rules, policies, and contract requirements. The 2019 QTA schedule: is April 23, 2019, 10:00 AM, July 23, 2019, 10:00 AM, and October 22, 2019, 10:00 AM. Phone number: 888-494-4032, Access Code: 6100424838#. To keep the call to the scheduled time limit, IDHS/SUPR requests that questions be submitted to DoIT.SUPRHelp@Illinois.gov a minimum of 8 days prior to each call. Note: Please do not join this call to file a complaint or share unrelated concerns or questions. The primary goal is to provide consistency in rule and policy interpretation and to improve clinical practice.
Question: Does IDHS/SUPR mandate 12-step meetings or any other specific treatment model?
Answer: IDHS/SUPR does not endorse any specific substance use disorder intervention or treatment model. A licensed organization can use any evidence-based intervention or treatment modality including cognitive behavioral therapy, motivational interviewing, 12-step philosophy, etc. However, prior to admission, the organization must provide a description of services and fees, the individual's right to refuse treatment or any specific treatment procedure, and a right to be informed of the consequences resulting from such refusal.
Each patient receiving treatment services must be provided with an individual treatment plan which they help develop and which is periodically reviewed and updated as mandated by administrative rule. Person-centered treatment means that every patient shall be permitted to participate in the planning of his/ her total care and medical treatment to the extent that his/her condition permits. A patient is also permitted to request the opinion of a consultant at his/her own expense, or to request an in-house review of a treatment plan, as provided for in the specific procedures of the organization.
Question: Can a religious-based IDHS/SUPR licensed organization refuse to provide services based upon the religious status of the patient?
Answer: IDHS/SUPR licensed organizations cannot refuse to provide services based upon the religious status of the patient and should have the capability to deliver person-centered individual treatment for each patient. If the organization identifies as a religious organization and the individual refuses to participate in services due to this status, then the organization must provide a referral to a secular provider who offers the same services. If you are concerned about the religious status of an organization, below please find contact information for the Illinois Attorney General:
Illinois Attorney General
Charitable Trust Bureau
100 W. Randolph St., 11th Floor, Chicago, IL 60601
(312) 814-2595, TTY: 1-800-964-3013
http://www.illinoisattorneygeneral.gov/charities/index.html
Question: Does IDHS/SUPR maintain a list of the fees associated with licensed services?
Answer: IDHS/SUPR licensed organizations determine their fee for all services so IDHS/SUPR does not maintain this type of fee information.
Question: What should an IDHS/SUPR licensed organization do if they are not utilizing one or all the licenses?
Answer: Organizations are encouraged to surrender the IDHS/SUPR license if they are not providing treatment and/or intervention services to the community. This helps maintain accurate records of where and what substance use disorder treatment and intervention services are being provided across the state of Illinois. Also, organizations are monitored for the license even if they are not delivering services (e.g. Level 2 - Adolescents; we would need to see CANTS results for all employees).
If an organization wants to surrender their license; the organization must inform IDHS/SUPR of their decision in writing and where closed files will be maintained post licensure.
If the organization wishes to surrender one license, but maintain another, (surrendering ASAM Level-2, but keeping ASAM Level-1); the organization must inform IDHS/SUPR of their decision in writing. Upon notice, IDHS/SUPR will update the organizations' license and inform applicable IDHS/SUPR staff of the changes.
Question: I would like clarification on the requirements for Psychiatric Evaluations. According to 2060.413 Medical Services, section B #4 it states. "A patientshall be referred for medical, surgical, obstetric, prenatal or psychiatric treatment or laboratory services as determined necessary by the medical director or other physician." Does this mean that the only the Medical director can refer clients for Psychservices, or can a Counselor/Clinician also refer a client to psychiatry services?
Answer: Anyone with the minimum qualification to provide clinical services for our awards can request the psych evaluation. The referral must me documented inthe patient's file and reflect the clinical presentation, symptoms, observations and perceived need for the evaluation to assess psychiatric diagnosis, medication needs, or monitoring the effectiveness of medications being prescribed. The patient's treatmentplan must also be updated when there is an intensification of symptoms in Dimension 3: Emotional, Behavioral, or Cognitive Conditions and Complications.
Question: If we have a Youth who is receiving substance abuse services without parent's knowledge/consent, and they have a Medicaid MCO plan-are we allowed to bill DASA Contract for all services during this time? (so that there is no risk of parent's finding out about services) Or will system automatically rejects because client has an MCO?
