|
|
  |
 |
  |
Chapter Three
Analysis of State Title V / Title XIX
Interagency Agreements
The updated [State MCH-Medicaid Coordination
of Title V and Title XIX Interagency Agreements]
publication will provide summaries of individual
State IAA between State Medicaid and MCH programs
and will highlight programs with successful
partnerships.
-- Peter C. van Dyck, M.D., M.P.H.
Associate Administrator for MCH
From MCHB’s call for State IAAs

A. Documents Reviewed
B. Methodology: Format of the State
IAA Tables
C. Analysis and Findings
A.
Documents Reviewed
A call for State Title V/Title XIX IAAs was
issued to MCH and CSHCN directors by the Maternal
and Child Health Bureau in the spring of 2004
for the purpose of updating this publication.
Thirty-six States from across the country responded
to the request, providing a substantial body
of material to review. From these responses,
47 IAAs were collected and analyzed. Additional
material was also gathered from cover letters,
e-mails, and follow-up phone calls, mostly explanatory
in nature about the process of IAA development.
One State (Texas) provided details on the ways
its respective agencies collaborate in the absence
of a formal agreement.
This analysis, therefore, is based on the review
of IAAs and supplemental information from the
following States (Chapter Five contains
summary tables of these State IAAs):
|
Alabama (AL) |
Illinois (IL) |
Mississippi (MS) |
Oregon (OR) |
|
Arizona (AZ) |
Indiana (IN) |
Missouri (MO) |
Rhode Island (RI) |
|
California (CA) |
Iowa (IA) |
Nebraska (NE) |
South Carolina (SC) |
|
Colorado (CO) |
Kansas (KS) |
New Mexico (NM) |
South Dakota (SD) |
|
Connecticut (CT) |
Kentucky (KY) |
New York (NY) |
Utah (UT) |
|
Florida (FL) |
Louisiana (LA) |
North Carolina (NC) |
Virginia (VA) |
|
Georgia (GA) |
Maryland (MD) |
North Dakota (ND) |
Washington (WA) |
|
Hawaii (HI) |
Michigan (MI) |
Ohio (OH) |
Wisconsin (WI) |
|
Idaho (ID) |
Minnesota (MN) |
Oklahoma (OK) |
|
The States surveyed represent wide geographic
diversity – ranging from the East Coast
to the
Midwest to the Pacific Coast to the South –
as well as great differences in size and population
density. While not every IAA of each State in
the country was collected and analyzed, the
group
surveyed represents a wide variety of racial,
ethnic, and economic diversity among its respective
populations. Of the States surveyed, 2 were
from Region I (CT and RI), 1 from Region II
(NY),
2 from Region III (MD, VA), 7 from Region IV
(AL, FL, GA, KY, MS, NC, SC), 6 from Region
V (IL, IN, MI, MN, OH, WI), 4 from Region VI
(LA, NM, OK, TX), 4 from Region VII (IA, KS,
MO, NE), 4 from Region VIII (CO, ND, SD, UT),
3 from Region IX (AZ, CA, HI), and 3 from
Region X (ID, OR, WA).
While the documents provide a great deal of
data to review, there are certain limitations
imposed by the scope of material. First, many
of the documents did not contain specific expiration
dates, but rather stated that they would remain
in effect until mutually revised or cancelled.
There is the possibility, therefore, that these
documents may have been or soon will be superceded
by newer agreements. Further, many of the IAAs
were unsigned and/or marked “draft,”
so there remains some uncertainty about their
authority. (Despite this, it appears from the
accompanying documentation and conversations
with the States involved that most of these
documents remained the basis for coordination
among agencies.) A number of other documents
were submitted with end dates that have since
passed, so those specific IAAs may have also
been superceded. However, from documentation
accompanying these agreements, it was evident
that in most (if not all) of these cases, the
State agencies were planning on the continued
use of the IAA with only a change of end date
and slight (if any) modification of content.
This report, thus, provides an analysis of
a substantial sampling of IAAs from across the
country. There are other IAAs, either in current
use or in process, that despite continued collection
efforts could not be included in the review.
As such, the material collected does not represent
the entire range of State coordination agreements,
but rather a strong, demonstrative group to
base conclusions upon.
The IAAs differ greatly in format, length,
and level of detail. Some IAAs are boilerplate
agreements with the names of each agency and
their responsibilities written in, while others
are clearly consensus documents, the result
of many hours of focused planning and negotiation.
The documents range from 3 to over 50 pages
with many averaging around 10-12 pages. Some
documents are a simple statement that the Title
V and Title XIX agencies should work together
in ways to be mutually determined, while others
rigorously outline objectives, responsibilities,
and detailed tasks, timelines, and budgets.
