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ATTENTION ICFs AND DAY PROGRAMS: IT AIN’T OVER TILL….

Ever feel like you’re running in a circle? Well you must if you’ve been around for a while. For years the day program that provided services to people who live in an ICF would bill for “day services” (could not be called day hab since that is a Waiver service) via voucher. Then at some point OPWDD Central Office staff would total all the units of day services delivered to people in the ICF, translate that number into dollars, and add the funds to the ICF on a temporary basis, and then a year or two later take it all back. That process became too work-intensive for the Central Office staff, so then came everyone’s favorite: the day program bills directly to the ICF. Seemed to make sense, except when the ICF didn’t pay the day provider, or the day provider’s billing didn’t match the records of the ICF. Then it was back to the future, except this time the day service provider would bill directly to eMedNY just like everyone else. Great!

Then came the April 23rd email from OPWDD (click here for a copy), “CFR Reporting Changes for ICD/IID Day Service Liability”. Fortunately this is not about the exchange of dollars between the ICF and day program; rather about the exchange of data between the day program and ICF because the ICF is required now to report the amount billed for day services on its CFR line 68e. The reason for this new reporting requirement is that day services are still considered to be a “cost” of the ICF and therefore needs to be reported on the CFR of the ICF, even though the ICF provider does not receive the day service portion in its rate. However, this does require cooperation between the day providers and the ICFs for the reporting of the day service information. The CMS threat if the day programs and ICFs don’t play nice in the sand box is that CMS will return to the requirement of the day program billing the ICF.

The effective dates of the reporting are Calendar Year 2017 (less than one month to the June 1 deadline!) and Fiscal Year 2017-18 for the fiscal year filers.