Answer: You can provide outpatient services without parental consent for 12-year-old and older, below that age the parents need to consent. Over 12 years old, we recommend that parental consent be obtained for residential services, but we do not mandate it. When the youth has a Medicaid MCO, the privacy of the youth, and parental notification is an issue that you need to discuss with the Medicaid MCO. You should not bill the contract for patients who have a Medicaid-MCO plan.
Question: Where can we find proof of our SUPR contract reimbursements monthly? (Similar to Medicaid or MCO remittance advice.)
Answer: Our MOBIUS reports reflect this by vendor totals, and by unit and program on the SERV code reports.
Question: Is HIV education/ outreach reimbursable under SUPR Contract - Community Intervention services?
Answer: NO, community HIV education and outreach education are done by public health and other medical health resources. If you provide HIV and or TB risk education session for individuals at risk, it would be billed as a didactic session.
Question: I seem to remember at one point that DASA would allow for billing of up to 3 Residential bed days when a client went into the Hospital in order to "HOLD" the slot for them until they were released (only Contract $$ and not Medicaid $$). Is this something that I dreamt or is it reality?
Answer: No, you cannot bill for a patient who is not in the residence receiving services. You should have an internal policy describing how you manage discharges after a patient leaves the residence over 24 hours, or a policy on "holds" for beds for patients who leave to address medical services, legal issues, etc. However, these policies are clinical best practices, and should be separate from billing practices.
Question: We're leaning towards billing physical exams as individual sessions. We are also contacting external medical programs (i.e. Mt Sinai or Mercy Hospital) to provide services on site for our patients under their billing structure, under the direction of our medical director. We haven't made much progress in that area, although we just started. Am I correct assuming that Caritas will also be unable to bill for MCO/Medicaid patients?
Answer: You cannot bill physical exams to DHS SUPR. Billing them as individual sessions is improper billing and must be avoided. These medical services need to be provided by the individuals primary care physician and billed via the individual's medical coverage.
Payment for onsite /external medical services is between the provider and the medical resource as to how it will be paid for, DHS SUPR does not pay for medical services beyond what is in the contract and policy manual currently.
Caritas will be limited to the same billing requirements as all DHS SUPR providers. They may only bill for DHS SUPR Medicaid eligible services to and MCO with whom they have a contractual agreement with. Medical services, such as physicals, are not a DHS SUPR billable service.
Question: What are the DHS SUPR contract exhibits and requirements for toxicology?
Answer: The toxicology requirements for DHS SUPR contracts may be found in the SFY2019 contract and policy manual, Page38/Section 6
Section 6: Service Protocols for Toxicology Testing for Recipients of Opioid Use Disorder (OUD)Treatment Services
Question: With the current Opioid epidemic, MAT services are often an integral part of treatment. The current SUPR reimbursement structure does not readily appear to include a mechanism for reimbursing MAT Providers, other than reimbursement for Methadone Service Providers. How can SUD Providers who provider Vivitrol or Buprenorphine be reimbursed for Medication monitoring services? Is SUPR considering a reimbursement rate for Vivitrol and Buprenorphine Medication monitoring, similar to reimbursement rate for Methadone Service Providers.
A large number of individuals seeking SUD services are diagnosed with co-occurring disorders; in order to effectively treat these clients, it is necessary to treat the co-occurring disorders. The additional services of licensed professionals are often required to address the needs of our clients. Has SUPR considered separate OP individual and group rates for co-occurring disorders? Has SUPR considered a mechanism for reimbursing residential providers for the additional psychiatric and psychological services rendered such individuals?
Answer: Not at this time, we will not elaborate on these two questions given that they are not related to CURRENT ADMINISTRATIVE RULES, POLICIES, AND CONTRACT REQUIREMENTS.
Question: From the contractual policy manual, it states the following: "funds contained in DASA contracts are expected to be used for covered services for income eligible patients when all other applicable entitlement or third-party payment has been depleted. When this occurs, funds can be used as follows. Can you please give examples of each, numbers 1,2, and 3?
1. For services for any patient who has exhausted or not yet purchased third party insurance
coverage OR for any annual insurance deductible.
Answer: The client does not have a 3rd party insurance and is income eligible - the insurance company annual limit for services paid has been exhausted
2. For the amount of any applicable Medicaid spend-down and/or for DASA covered services
that are not Medicaid reimbursable.
Answer: The client has a spend down and is billed for the service, but is unable to pay, and is
Income eligible
3. For any patient covered by Medicare who receives services from a DASA licensed
organization that is not enrolled as a Medicare provider.