There are several differing format styles that
are used in the IAAs:
- About half of the States have developed
a single IAA for outlining a full range of
activities to be coordinated between their
Title V and Title XIX agencies; the remaining
States use a series of individual IAAs to
detail activities related to specific areas
of coordination, such as EPSDT, outreach,
CSHCN, confidentiality, and record keeping.
Similarly, some of the IAAs collected are
part of a larger set of State-wide agreements
that detail activities between multiple other
agencies.
- Most (42) of the IAAs are strictly between
two agencies (almost exclusively specified
as Title V and Title XIX); however, several
documents include agreements between a larger
number of State agencies, including WIC and
local provider organizations.
- The majority of the IAAs are specifically
written for the agencies involved, highlighting
their respective responsibilities and areas
for collaboration; however, several (e.g.,
AZ) IAAs
contain only standard contract provisions.
These IAAs often include addenda that dealt
with
specific areas of focus, such as identification
of beneficiaries, lead screenings, and CSHCN.
Some of these IAAs are actually a basic Medicaid
provider agreement that can also be used
for individual providers (e.g., NM).
- Many of the IAAs highlight specific activities
that require special attention (e.g., agency
coordination, referrals, outreach, and reimbursement)
in separate sections; however, an equal number
of IAAs include such activities in an overarching
list of activities to be carried out between
agencies.
- In cases where a State’s Title V
and XIX agencies are administratively housed
within the same State agency, their corresponding
agreements are often referred to as “intra-agency
agreements.”
B.
Methodology: Format of the State IAA Tables
The summary tables (provided fully in Chapter
Four) are divided into four sections for clarity,
although each IAA itself may not conform to
this format: (I) a general description of the
document; (II) a summary of the contractual
details (Sections 1-5); (III) a summary of the
agreement components that relate to CMS requirements
outlined in 42 CFR 431.615(d) (Sections 6-18);
and (IV) a listing of general contract provisions
(Section 19). Information in the summary tables
is excerpted directly from the actual IAAs,
wherever possible.
Federal Medicaid regulations provide
a logical framework to analyze the State IAAs.
Under 42 CFR 431.615(c) State plans are required
to describe the cooperative arrangements between
the relevant agencies in order to make maximum
use of services [CFR 431.615(c)(1)]; to allow
for Medicaid to utilize services listed in the
State plan that are provided by Title V grantees
[CFR 431.615(c)(2)]; and to allow the Title
V grantees be reimbursed by the State’s
Medicaid agency [CFR 431.615(c)(4)].
CMS continues in CFR 431.615(d) to describe
the actual content required, as appropriate,
in the State IAAs. The main component of the
Chapter Four summary tables follows this regulation
very closely. Thus, many of the table sections
directly address CMS requirements:
| Summary Table Section:
(Section number) and description |
CMS Requirement Addressed: |
| (6)
Objectives and (7) Responsibilities |
42
CFR 431.605(d)(1):
The mutual objectives and responsibilities
of each party to the arrangement. |
| (8)
Services Provided by Agency |
42
CFR 431.605(d)(2):
The services each party offers and in
what circumstances. |
| (9)
Cooperative Relationships |
42
CFR 431.605(d)(3):
The cooperative and collaborative relationships
at the State level. |
| (10)
Services Provided by Local Agencies |
42
CFR 431.605(d)(4):
The kinds of services to be provided
by local agencies. |
| (11)
Identification and Outreach |
42
CFR 431.605(d)(5)(i):
The methods for early identification
of individuals under 21 in need of medical
or remedial services. |
| (12)
Reciprocal Referrals |
42
CFR 431.605(d)(5)(ii):
Methods for reciprocal referrals. |
| (13)
Coordinating Plans |
42
CFR 431.605(d)(5)(iii):
Methods for coordinating plans for health
services provided or arranged for recipients. |
| (14)
Reimbursement |
42
CFR 431.605(d)(5)(iv):
Methods for payment or reimbursement. |
| (15)
Reporting Data |
42
CFR 431.605(d)(5)(v):
Methods for exchange of reports of services
furnished to recipients. |
| (16)
Review |
42
CFR 431.605(d)(5)(vi):
Methods for periodic review and joint
planning for changes in the agreements. |
| (17)
Liaison |
42
CFR 431.605(d)(5)(vii):
Methods for continuous liaison between
the parties, including designation of
State and local liaison staff. |
| (18)
Evaluation |
42
CFR 431.605(d)(5)(viii):
Methods for joint evaluation of policies
that affect the cooperative work of the
parties. |
While the State IAAs follow this structure to
varying degrees (from an almost one-to-one correspondence
to a more general reliance on the Federal Code
for structural guidance), it nevertheless provides
a consistent benchmark to look at the documents
as a whole. In many cases, an IAA addresses
a topic that is similar to but not an exact
match to one of the summary table sections (and
its corresponding CMS requirement); in these
cases, the topic is reported in the table element
to which it is most closely related. Often an
IAA does not treat specific elements outlined
in 42 CFR 431.605(d). In such cases, “N/A”
(not addressed) is listed under that table element.
