6 OPTIONS: 1. Develop a statewide, statistically valid CMS-approved random moment time study, per OMB Circular A-87 cost allocation principles.
2. When the number of participating claiming entities is small, develop a non-statewide CMS-approved time study that is statistically valid when the results from the individual claiming entities are aggregated, with FFP distributed in a way that each claiming entity’s costs are fully recognized.
3. Select 5 random days per Tribal staff person with each day considered as the observation unit, and total observations will vary depending on number of Tribal staff. The resulting estimates of reimbursable time would likely reach the desired level of statistical precision of all Tribes, except those with small staff sizes. A somewhat larger number of randomly selected days would be required for the small Tribes.
4. Select one random week for all Tribal staff with each week considered as the observation unit. The total number of observations will equal the total number of staff persons participating in the time study in a given Tribe. The random week sampling method will likely fail to produce statistically reliable estimates of reimbursable activity for most Tribes. This method, however, may provide statistically reliable estimates if the data from a number of Tribes is combined.
5. Develop an administrative fee for Tribes providing Medicaid Administrative Services to Medicaid beneficiaries in lieu of an ongoing time study.
6. In lieu of time studies altogether, and when underlying costs are nominal and do not exceed a CMS- determined threshold of significance, execute a legal contract directly with the claiming entities that does not involve application of a proportion Medicaid eligibility ratio.
WE CHOSE OPTION #6 There are 18 Tribal Health Programs sub- contracting with CRIHB; CRIHB is the sole contractor with the State. The 18 Tribal Health Programs represent 51 Federally Recognized Tribes. Our Tribes and THP’s are small and this option works best for us.
C ALIFORNIA T RIBAL MAA TMAA Specific Activities Initial Medi-Cal Outreach Facilitating Medi-Cal Application Ongoing Referral Interpreter Services Program Planning & Policy Development Coordination & Claims Administration Transportation Medi-Cal Non- Emergency, Non- Medical Transportation. The actual cost of providing transportation Staff costs (salary & benefits)
TMAA TRANSPORTATION We document 100% time and actual Medi-Cal mileage to be reimbursed to the THP. The supporting documentation is the transporters time card and mileage/time log. CRIHB invoices the State for each THP separately on a quarterly basis. The turn around time is usually 5-6 weeks.
TMAA SPECIFIC ACTIVITIES The THP staff document 100 percent of their time. The actual percentage of time is applied to the staff salary and benefits. CRIHB invoices the State for each THP on a quarterly basis on a single invoice combined with the transportation per program. The supporting documentation is the THP staff time card and the time log.
BENEFITS – ECONOMIES OF SCALE CRIHB is the sole state contractor & the TMAA Coordinator is a CRIHB staff The 18 THP’s are sub-contractors CRIHB maintains the Audit Files for all participating THPs The State trains the CRIHB TMAA Coordinator and the TMAA Coordinator trains the participating THP staff. The State monitors the all aspects of the program.
SUCCESSFUL IMPLEMENTATION 18 of the 24 THP are participating in the TMAA program. The last 3 years has brought new funds into California for the THPs / approximate $1 million.