Answer: Medicare does not pay for addiction treatment services from an SUD treatment provider, therefore this is treated as having no insurance. The client must still be income eligible
Question: How would a DASA licensed facility get a Medicaid covered service occurring on site paid for? (We have a women's only level 3.5 care that completes pap smears on-site, as it is part of providing women specific treatment and vital to this high-risk population. The very nature of clients being in this level of care is that it is not safe for them to leave on pass to an outside facility to have this completed if they could control their impulses to use they would not need inpatient. We are really trying to provide best practices, integrated care and wrap around services as the literature suggests and receiving payment would guarantee it's sustainability).
Answer: You cannot bill pap smears or any medical services to DHS SUPR. Billing them to the SUPR contract is improper billing and must be avoided. These medical services need to be provided by the individuals primary care physician and billed via the individual's medical coverage.
Also, Payment for onsite /external medical services is between the provider and the medical resource as to how it will be paid for, DHS SUPR does not pay for medical services beyond what is in the contract and policy manual currently.
Question: What are the OMT-Residential Health requirements?
Answer: It would be the same as for any other DSUPR-licensed Residential program with the addition of the OMT's requirements for Physical Examinations, laboratory tests, and toxicology tests required by CSAT under CFR 42 Part 8'.
Question: I have a few questions and am in need of direction. Our agency has been asked to assist with Substance Abuse counseling for the Drug Court as they are temporarily without a counselor. I usually assess and give a recommended number of hours or sessions (Or if they are a DUI they come with their evaluation.) The drug court is more based on completion of goals. They have 5 phases with Phase I lasting approximately 2 months, Phase 2 approximately 4 months, Phase 3 approximately 6 months, Phase 4 approximately 6 months and their Phase 5 is after care that last approximately 6 months. I will have people coming in at different phases who are being seen weekly for MRT groups through Drug Court and have been meeting with the counselor 1, 2, or 3 times a month. Will it be acceptable to put them down for a period of time rather than a set number of hours? For Level 1 (which we are licensed for) individual are supposed to be seen a minimum of once weekly, so if I am not doing the groups, this will not take place. I am not certain how to address this in the treatment plan since most are coming mid-treatment.
Answer: Fixed lengths of stay are discouraged. When the patient meets criteria for an ASAM Level of care, and is diagnosed with a SUD, you work with the patient to determine what are the best interventions, (group or individuals, or a combination of both), and more importantly what are the individual treatment goals the patients wants and can work on.
Court mandated treatment must be provided following the agency's policy and procedure. The policy and procedure must be reviewed and approved by the medical director. Keep in mind that court mandated means that the patient is court mandated, not the provider. You must still follow 2060, ASAM and DSM-5 rules and criteria. Program focused services are not in compliance with SUD Tx. Best practices, ASAM or 2060.
Question: For the 1115 Waiver that deals with the IMD pilot can you clarify the following: Will only existing IMDs be allowed to participate?
Answer: We are going to start with existing IMD and exciting bed capacity. Once we have stablished some numbers we will reexamine.
Question: Under the new Integrated Health Homes (IHH), we have been told by DHS/DMH that we will not be able to bill case management for clients who are enrolled in an Integrated Health Home, regardless of who the IHH provider is. Will a patient's status in an integrated health home affect our ability to bill case management through SUPR?
Answer: No, it will not. The prohibition by DHS/DMH only pertains to Targeted Case Management billed to Medicaid by Community Mental Health Centers for persons with mental health disorders. However, you must ensure that there is no duplication of case management service billing between SUPR and DMH .
Question: What is the process to get additional locations added as SUPR designated providers? We want to add several of our FQHC sites, so we can expand our MAT services, we will get a new NPI for each new SUPR site.
Answer: Submit a complete application for intervention/treatment license and/or Medicaid certification for each location you wish to add. The license fee is per-site and must be in separate checks. Application requirements and forms can be located at: https://www.dhs.state.il.us/page.aspx?item=68564
Regarding the NPI number, FQHCs only need one NPI number for all services at all their sites. Any need for additional clarification should be directed to Jayne.Antonacci@illinois.gov.
Question: Regarding medical services provided at a SUPR location, is there a COS we need to add to get these paid? If so, what is it? We are not getting paid by the MCO's for these services. Example: at our Women's Residential Services site, we have one of our FQHC medical providers come on-site to perform a variety of medical services i.e. if client is sick and needs exam/meds, STI testing and treatment, Hep testing. MCO's are not paying for the above professional fee's
Answer: Medical services are not a DHS SUPR billable service. You must seek other funding for medical services, send to an FQHC, or utilize other medical resources.
Question: What is considered the "Admission Date"? According to 2060.417, an assessment shall be conducted prior to admission to any level of care. The assessment of the severity of the six dimensions established in the ASAM Patient Placement Criteria determine what level of care they will be admitted to. We can't always get that completed on the first appointment date. I would interpret that as the date the client is admitted to care would be the date the assessment is completed with the recommended level of care and diagnosis if applicable.