This does not mean that the document is lacking
in any way, merely that it does not address
that specific topic (which may be implicit or
treated in another document).
In many of the IAAs, specific activities are
addressed in separate sections to highlight
their importance (e.g., reimbursement is often
addressed in its own section). When this occurs,
the related requirements are described in that
specific table element. However, many IAAs summarize
all of their activities together. In this case,
specific table elements cross reference the
appropriate activity to its appropriate section
(e.g., in New York, a discussion of reimbursement
is integrated in a list of overall services.
Thus, the table element for reimbursement refers
back to the list of overall services: “See
Section 8, Service A7, B1.”)
C.
Analysis and Findings
A summary of the findings of the review of
State IAAs is presented in the following table,
followed by a more detailed analysis.
| Analysis of the State
Interagency Agreements: Summary Based
on 47 Documents |
| Contractual Details
|
| 1.
Effective Date:
• 42 specify an effective date (exceptions:
AZ, CT#2, FL, NY, SD)
• 40 specify a specific date/specific
“date of issuance or amendment”
• 2 specify a general “date of issuance
or amendment,” but no specific date |
| 2.
Duration
• 39 address the IAA’s duration (exceptions:
AL, AZ, CT#1, LA, NY, RI#1-2, ID)
• 16 denote a specific date (CO#1-2,
HI, IL, IA#1-4, KS, KY, MS, OH, OK, OR,
SC, WA) |
| 3.
Type of Agreement
• 12 “Cooperative Agreements”
• 11 “Interagency Agreements;” 1 “Intra-angency
Agreement”
• 5 “Memorandum of Agreements;” 7 “Memorandum
of Understandings”
• 2 “Intergovenmental Agreements”
• 6 miscellaneous (2 “Provider Contracts/Agreements,”
2 “Agreements;” 1 “Joint Powers Agreement,”
1 “Action Plan,” 1 “Standard Business
Agreement,” 1 “Master Agreement”) |
| 4.
Agencies Involved
• 39 are between two agencies (most
specified as Title V and Title XIX)
• 7 include additional agencies (CA,
CO, KY, MD, ND, OH, RI#2)
• 1 specifies only the Title V role
(RI#1) |
| 5.
Authority Cited
• 33 cite specific requirements on legislation,
often citing multiple sources
• 12 cite SSA§1902(a)(11) (CA, FL, HI,
ID, IN, IA#2, KS, LA, MD, NE, RI#1, SC)
• 20 cite 42 CFR 431.615 (CA, GA, IN,
IA#1-3, KS, LA, MD, MO#1,3-6, ND, OH,
OR, SC, UT, VA)
• 14 cite State legislation (CO#1-2,
CT#1, HI, IL#2, IA#1, KY, MN, MS, ND,
OK, OR, SD, WA) |
| Analysis
Related to CMS Requirements |
| 6.
Objectives
• 46 contain readily identifieable objectives
• 24 list increased coordination, strengthened
relationships, and/or establishing strong
cooperative relationships (CA, CT#1-2,
IA#1-3, ID, IL#2, IN, KS, LA, MD, MN,
ND, NE, NY, OH, OK, RI#1, SC, SD, UT,
WA, WI) |
| 7.
Responsibilities
• 30 provide a summary of each agency’s
programmatic/administrative accountabilities(CA,
CO#1, CT#1, FL, GA, IA#1-2, ID, IL#2,
KS, KY, LA, MD, MN, MO#1,3-6, MS, ND,
NE, NY, OK, OR, RI#1-2, SD, WA, WI)
• 17 only included information on which
agency is identified as Title V and Title
XIX(AL, AZ, CO#2, CT#2, HI, IA#3-4, IL#1,
IN, MI, MO#2, NC, NM, OH, SC, UT, VA)
|
| 8.
Services Provided by Agency
• All 47 provide a breakdown of services
provided by agency
• 39 provide specific services provided
by each agency, and/or mutual services
(CO#1-2, CT#1-2, FL, GA, HI, ID, IL#1-2,
IN, IA#2-4, KS, KY, LA, MD, MI, MN, MO#1-6,
NE, NM, NY, NC, ND, OH, OK, RI#2, SC,
SD, UT, VA, WA)
• 5 break down services by topic/objective
(CA, MS, ND, RI#1, WI) exclusively or
in addition to services provided by agency |
| 9.
