Provider Notice Issued 06/06/2025

To comply with the Improper Payments Information Act of 2002, the federal Department of Health and Human Services, Centers for Medicare & Medicaid Services (CMS) has implemented a Payment Error Rate Measurement (PERM) program, which measures improper payments within each state's Medicaid Program and Children’s Health Insurance Program (CHIP). Each state is required to participate in a PERM audit every three (3) years.

This notice serves as a reminder that all services for which charges are made to the Department of Healthcare and Family Services (HFS) are subject to audit. Audits are an important and necessary part of the Department’s monitoring of health care facilities and services, as required by federal and state law.

For more information about PERM medical records reviews, please see the HFS Office of Inspector General’s (OIG) PERM website.

Audit findings against a provider will result in the recovery of associated overpayments and may also result in sanctions or other penalties, including but not limited to: (1) termination or suspension of the provider’s eligibility to participate as a Medicaid and/or CHIP provider; (2) suspension or denial of the provider’s payments; and (3) civil monetary penalties.

Reporting Year 2025 PERM Review

The PERM audit for reporting year (RY) 2025 (claims paid on/between July 1, 2023 – June 30, 2024) was conducted and resulted in the following errors being cited:

       1.      School-Based Services:  
          a.    Provider submitted a claim for a date of service when the student was not in attendance.
          b.    Provider did not retain notes for school-based services, relying on a previously contracted provider to retain them. Provider was not willing to supply necessary documentation as they are no longer under contract with the school.

      2.      Early Intervention:
         a.    Provider failed to locate records and submit them for review.

     3.      Long Term Care facilities:
         a.    Physician recertification of services was not completed, collected, or maintained by the provider.

     4.      General:
         a.    Businesses (pharmacy, long term care facility, laboratory) closed and did not respond to medical records requests.
         b.    Progress notes for home health care services were not completed or maintained.
         c.    Provider billed for units of services contrary to what was documented in medical records (one provider billed fewer units than documented, one provider billed for more units than documented).

Providers are reminded to:

·         Follow the policies and procedures issued in the general handbook for all providers, Chapter 100 – General Policy and Procedures, Topic 110 - Record Requirements, subtopics 110.1 to 110.3 - Maintenance, Retention and Availability of Records. 
·         Refer to their specific handbook in the Chapter 200 series of handbooks, as well as their applicable fee schedule, for guidance regarding needed documentation.
·         Maintain current enrollment data, including contact information. Provider change information must be updated via the online application available on the Illinois Medicaid Program Advanced Cloud Technology (IMPACT) Provider Enrollment web page. The online change function is available to notify HFS of updates or changes to enrollment information for the following categories: 

o   National Provider Identifier (NPI)
o   Provider name
o   Provider demographic (address, phone, email)
o   Payee demographic (address, phone, email)
o   Add a Pay To (payee)
o   Close a Pay To (payee)
o   Close enrollment
o   License
o   Clinical Laboratory Improvements Amendments (CLIA)

HFS generates a Provider Information Sheet when changes are made to the provider file. The Provider Information Sheet contains information used by the provider in the preparation of claims. This information is also used in the claim processing system for claim editing. Any inaccuracies must be corrected, and HFS notified immediately via IMPACT. Failure to properly update the IMPACT provider enrollment system with corrections or changes may cause an interruption in participation and payments.

Questions regarding this notice may be directed to the Bureau of Professional and Ancillary Services at 877-782-5565.

Kelly Cunningham, Administrator
Division of Medical Programs