1. Federal Financial Participation (FFP)
Comprehensive Perinatal Services Program (CPSP) Annual Meeting
November 7, 2012
Jonathan Alspektor, BSBA
State of California
Contract Manager

2. Objectives for this Presentation
FFP Definition and Objectives
FFP Requirements
FFP Reimbursement
FFP Decision Tree
FFP Secondary Documentation

3. What is FFP?
Federal Financial Participation (FFP) is a Title XIX (Medicaid) program that allows states to receive partial reimbursement for activities that meet FFP objectives.

4. What is FFP? FFP has two programs: 1.) Targeted Case Management – TCM
2.) Medi-Cal Administrative Activities – MAA
MAA FFP reimburses for activities that primarily involve linking clients to Medi-Cal services and/or coverage.
MCAH FFP is a MAA program.
Federal Financial Participation has two programs: Targeted Case Management and Medi-Cal Administrative Activities or MAA. MAA FFP reimburses for activities that primarily involve linking clients to Medi-Cal services and/or coverage. MCAH FFP is a MAA program.

5. FFP Requirements Qualified Perinatal Services Coordinator (PSC) must:
Be a Skilled Professional Medical Personnel (SPMP) and must meet Federal SPMP requirements not State or County.
Complete SPMP Questionnaire
Complete activities that meet at least one of the two FFP Objectives .
The MCAH program and staff must meet all FFP requirements to be reimbursed with Title XIX funds.
The local program must use qualifying non-federal funds (i.e. local county/city/state funds) to draw down Title XIX matching/reimbursement.

6. FFP Requirements Qualified Perinatal Services Coordinator (PSC) must:
Time Study
Adhere to current MCAH Policy & Procedure position requirements
The MCAH program and staff must meet all FFP requirements to be reimbursed with Title XIX funds.
The local program must use qualifying non-federal funds (i.e. local county/city/state funds) to draw down Title XIX matching/reimbursement.

7. FFP Personnel There are two FFP personnel classifications:
1.) Skilled Professional Medical Personnel (SPMP)
Education and training at the professional level
Nurses, physicians, Registered Dieticians, etc.
2.) Non-Skilled Professional Medical Personnel (Non-SPMP)
All other personnel

8. Double-click on image to show full screen example
SPMP Requirements
All SPMPs must complete the SPMP Questionnaire
Determines SPMP or Non-SPMP
Complete once and keep on file for audit purposes.
Agency must retain the SPMP questionnaire onsite for audit purposes for at least three years from the close of the Fiscal year.
Double-click on image to show full screen example

9. FFP Objectives
1.) To assist individuals eligible for Medi-Cal to enroll in the Medi-Cal program
and/or
2.) To assist individuals on Medi-Cal to access Medi-Cal providers, care and services.
The two main FFP objectives are to assist individuals eligible for Medi-Cal to enroll in the Medi-Cal program and/or to assist individuals on Medi-Cal to access Medi-Cal providers, care and services.

10. Double-click image to show full screen example
FFP Time Study
Staff claiming FFP reimbursement must keep record of 100% of their time and activities for all programs (including non-MCAH programs) for a minimum of one month each quarter.
The “start and stop” time of all activities are required on each time study at a maximum of 30 minute increments.
Activities can be tracked in 15 minute increments, if needed, to claim multiple function codes.
Double-click image to show full screen example

11. FFP Reimbursement 50/50 Non-Enhanced Matching (Non-SPMP)
$1 spent = .50 cents reimbursed
75/25 Enhanced Matching (SPMP)
$1 spent = .75 cents reimbursed
The Centers for Medicaid and Medicare Services (CMS) regulations allow matching or reimbursement for administrative activities at a Non-Enhanced rate (50/50) for the majority of expenses necessary for the proper and efficient administration of the Medi-Cal program.
CMS also allows matching at an Enhanced rate (75/25) for certain activities performed by Skilled Professional Medical Personnel (SPMP) with specified education and/or training, and their direct clerical support. In other words, for every dollar that is spent performing Non-SPMP activities (Non-Enhanced) the Feds will reimburse 50 cents. For every dollar spent performing SPMP activities (Enhanced) the Feds will reimburse 75 cents.