Cooperative Relationships
• 27 address cooperation between agencies
(CA, CO#1-2, GA, IA#1-2, ID, IL#1, IN,
KS, LA, MD, MI, MN, MO#1,4, NC, ND, NY,
OH, OK, RI#1, SD, UT, VA, WA, WI)
o 17 of these 27 address cooperation/coordination
as part of Section 8 or elsewhere
(CA, CT#2, GA, IL#1, IN, MD, MI, MO#4,
ND, NY, OH, OK, RI#1, SD, UT, VA, WA)
o 10 of these 27 address cooperation/coordination
as an indivudual section (CO#1, IA#1-2,
ID, KS, LA, MN, MO#1, NC, WI) |
| 10.
Services Provided by Local Agencies
• 13 address collaboration with local
agencies and services to be provided (CA,
IA#3, IL#1, KS, MI, NC, ND, NE, NY, OH,
VA, WI)
• 12 integrate engagement of local agencies
into overall division of services (Section
8), stating that plans for coordination
and services are often developed in conjunction
with community partners (CA, IA#3, IL#1,
IN, KS, MI, ND, NE, NY, OH, VA, WI) |
| 11.
Identification and Outreach
• 34 address outreach to various degrees
(AL, AZ, CA, CO#1, CT#2, FL, HI, IA#1-4,
ID, IL#1-2, KS, MD, MI, MN, MO#3-6, MS,
NC, NE, NM, NY, OH, RI#1, SD, UT, VA,
WA, WI)
• 17 address outreach as part of overall
division of services (AL, AZ, CT#2, FL,
HI, IA#3, IL#2, MI, MO#4-5, NM, NY, OH,
RI#1, SD, UT, WI)
• 1 focuses entirely on outreach (IA#4)
|
| 12.
Reciprocal Referrals
• 28 address referrals (AL, CA, CO#1,
CT#2, FL, HI, IA#1-2,4, ID, IL#2, KS,
KY, MD, MI, MN, MO#1,3, 5-6, NC, ND, NE,
NY, OH, SD, WA, WI)
• 16 incorporate referrals as part of
overall division of services (AL, CA,
CO#1, CT#2, IA#4, IL#2, KY, MD, MI, MN,
MO#5, NC, NY, OH, SD, WA) |
| 13.
Coordinating Plans
• 30 include plans for coordination
(CA, CO#1, CT#2, GA, IA#1-2,4, ID, IL#1,
IN, KS, KY, MD, MI, MN, MO#1-4, MS, NC,
ND, NY, OK, RI#1, SD, UT, VA, WA, WI)
|
| 14.
Reimbursement
• Only 8 do not cover reimbursement
topics (AZ, CO#2, CT#1-2, MN, MO#6, RI#1,
SC)
• 18 incorporate reimbursement into
overall division of services (FL, ID,
IL#1, IN, MI, MO#1-5, ND, NM, NY, OH,
OK, RI#2, SD, UT) |
| 15.
Reporting Data
• Only 3 do not cover data reporting
(OR, RI#1, MO#6)
• 22 address data as part of the division
of services (AL, FL, HI, IA#3-4, IL#1-2,
IN, KY, MI, MO#1-5, NM, NY, OH, OK, SD,
UT, WA) |
| 16.
Review
• 19 detail a plan for periodic review
of the IAA (CA, IA#2, IL#1-2, IN, KS,
KY, LA, MN, MO#1,3-5, NC, ND, OH, RI#1,
UT, WI)
• 8 incoporate a review into other sections
of the IAA (IA#2, IN, KS, KY, MO#4-5,
OH, WI) |
| 17.
Liaison
• 32 establish a method or individual
for liaison (CA, CO#1-2, FL, GA, IA#1-3,
ID, IL#1, IN, KS, KY, LA, MI, MN, MO#1-5,
NC, ND, NY, OH, OK, RI#2, SD, UT, VA,
WA, WI) |
| 18.
Evaluation
• 23 establish a system for evaluating
the effectiveness of the programs and/or
IAA (CA, IA#2, ID, IL#1-2, IN, KS, KY,
LA, MN, MO#1-6, NC, ND, OH, RI#1-2, UT,
WI)
• 12 discuss evauation as a separate
topic, outside the general division of
services (CA, IA#2, ID, IL#1, KY, LA,
MO#3-6, ND, RI#1) |
| General
|
| 19.