Answer: The admission date is the date of the first treatment service (individual or group counseling). The Assessment is not treatment.
Question: Can we document in a treatment file if a client reports their reason for being here as "I got a DUI and have to do hours"? We make it very clear to our clients that treatment is not focused on hours or their DUI charge and that treatment is focused on them meeting treatment goals. I still think it is relevant to report the client's stated reason for coming to treatment.
Answer: It is relevant to document the reason for a referral which in this case would be the DUI. However, a treatment plan is based on the patient assessment and medical necessity for treatment. The DUI is a consequence of the substance use disorder. Simply stating that the problem area in a treatment plan is the DUI and required treatment hours does not support medical necessity.
Question: If a client has an assessment but doesn't follow through with services and is closed, then returns for services, can the previous assessment and intake paperwork be used? Can we review the information to be sure it is still accurate and sign and date with current return date or do we need to start over with all the paperwork and assessment?
Answer: You must follow your medical director and/or agencies' board approved written policy for reassessments (return to treatment policy), follow ASAM and use clinical judgement to readmit the patient.
Question: We are still having problems receiving RIN numbers in a timely manner causing claims to be delayed in submission and in many times denied for timely filing. How can we obtain numbers more quickly?
Answer: We have reached out to DHS/DFCS and we are waiting for a response regarding the delay in e-rin numbers.
Question: We also see many undocumented clients and the e-rin staff are asking for SSN numbers which just do not exist, how do we move forward, especially when they are common names like Juan Rodriguez (fake client, common names)
Answer: For individuals who do not have an assigned SSN you will use all zeros.
Question: Does documentation such as releases of information and consent to treatment need to have a CADC signing as witness?
Answer: No. However, for any legal document such as the patients' rights, or consent to treatment, the witness must understand and must be able to explain the content and intent of each form.
Question: If a patient is admitted and is schedule for a physical in 4-5 days, but leaves AMA, how do we document?
Answer: The provider should explain any delays with getting the physical due to the MCO or efforts made to get the physical within allotted time frame; documentation should be noted in the file.
Question: Medicaid Certified provider: Are inspections still conducted every 3 years?
Answer: Yes, SUPR is behind due to staffing. We are in the process of scheduling site visits.
Question: Confusion about the injection - how does the nurse bill for someone on Injectable Naltrexone?
Answer: This service cannot be bill to IDHS/SUPR.
Question: Is there a list that is on the website in provider county area that has the file location of providers who are no longer in business/licensed? It is a struggle trying to correlate information or verifying what clients may or may not have done when they don't have documents anymore and we cannot locate the provider records, that should be designated to another provider according to 2060 (I have files from a provider who retired in 2010).
Answer: If the provider has closed, you can contact IDHS/SUPR's licensing department to inquire about the provider's licensing status and/or where the files are being stored. Please keep in mind that after 5 years this information may not be available.
Question: If a provider is interested in applying to be a Medicaid provider, is there a contact person who can go over the Medicaid process prior to making a decision on applying (additional documents/billing/reimbursement) so we can have a better understanding prior to blindly applying/paying application fees?
Answer: Send Medicaid questions to our Help-Line: DoItSUPRHelp@illinois.gov, or call Jayne Antonacci (217) 785-7754.
Question: Section 2060.413 Medical Services under Medical Director it says, "Any organization providing treatment services shall designate a medical director, who is licensed and in good standing to practice medicine in all its branches in Illinois, who shall oversee all medical procedures". Does this doctor have to be a family practice or general practitioner? Not clear on what it means "to practice medicine in all its branches".
Answer: This is language directly from the medical practice act. Anyone licensed as a medical physician under that act would qualify as a Medical Director under our license. It can be a psychiatrist.
Question: Now that the state of Illinois is implementing the IM+CANS for behavioral health clients for Assessments and treatment plans; As a MISA administrator, I need to know when my MISA clients charts are reviewed by SURP will they be looking for a substance abuse assessment, mental health assessment, a treatment plan, LOCUS Notes assessment as completed in the past or just the IM+CAMS Assessment as required by the state?
Answer: IM+CANS is not required for use by any SUPR licensed provider for SUD treatment. As always, all documentation should follow current 2060 rules.
Question: Currently we provide Mantoux TB screening and testing through a skin test. The 2060 states at a minimum a PPD test must be performed; my question is would it be acceptable to use a blood test instead of a skin test. This is for residential patient who already receive a blood draw.
Answer: Yes, you can use a blood test to comply with the TB skins test requirements.
