Issue 3 - the Montana Secretary of State Website

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RESPONSE #5: The department acknowledges that these rules may affect a
recipient's choice of who provides activities of daily living and other direct services,
but the amount and quality of services should not change.
COMMENT #6: Transportation and daily living assistance should remain a part of
case management services.
RESPONSE #6: Federal regulations clearly permit transportation and assistance
with activities of daily living to be billed as CBPRS activities.
COMMENT #7: We are concerned that the reimbursement rate for CBPRS is not
adequate.
RESPONSE #7: The department acknowledges the commentor's concerns.
However, reimbursement rates are outside the scope of the proposed amendments.
COMMENT #8: Do the proposed changes prohibit billing CBPRS for transportation,
education, training, and the other services mentioned
RESPONSE #8: No. Please see ARM 37.88.901(5). Community-based psychiatric
rehabilitation and support services are provided on a face-to-face basis with the
recipient, family members, teachers, employers, or other key individuals in the
recipient's life when such contacts are clearly necessary to meet goals established in
the recipient's individual treatment plan.
COMMENT #9: Why did the department choose to use the 15 minute billing
increment when the Centers for Medicare and Medicaid Services (CMS) have
withdrawn regulations requiring its use
RESPONSE #9: The use of a 15 minute unit for case management is not a change
in Montana. The department agrees that the detailed delineation of time proposed in
ARM 37.86.3515(b) is unnecessary and this language has been deleted. The
department will continue to require that all Montana Medicaid targeted case
management providers bill in 15 minute increments.
COMMENT #10: We recommend the entire section of ARM 37.86.3515 pertaining
to reimbursement be deleted.
RESPONSE #10: The department agrees and has deleted ARM 37.86.3515(c), (d),
and (e) from the final rule.
COMMENT #11: It is not practical to require that each recipient have only one case
manager. Services are sometimes necessary when a case manager is away for
training, sick leave, or vacation. Another case manager should be permitted to
provide services temporarily.
Montana Administrative Register 3-2/11/10