General Contract Provisions
• Only 7 do not contain general contract
provisions (AL, CT#2, ID, LA, NY, RI#1-2)
• 37 contain termination of agreement
clauses, 29 lay out procedures for amendment,
26 define standards of confidentiality
in record keeping. |
Detailed Analysis
A detailed analysis of the manner in which
the State IAAs correspond to the review components
are presented in the following section. Most
often, a common trend emerges as to how States
approach each topic. These common trends are
explained and examples of States that either
greatly differ from or reflect the norm are
given.
General Document
Description
Title and Author
Many of the documents collected contain an
easy to find title, most often consisting of
the type of agreement, followed by the agencies
involved, and concluding with the scope of the
agreement. However, most of the documents do
not provide an easily identifiable author or
originating agency, which has to be inferred
by the contractual language. Many States also
do not include the State name in the title or
opening pages of the document, making it initially
difficult to identify what State is being discussed.
Document Date, Number
of Pages, and Document URL
This information has been taken from a physical
review of each document. The Web site address
for each document is given; the full electronic
text of every document surveyed is available
from http://www.mchlibrary.info/IAA.
Contractual Details
(1) Effective
Date
Of the 47 IAAs collected, only 5 do not contain
any language related to an effective date (AZ,
CT#2, FL, NY, and SD). Most of the documents
list specific dates or state that they would
take effect upon signature (e.g., MD, OH) or
upon the date of issuance (e.g., GA). In the
case where the effective date depends upon the
date of signature, the summary table lists that
date in brackets (e.g., for WA, [January 1,
2000]). Several of the IAAs list both an issuance
date and an effective date of amendment (e.g.,
AL, MI).
(2) Duration
Sixteen of the 47 IAAs collected denote specific
dates of duration (CO#1-2, HI, IL, IA#1-4, KS,
KY, MS, OH, OK, OR, SC, and WA), while 8 (AL,
AZ, CT#1, LA, NY, RI#1-2, and ID) identify no
period of duration. However, for all of these
IAAs, supporting documentation reveals that
the IAAs are currently in effect. Several of
the documents indicate that they will remain
in effect for a period of 1, 3, or 5 years from
an unspecified effective date.
Many of the IAAs specify that they will remain
in effect in perpetuity (e.g., NE) or until
cancelled (e.g., MO, NM) or modified (e.g.,
CA) by one or both parties. Several IAAs require
periodic review and unless modifications are
required, they are set to automatically renew
at the
end of each year unless written notice is provided
to request amendment or nullification of the
agreement (e.g., IN, MI).
(3) Type of Agreement
There are many permutations of the type of
agreement entered into by the various State
Title V and Title XIX agencies. Agreements between
separate State agencies are often described
as “interagency agreements” (e.g.,
CA, CO), while those housed within the same
division or department often describe themselves
as “intra-agency agreements” (e.g.,
LA). On the whole, terms used to describe the
contract vary widely from “Action Plan”
to “(Cooperative) Agreement” to
“Memorandum of Agreement/Understanding”
(MOA or MOU). In such instances, there does
not seem to be a direct correlation between
the type of agreement and the nature of the
relationship between agencies. It is likely
that the types of agreement are stock titles
used in legal agreements across the various
States or similarly that specific State regulations
require a specific form of agreement to be entered
into between parties. In a few states such as
AL and NM, the format of the IAA is specified
as a “Provider Contract” or a “Provider
Participation Agreement” that the Title
XIX agency obviously uses with other provider
contracts as well as with Title V agencies.
(4) Agencies Involved
Thirty-nine of the 47 IAAs surveyed are between
two agencies, most specified as the agencies
that administer Title V and Title XIX. Many
of the agreements, however, stated only the
agency title without clearly specifying what
its exact role is (either Title V or Title XIX).
However, in the majority of these cases, it
is fairly evident as to each agency’s
respective identity, roles, and responsibilities.
One of the documents (RI#1) lists only the participation
of the agency that administers Title V without
specifying the corresponding Title XIX agency’s
responsibilities. Several other States (CA,
CO, KY, MD, ND, OH, and RI#2) also include other
agencies (e.g., Title XXI, WIC, and local provider
organizations), assigning each specific responsibilities.
(5) Authority Cited
From the 47 documents collected, there are
a variety of sources relied upon for authority
in delineating each agency’s respective
roles and responsibilities. While each State
cites the authority that is most relevant to
their specific IAA, there are some overall trends:
- Legislative
or Regulatory Medicaid Federal Law.
Most States (33 total) cite specific
requirements in legislative or regulatory
Medicaid Federal law [either exclusively (13)
or in combination with another authority (20)].
