To better maximize federal reimbursements for the administrative activities program, Health Care Services should, within six months, determine the extent to which claiming units can claim the unreimbursed difference between the 50 percent and 75 percent reimbursement rates for translation activities for past years and inform claiming units of the findings.
CMS approved retroactive claiming for all claims within the 2-year claiming limit. CMS approval allows retroactive claiming to begin with invoices submitted for the FY 2014-15 Q3 period of service. The invoices for the FY 2014-15 Q3 were submitted to DHCS on December 2016, and 2014-15 Q4 were submitted on February 28, 2017 for payment
We cannot confirm that Health Care Services fully implemented this recommendation. It did not submit for our review a copy of CMS' approval of retroactive claiming nor copies of documents informing claimants of their ability to claim the unreimbursed difference for translation activities.
CMS will provide a response to our request for retroactive claiming once the SMAA manual and new invoice have been approved. The SMAA manual and invoice were submitted on August 15, 2016.
DHCS is revising the current SMAA invoice to allow LEAs to claim the enhanced 75% reimbursement rate for translation related Medi-Cal activities. DHCS has reached out to CMS to determine the period of service for which retroactive claiming can be applied and will develop a mechanism to collect and distribute the additional funding to LEAs as a result of the increased reimbursement rate. DHCS is still awaiting a response from CMS.
DHCS is currently working to incorporate the increased reimbursement for translation services into the current invoice. Once the invoice has been updated and a process is in place to track this activity, DHCS will ask CMS if retroactive claiming will be allowed. Once DHCS develops a process, with the collaboration of stakeholders, we will submit to CMS for approval.
Agency responses received are posted verbatim.