Provider Notice issued 11/26/07

Clarification of Code Definitions in the School Based Health Services Claiming Guide

This notice is intended to provide additional guidance and clarification of the activity code definitions delineated in the Department's "Illinois Guide for School-Based Health Services Administrative Claiming (Guide)."  The Department has been conducting on-site monitoring activities throughout the State.  This monitoring not only has resulted in a number of corrective actions in many LEAs, but also disclosed the existence of a general statewide misunderstanding and misinterpretation of the activity code definitions. 

The Department recognizes that school administrators and support staff often perform multiple roles that might include activities in support of the Medicaid program.  These activities may include outreach activities to inform and identify those in need of medical services and supportive case management activities for Medicaid enrolled students.  These activities must be clearly separable from educational activities. 

To assure the accuracy of subsequent claims, the LEA should implement measures to ensure that all employees who participate in a time study have a thorough understanding of the activity code definitions and how they relate to their daily responsibilities.  Regardless of any training staff may have received, an LEA is ultimately responsible for its administrative claim and therefore must ensure that the time study training its employees receive from non-department personnel, is consistent with the guide.  As a general guide in determining how to report time, employees should ask themselves, "What am I doing for this child and why?"  If the answer is educational in nature, then I3 should be used.  If it is medical in nature and relates to a service supported by Medicaid/All Kids program, then code E or F should be used.

LEAs should review the training programs to ensure that the program is complete and clearly differentiates between activities in support of medical case management and educational related case management.  In particular, LEAs should ensure the training provides a clear message that time attributable to an educational, educationally related or school related program must be coded to Code I3, Educationally Related Activity, not General Administration, Code G1. 

In most cases, salary and benefit costs associated with employees that do not complete time studies must not be included in the total expenditures amount for their respective employee category.  The only exception to this requirement is in the case of an LEA that has developed a formal sampling process consistent with Section 430 of the Illinois Guide for School-Based Health Services Administrative Claiming.  Prior to implementation of any such sampling, the LEA must receive formal approval from the Department.

Claimed expenditures must be incurred by the entity claiming them.  The guide and the intergovernmental agreement LEAs enter into with HFS are clear in that an LEA may only submit a claim for reimbursement of Medicaid administrative expenditures the individual LEA has incurred.  Neither the guide nor the intergovernmental agreement has a provision that permits claiming of expenditures incurred by another entity.

The full documents referenced in this notice can be downloaded from the Department's Web site at:

https://www.illinois.gov/hfs/MedicalPrograms/sbhs/Pages/default.aspx

In addition, school districts may request training directly from the Department. 

Attached is an outline of the activity codes used in time studies.  The full document is available on the Web site described above.  This outline emphasizes many of the coding errors that have been identified through site visits and should be used by time study staff to assure correct time study coding.

Questions regarding this notice should be directed to Marie VonDeBur at 1-217-782-3953.

Theresa A. Eagleson, Administrator

Division of Medical Programs

Reference Guide for Completing Time Studies, Participating in a

Time Study and Reporting Financial Informaton

Time Study Activity Codes

Codes A, B, and C

Codes A, B and C are for activities performed to inform and identify those in need of medical services and who would benefit from the Department’s Medical Assistance program. 

• Such activities inform children and their families about the availability and accessibility to medical services and assist families with the application process for those services. 

• The numeric designators utilized with these codes are intended to allow the employee to differentiate between activities when the employee is assisting with:

-     Medicaid/All Kids related medical programs (A1, B1, C1)
-     Non-Medicaid/All Kids related programs (A3, B3, C3)

Code D

Code D should be used only when the employee is outreaching to and networking with the medical provider community to assure that services are available when children are identified with special medical needs. 

• The purpose of theses activities must be to increase either the number or capacity of the Medicaid/All Kids providers. 
• Speaking with an individual medical provider to obtain services for specific children would be more appropriately coded under the case management codes (E, F).

Codes E and F

Codes E and F should be used only when an employee performs activities that actively support meeting an identified medical need of a student.

• Staff completing time studies must differentiate between activities related to providing medical case management on behalf of a student and activities that support the educational case management function. 
• Activities related to managing the educational component of a student’s IEP or classroom teaching of students with an identified medical need is not medical case management.  These activities should be more appropriately coded to E3 or I3, Educationally related activity. 

Code G

Code G1 should be used rarely and only when a given activity cannot be specifically attributed to either the school-based health services program or the educational and/or school-related program of the LEA. 

• Paid benefit time such as lunch or leave time
• General meetings such as board meetings or general staff meetings
• District wide activities

Staff meetings that discuss classroom issues, discipline, or other educational issues should be coded as I3. 

Clerical activities in support of educational and school-related activities, including copying and answering phones, should be coded as I3.

Code H

These codes are to be used for daily direct service activities. 

• Practitioners use the H3a and H3b codes when:

-      Providing care or treatment
-      Screenings
-      Evaluation of a child and related paperwork

Code I

School personnel must use Code I3 when performing their usual educational activities.  This includes:

• Instruction
• Discipline
• General supervision of students
• Any duties in support of the academic function
• Staff meetings that discuss classroom issues, discipline, or other educational issues 
• Clerical activities in support of educational and school-related activities, including copying and answering phones 

Code I3 must be used when performing medical case management activities that overlap with educational activities.

Time Study Participants 

LEAs should ensure that only appropriate personnel are included in time studies.  Section 410 of the guide provides a listing of personnel who could potentially perform administrative activities.  LEA personnel who perform only educational activities should not be time studied.  Classroom aides, as an example, typically perform only educational and classroom activities.  However, if the aide is a School Health Aide, then their time spent in providing health aide service may be reimbursable on a fee-for-service basis.  Chapter U-200 provides assistance with fee-for-service billing.

Financial Issues  

LEAs should only submit documented expenditures on the administrative claim.  The expenditures must be submitted for the quarter in which they were actually incurred.  LEAs cannot use budget amounts as a basis for determining costs.  LEAs should ensure that their claim only includes allowable expenses.  Refer to the Informational Notice, dated September 8, 2003, for examples of allowable insurance, interest, dues and fees and rental expenditures.  For allowable materials ands supplies expenditures, please refer to Office of Management and Budget (OMB) Circular A-87, Section 26.