Most often, the IAAs cite:
- SSA §1902(a)(11) or related sections
(CA, FL, HI, ID, IN, IA#2, KS, LA, MD,
NE, RI#1, and SC) and/or
- 42 CFR 431.615 (CA, GA, IN, IA#1-3,
KS, LA, MD, MO#1,3-6, ND, OH, OR, SC,
UT, and VA).
- State
Requirements.
Fourteen IAAs cite State authority
for establishing their agreements (CO#1-2,
CT#1, HI, IL#2, IA#1, KY, MN, MS, ND, OK,
OR, SD, and WA), including both State legislature
and other/previous IAAs.
- Multiple
Authorities Cited. Many
IAAs thoroughly cite a combination of Federal,
State, and other (program-specific) authorities
for the establishment of their agreements.
Only 12 of the IAAs do not refer to any overarching
authority as the basis for establishing their
agreements (AL, AZ, CT#2, IL#1, IA#3, IA#4,
MI, MO#2, NM, NY, NC, and RI#2); two (ID, RI)
cite the SSA in general, but do not give a specific
reference. One (WI) does not cite an authority
for the statutory basis for its IAA, but instead
refers to authority for specific programs such
as EPSDT and WIC.
Analysis Related
to CMS Requirements
(6) Objectives
Overall, States are highly conscientious in
providing clear sets of objectives for their
IAAs. Forty-six of the 47 documents surveyed
contain readily identifiable objectives at the
beginning of their narratives. The objectives
range in descriptiveness, from extremely direct
(Florida’s IAA states its objective “to
better serve the needs of Florida’s pregnant
women and children at risk for poor birth and
health outcomes”) to highly detailed (Ohio’s
IAA lists 13 separate objectives, detailing
numerous goals for almost all of its activities).
Often the objectives contain general statements
followed by State- or program-specific goals.
In every IAA, the goals are stated as being
mutually shared between the two (or more) agencies
involved, and the majority (24) list increased
coordination, strengthened relationships, and/or
establishing strong cooperative relationships
as part of their overall objectives.
Common objectives often include:
General and Coordination:
• To improve the health of women, pregnant
women, infants, children, and adolescents, CSHCN,
etc.
• To meet the requirements of the Social
Security Act and to comply with other applicable
State and Federal statutes, regulations, and
guidelines, including HIPAA.
• To increase coordination/collaboration
between the Title V and Title XIX (and other,
if applicable) agencies.
• To maintain clear communication between
agencies.
• To develop and implement initiatives
that address the underlying causes of preventable
diseases.
• To develop and implement standards of
care.
Programmatic and Local
Relationship Building:
• To prevent duplication, overlap, and/or
fragmentation of effort and/or services.
• To promote long-range planning.
• To strengthen relationships with local
health agencies.
• To develop and maintain local capacity
for MCH Services and to provide Medicaid information
and care coordination.
• To strengthen relationships with multi-cultural
and multi-ethnic organizations.
Identification, Outreach,
and Referral:
• To coordinate identification of infants,
children, adolescents, and women who are potentially
eligible for services.
• To provide outreach and increase public
awareness of the need for health care coverage
and services for women and children.
• To provide outreach related to the services
provided by Title V and Title XIX.
• To provide resource and referral information;
to refer the child and family to appropriate
services.
• To implement an established joint referral
process.
Reimbursement and
Financial:
• To specify the reimbursement and financial
arrangements applicable.
• To facilitate the claim for Federal
matching funds for the efficient and effective
administration of the State Plan.
• To ensure the maximum utilization of
Title XIX resources.
Data Sharing:
• To promote timely sharing of programmatic
data.
• To allow joint access to critical Medicaid
and public health data.
• To cooperate in creating linked, de-identified
data files that will be used for public health
and health care research, program evaluation,
and surveillance.
States that have issued separate IAAs addressing
specific topics (such as outreach, EPSDT services,
hotline establishment, non-emergency medical
transportation) most often include objectives
that are specific to the programs addressed.
These agreements (e.g., IA#1-4 and MO#1-6) spend
less time stating overarching goals than IAAs
that deal with Title V/Title XIX activities
as a whole.
(7) Responsibilities
States are divided when it comes to specifying
agency responsibilities. Thirty States provide
a summary of each agency’s programmatic
and/or administrative accountabilities, while
17 States do not include such a summary beyond
what agency is identified as Title V and Title
XIX.
In the documents that do include a listing
of responsibilities, a series of “whereas”
paragraphs at the beginning of the agreement
is often used to delineate specific agency responsibilities.