12. FFP Reimbursement
Medi-Cal Factor (MCF%)- Medi-Cal paid births as a percentage of live births in each county.
Comprehensive Perinatal Services Program (CPSP) is a Medi-Cal program serving only Medi- Cal providers and clients.
PSCs can claim up to 95% of their matchable activities.
Medi-Cal Factor = Medi-Cal Paid births as a percentage of live births in the CA Birth Statistical Master File (BSMF)
Because the Comprehensive Perinatal Services Program is a Medi-Cal program serving only Medi-Cal providers and clients PSCs can claim up to 95% of their matchable activities.

13. Double-click image to show full screen example
FFP Decision Tree
Determines if an activity can be matched
Determines the codes than can be claimed for an activity
The FFP Decision Tree is a tool that was developed to help you in two primary ways: First and foremost, it will help you to determine if an activity can be matched. Secondly, it will determine the possible codes that can be claimed for an activity. Let’s take a quick look at it…….
Double-click image to show full screen example

14. SPMP FFP Codes Enhanced (75/25 Matching)
2: Administrative Medical Case Management
(Short Term Only)
3: SPMP Intra/Interagency Coordination, Collaboration and Administration
6: SPMP Training
8: Program Planning and Policy Development
9: Quality Management
There are three types of codes, SPMP, Non-SPMP, and Other. SPMP (Enhanceable) codes are 2, 3, 6, 8, and 9.

15. Non-SPMP FFP Codes Non-Enhanced (50/50 Matching) 1: Outreach
4: Intra/Interagency Collaboration and Coordination
5: Program Specific Administration
7: Non-SPMP Training
Non-SPMP codes can be used by all staff included 1, 4, 5, 7.

16. Other FFP Codes 10: Non-Program Specific General Administration
11: Other MCAH Scope of Work Activities that are not matched
12: Paid Time Off
Other FFP codes include 10, 11, and 12. Code 11 should be used for unmatchable MCAH Scope of Work activities.

17. Function code examples
Outreach
Examples:
Informing potential client about the services offered by a CPSP provider
Describing range of services, how to access them, and the benefits of preventative health care.
Due to time restraints we will not be going into detail about each function code; however, we have provided several real world examples for each one.
Outreach can be preformed for a group or an individual. Outreach is when you are doing a presentation about CPSP to a group of providers or individuals that might benefit from the program.
Some examples include…

18. Function code examples
FUNCTION CODE 2 (SPMP)
SPMP Administration Medical Case Management
Examples:
Consulting with a Medi-Cal provider in regards to the client’s or the infant’s health needs.
Assisting Medi-Cal client in contacting their physician for clarification on a specific medical condition such as gestational diabetes and its effect on her pregnancy.
SPMP Administrative Medical Case Management. Activities must meet the two (2) FFP objectives. If not, they are non-matchable or exceptions, Function Code 11.
Some examples include…

19. Function code examples
FUNCTION CODE 3 (SPMP)
SPMP Intra/Interagency Coordination, Collaboration, & Administration
Examples:
Meeting with Dental providers to develop strategies to increase access to dental services for pregnant women.
Community Action and Planning strategy meetings
Function Code 3 – SPMP Intra/Inter Agency Coordination , Collaboration, and Administration is defined as activities that involve planning and resource development with other agencies to increase cost effectiveness and improve availability of medical services. MUST BE SPMP.
Some examples include…

20. Function code examples
Non-SPMP Intra/Interagency Collaboration and Coordination
Examples:
PSC provides assistance to a CPSP Provider with a technical question related to the program i.e. Billing for services to Medi-Cal.
Function Code 3 – Non-SPMP Intra/Inter Agency Coordination , Collaboration, and Administration is defined as activities that involve planning and resource development with other agencies to increase cost effectiveness and improve availability of medical services. NON-SPMP STAFF ONLY
One example is when a ……

