Informational Letter No 2369 Mc Ffs Date To From

Informational letter no 2369 mc ffs date to from

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DATE: September 1, 2022
TO: All Iowa Medicaid Providers
APPLIES TO: Managed Care (MC), Fee-for-Service (FFS)
FROM: Iowa Department of Health and Human Services (HHS), Iowa Medicaid
RE: Participation in the Federal Fiscal Year (FY) 2024 Payment Error Rate
Measurement (PERM) Program
EFFECTIVE: Upon Receipt
Based on requirements of the Improper Payments Information Act (IPIA) of 2002 (amended in
2010 by the Improper Payments Elimination and Recovery Act [IPERA]), the Office of
Management and Budget (OMB) has identified Medicaid and the Children’s Health Insurance
Program (CHIP) as programs at risk for significant improper payments. As a result, the Centers
for Medicare and Medicaid Services (CMS) developed the Payment Error Rate Measurement
(PERM) program to comply with the IPIA and related guidance issued by the OMB

The PERM program measures improper payments in Medicaid and CHIP and produces error
rates for each program. The error rates are based on reviews of the FFS, MC, and eligibility
components of Medicaid and CHIP. It is important to note the error rate is not a “fraud rate”
but simply a measurement of payments made that did not meet statutory, regulatory, or
administrative requirements

Iowa Medicaid is participating in the federal FY 2024 PERM program. This means that providers
may be contacted by the CMS review contractor, NCI Information Systems, Inc. (NCI), who
will collect medical records either in hard copy or in electronic format. The medical record
request letters will be sent to Iowa Medicaid-enrolled providers at any time upon completion of
the data sampling process

Medical records are needed to support FFS Medicaid and CHIP claims to determine if the
claims were correctly paid. If a claim is selected in which a provider’s national provider
identification (NPI) number was identified on the claim to receive reimbursement, the CMS
review contractor will send a request for a copy of the required medical records to support
the medical review of the claim. Upon receipt of the request for medical records, providers
All Informational Letters are sent to the Managed Care Organizations
Iowa Medicaid – 1305 E Walnut St. – Des Moines, IA 50319
must submit the records within 75 days. Please note that it is the responsibility of the
provider who is identified to receive payment on the claim, to ensure that all supporting
medical records, from all providers who rendered a service on the claim, are submitted in a
timely manner. In addition, it is the responsibility of the provider to ensure that
correspondence address and contact information is current with Iowa Medicaid for delivery of
the request for medical records

The CMS review contractor will follow up to ensure that providers submit documentation
within the given timeframe. Iowa Medicaid Provider Services may also contact providers to
assist in identifying required documentation for submission

If the submitted documentation is incomplete, the CMS review contractor may contact
providers for additional documentation. Providers will then have 14 days to respond to the
request. The lack of a response or submission of insufficient documentation will count as an
error. Failure to comply with the records request made by the CMS review contractor will
result in a payment error and Iowa Medicaid will take actions to recover the payment
associated with the records request

Understandably, providers may be concerned with maintaining the privacy of patient
information. However, providers are required by section 1902(a)(27) of the Social Security Act
to retain records necessary to disclose the extent of services provided to individuals receiving
assistance, and furnish CMS or its contractors with information regarding any payments claimed
by the provider for rendering services. The furnishing of information includes producing medical
records. Section 2107(b)(1) of the Social Security Act requires a CHIP state plan to provide
assurance to the secretary of Health and Human Services that the state will collect and provide
to the secretary any information required to enable the secretary to monitor program
administration and compliance and to evaluate and compare the effectiveness of states’ CHIP
plans. In addition, the collection and review of protected health information contained in
individual-level medical records for payment review purposes is permissible by the Health
Insurance Portability and Accountability Act of 1996 (HIPAA) and Title 45 of the Code of
Federal Regulations, parts 160 and 164

Please see the CMS website for more information on the PERM program1

If you have questions, please contact Iowa Medicaid Provider Services at 1-800-338-7909 or by
email at [email protected]

Payment Error Rate Measurement (PERM) | CMS

All Informational Letters are sent to the Managed Care Organizations Iowa Medicaid – 1305 E Walnut St. – Des Moines, IA 50319 INFORMATIONAL LETTER NO. 2369 …

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