(e.g., “Whereas the [North Dakota] Department
of Human Services…is the state agency
responsible for administering Children’s
Special Health Services in conformity with Title
V of the SSA…” and “Whereas
the [North Dakota] Department of Health is the
state agency responsible for administering the
MCH Program…”).
Many of the responsibility statements also
include specific tasks beyond a listing of the
programs
for which an agency has oversight (e.g., “the
Georgia Department of Community Health is
responsible for all health planning issues in
the state,” and similarly, “the
Kentucky Department of
Community Based Services is responsible for
providing protective services, such as targeted
case
management and rehabilitative services”).
These “whereas” statements are
often used to “set the stage” by
introducing the objectives, services, and other
components of the IAA. These responsibilities
are often closely followed by a summary rationale
for the establishment of the agreement (e.g.,
“Now, therefore, be it resolved that the
Department of Human Services and the Department
of Health agree to perform the following in
connection with this agreement: …”).
Most of the IAAs that include responsibilities
break them out by agency, describing first what
the Title V agency’s responsibilities
are and then the corresponding Title XIX responsibilities.
However, a few States (e.g., MO and NY) list
joint or shared responsibilities. Often the
line between shared responsibilities and shared
objectives is blurred, so that it is difficult
at times to differentiate the two. Indeed, Federal
Medicaid regulation 42 CFR 431.605(d)(1) combines
objectives and goals into one requirement.
(8) Services Provided
by Agency
The primary focus of most State IAAs is the
specification of services to be provided by
each agency entering into the agreement. The
format and amount of information included by
each State varies substantially: some documents
include bulleted or numbered lists under each
agency while other States provide narratives
of various lengths to enumerate the division
of services. Often, the documents summarize
services to be supplied by both parties and
then treat the services to be provided by each
respective agency. Some IAAs (e.g., IN) break
these services down by topic, such as coordination,
confidentiality, data sharing, and reimbursement.
Other States divide this section by objective
(e.g., IA#2) or by State program (e.g., KS).
Section 8 of the State Summary Tables (listed
in Chapter Five) attempts to standardize the
reporting of these services across the States
(in numbered lists) and to present them in a
manner that is easy to summarize by State or
to compare across State, region, or IAA section.
At their best, the State IAAs present divisions
of tasks in such a way as to make such services
more than just “laundry lists” of
activities that each agency is assigned to complete.
It is obvious that across the country States
have put great thought and effort into coordinating
activities between various agencies to satisfy
(and in many cases, to go beyond) their stated
objectives.
In the most standard approach to services provided
by agency, the respective Title V agency agrees
to be the administrative unit responsible for
providing services (either through local programs
or by direct contracting with health providers)
while the Title XIX agency assumes responsibility
for providing reimbursement for such services.
Often, the two agencies further agree to a series
of mutual services or responsibilities in addition
to those tasks for which they are each responsible.
The range of activities provided by the respective
Title V, Title XIX, and other State agencies
greatly varies, in part due to the structure
of the State health system and the specific
needs of
the population served. However, there are many
activities that appear repeatedly in the IAAs.
General services that appear often in State
IAAs are outlined below (typically appearing
in more
than half of the IAAs summarized); these are
not meant to be exhaustive lists, but rather
an
overview of typical activities. Specific activities,
such as those related to identification and
outreach, referrals, coordination, reimbursement,
data, and liaison are discussed in detail in
their
corresponding sections.
Agencies
that administer Title V often have the
responsibility to:
- Provide EPSDT, family planning, immunizations,
prenatal care, early intervention, and/or
case management and related services
to those who meet eligibility requirements.
- Determine the level, intensity, frequency,
appropriateness, and service modality
of services to be provided.
- Identify and fund local health departments
and other contractors to provide the
infrastructure for health care programs.
- Use Medicaid funding to contract
for development, implementation, and
direction of services to eligible children
and mothers.
- Provide required financial and statistical
data/records to document reimbursement
for Medicaid services. Collect and maintain
appropriate records and health data
(e.g., records of covered services furnished
to eligible participants) and/or to
identify needs and to ensure that the
Medicaid agency will be able to collect
Federal matching funds.
- Refer potentially eligible children
and pregnant women to the Medicaid program
and/or assist them in applying for Medicaid.
- Inform potentially eligible families
of the availability and scope of the
EPSDT program.
- Support provider outreach; require
Title V providers to also be Medicaid
providers.
- Develop outreach materials for informing
recipients about Medicaid services.
- Maintain a toll-free number that
women and families can contact and receive
information from appropriately trained
personnel.
|
Agencies
that administer Title XIX often have the
responsibility to:
- Develop reimbursement methodologies
for the payment of MCH care services.