21. Function code examples
Program Specific Administration
Examples:
Reviewing reports, documents, and/or legislation for potential impacts to the CPSP programs.
Coordinate logistics for outreach services from various programs to prevent duplication of services and encourage optimal use of resources for Medi-Cal clients.
Function Code 5 – Program Specific Administration is defined as the general activities that support meeting the two FFP objectives.
Some examples include…

22. Function code examples
FUNCTION CODE 6 (SPMP)
SPMP Training
Examples:
Develop, conduct, or participate in training for CPSP physicians, nurse practitioners, and office nurses to increase access to Medi-Cal services.
Using skilled medical expertise to deliver professional training to health care providers that will improve quality of care.
Function Code 6 – SPMP Training is very limited and restricted. It does not include all SPMP training. Remember, this training again must support your ability to meet the two FFP objectives especially at your level as a SPMP.
Some examples include…

23. Function code examples
NON-SPMP Training
Examples:
Participate in training on data sources, data management and preparation for analysis to improve access to care for Medi-Cal clients.
Attending an FFP training
Function Code 7 – Non-SPMP Training is training for staff and program participants concerning the FFP objectives. May be provided by a SPMP or Non-SPMP.
Some examples include…

24. Function code examples
FUNCTION CODE 8 (SPMP)
SPMP Program Planning and Policy Development
Examples:
Identify, recruit, and provide program support for new providers to expand access for CPSP clients.
Assisting providers with CPSP clinical requirements and implementation.
Function Code 8 SPMP Program Planning and Policy is developing strategies to increase Medi-Cal system capacity, providers, care, and services for targeted or Medi-Cal specific populations.
Some examples include…

25. Function code examples
FUNCTION CODE 9 (SPMP)
Quality Management by Skilled Professional Medical Personnel
Examples:
Developing training materials for CPSP providers for quality assurance monitoring.
Reviewing CPSP provider arrangements to assure continuous provision of required consultant services.
Function Code 9 – Quality Management is quality assurance concerning matchable activities and activities that provide direction and oversight in how staff activities are meeting the two FFP Objectives.
Some examples include…

26. Function code examples
Non-Program Specific General Administration
Examples:
Agency related activities, such as, fire drills.
Staff attend agency meetings and non-program related trainings such as HIPAA, Safety Training, Sexual Harassment.
Function Code 10 – Non-program Specific General Administration is mandated or required activities, training and/or meetings not about the program but rather by your employer.
Some examples include…

27. Function code examples
Other Activities (Included in MCAH SOW)
Examples:
Attending Child Abuse Prevention Council meetings.
Smoking cessation training.
Remember, if the activity you are doing does not meet the two FFP objectives then it must be an exception. MCAH may require many activities that are not FFP matchable but are still MCAH claimable.
Some examples include…

28. Function code examples
FUNCTION CODE 12 Paid Time Off Examples: Paid time off for a Holiday, sick leave, vacation, or jury duty
Function Code 12 Paid Time OFF. This includes any paid time off such as holidays, vacations, sick leave, jury duty, and so on. This does NOT include Compensatory Time Off or Flex Time.

29. Federal Financial Participation (FFP) Secondary Documentation
Purpose:
The information and data that substantiates and supports reimbursable activities claimed on the Time Study.
Ensures Program Integrity
Informs Auditor
Secondary documentation is the information that substantiates and supports reimbursable activities and time claimed on the Time Study:
It should provide enough detail to support the chosen Function Code and the time study
Is used by an auditor to evaluate the appropriateness of reimbursement for FFP
Secondary documentation also helps to ensure program integrity by:
Assisting a supervisor in monitoring staff activities and accuracy of time studies
Brings FFP training needs to the attention of a supervisor

30. Federal Financial Participation (FFP) Secondary Documentation
Documentation Requirements:
Requirement of All FFP Staff
Evidence of FFP Activities Performed
Provides Audit Trail
Accessible and Available
Records Must Be Retained
Secondary documentation is required for all staff on the MCAH budget that claim Title XIX or FFP
Secondary documentation supports and substantiates the claiming of FFP matchable funding
Auditors use secondary documentation to evaluate whether activities preformed are eligible for FFP and are appropriately matched and claimed
Secondary documentation must be readily available and accessible in the event of an audit
Secondary documentation must be retained like any other agency records as they are legal documents. All agency records are subject to inspection, audit and/or on-site review and reproduction.

31. Federal Financial Participation (FFP) Secondary Documentation
Example – SPMP Program Planning And Policy Development – Function Code 8
Good
5/21/09 from 12:00-2:00 (when) – Attended the South Bay Prenatal Access Task Group meeting (where). The membership, doctors and nurses (who), discussed and made plans (what) to increase access to prenatal care clinics (why).
Other relevant details might include the meeting agenda and participant list
Poor
Met with the South Bay Prenatal Access Task Group about access to prenatal care clinics
To be able to use an SPMP Function Code:
The activity description needs to be clearly stated as if the person is defending it to an auditor
SPMP activity descriptions need to include clinical wording and/or details of why only a skilled professional medical personnel can perform that activity
You might want to include a statement in your secondary documentation of SPMP activities of why a non-SPMP could not perform the activity

32. Federal Financial Participation (FFP) Secondary Documentation
Supporting Documents:
Job specifications
Duty statements
Organizational chart
Scope of Work
Current Organizational charts, job specifications and duty statements for personnel identified on the MCAH program related budgets serve as supporting documentation for the percent of time assigned to program activities and the level of FFP match.
Job classifications describe education and experience required for SPMP positions.
Duty statements should reflect the activities and responsibilities of the position.
Duty statements for Skilled Professional Medical Personnel (SPMP) should reflect the specific skills and knowledge associated with the individual’s qualifications.
There are more detailed instructions on the components of duty statements and organizational charts in the MCAH Policy and Procedure Manual.
Organizational charts illustrate the interrelationship of personnel within MCAH programs and the agency.
The Scope of Work also serves as a supporting document because it defines goals, activities, timelines and methods of evaluation.

33. Federal Financial Participation (FFP) Secondary Documentation
Guidelines and Suggestions:
No standardized form but must provide evidence
Notes should be detailed and specific
Attach other types of documentation, such as, agendas, day planner, flyers, client notes, etc.
There are no standardized forms for secondary documentation but the secondary documentation must provide evidence that the activity performed qualifies for reimbursement under FFP; therefore:
Notes should be specific and detailed
Is required for all function codes
Written records should distinguish different activities and programs
Time should be continuous in 30” increments
Provide start and stop times for all activities
Other types of supporting documentation which should be included with secondary documentation are: agendas, minutes, participant list, event flyers, day planner, client notes, etc.
It is recommended that all secondary documentation is kept together and sent to the LHJ fiscal office along with time studies and time study cards to be audit ready. This way, during an audit, you will not have to research or reconstruct documentation.

34. Federal Financial Participation (FFP) Secondary Documentation
Secondary Documentation can be anything an agency chooses, but it should include the following elements:
Date
Time Spent
Activity
Program

35. Federal Financial Participation (FFP) Secondary Documentation
Secondary Documentation can be anything an agency chooses, but it should include the following elements:
Identify the client/Program/Event for which the activity was performed
Function Code

36. Federal Financial Participation (FFP) Secondary Documentation
REMEMBER
Secondary documentation must support time study
If not supported, FFP activities cannot be reimbursed
In summary:
It is important to keep all secondary documentation with the time study and time card in a separate file.
Remember, your secondary documentation supports and substantiates your time study. If your description is not complete or accurately describe the activity performed you may not:
Be able to remember what the activity and situation was to defend your function code decision to an auditor
Therefore; the activity may not be reimbursable and your agency may have to repay funds

37. resources MCAH Business Partners
Please visit our MCAH website for additional information. Please also refer to the Fiscal Policies and Procedure manual for more detailed information on FFP requirements.

38. Questions?