- Provide timely reimbursement for
the services provided by the Title V
agency, its local health departments,
or contracting providers with current
Medicaid rates and fees for all services
within the scope of Medicaid benefits
- Provide Medicaid data to the agency
that administers Title V.
- Provide case management services.
- Refer eligible children, adolescents,
and/or pregnant women to Title V providers
for EPSDT screenings and/or other Medicaid
services.
- Provide the agency that administers
Title V and/or local health departments
with a listing of EPSDT and/or other
Medicaid eligible beneficiaries and
related data.
- Provide training to Title V providers
on Medicaid services, and particularly,
Medicaid billing procedures.
- Monitor the quality of services being
provided by the Title V providers.
- Collect and analyze expenditure data
for Medicaid-covered services; develop,
implement, and monitor Medicaid provider
and contract agreements; investigate
inappropriate billing/utilization of
Medicaid reimbursement.
|
Agencies
administering Title V and Title XIX often
share responsibility to:
- Work collaboratively to improve the
health of State residents.
- Ensure that Title V, Title XIX (and
other) services are consistent with
the needs of the participants and the
programs’ objectives and requirements.
- Coordinate program initiatives to
avoid duplication of effort among agency
programs.
- Encourage referrals between various
programs.
- Develop and implement, in cooperation,
health care standards, program policies,
and pilot programs.
- Develop, in cooperation, provider
manuals, billing instructions, and provider
training.
- Develop statewide advisory groups
to oversee the implementation of care
coordination.
- Provide liaison between agencies
for interagency communication and coordination.
- Provide financial support/reimbursement
to local health agencies and other groups
and individuals engaged in the delivery
of health services to mothers and children.
- Comply with all applicable State
and Federal laws, regulations, and rules
regarding confidentiality of participant
information, ensuring that information
is disclosed only for the purpose of
activities necessary for administration
of the respective program(s) and for
audit and examination authorized by
law.
|
The majority of the State IAAs present services
in this manner, separated by the agency responsible
for their implementation. However, several documents
(CA, IA#2, IN, MD, and RI#2) further categorize
services by objective or by type of service.
For example, California lists the following
clearly defined objectives and then relates
agency activities directly to each objective:
- Objective 1: Assure and support the
provision of a comprehensive, coordinated,
and accountable health services delivery system
for all eligible pregnant women, infants,
children, and adolescents.
- Objective 2: Assure the provision of
high quality health care by organizations
and providers who meet professional practice
standards.
- Objective 3: Improve access to perinatal
and preventive health care services for low-income
women, particularly adolescents and children,
respectively, and services to CSHCN.
- Objective 4: Assure maximum utilization
of Title XIX funds by Title V contractors
and providers, including reimbursement by
Title XIX for all medically necessary services
within the Title XIX scope of benefits.
- Objective 5: Plan and support the delivery
of training and education programs for health
professionals and the community, including
beneficiaries of Title V and XIX services.
- Objective 6: Develop and implement
data collection and reporting systems that
support assessment, surveillance, and evaluation
with respect to health status indicators and
health outcomes among the populations served
by both programs.
- Objective 7: Improve ongoing intra
departmental communication between staff of
the two programs for information sharing,
problem solving, and policy setting (this
includes sharing of information and maintaining
regular, formal communications).
- Objective 8 : Maintain adequate Title
XIX and Title V program staff with the necessary
expertise necessary to carry out the specific
functions and responsibilities of providing
direct support in administering the Title
XIX program.
- Objective 9: Maximize utilization of
third party resources available to Title XIX
recipients.
In this IAA, each objective is followed by
a list of the Title V services to be provided
followed by a similar list of Title XIX services.
The Indiana MOU groups services provided by
agency according to type: coordination, confidentiality,
data sharing, and reimbursement. Similarly,
the Maryland cooperative agreement groups services
according to the following divisions: administration
and policy; reimbursement and contract monitoring;
confidentiality and data exchange; recipient
outreach and referral; training and technical
assistance; provider capacity; system integration;
and quality assurance activities.
Several IAAs group services by the State program
they fall under. For example, the Colorado Title
V/Title XIX IAA (CO#1) organizes its services
by the following programs: Family Planning;
Prenatal Plus; Health Care Program for Children
with Special Needs; Developmental Evaluation
Clinic Services; Immunization Program; Lead
Poisoning Prevention Program; Breast and Cervical
Cancer Program; and the Nurse Home Visitor Program.
Many of the IAAs focus specific attention on
a specific set of activities. Often, in such
cases the State issues a separate IAAs for each
program rather than combine all Title V and
Title XIX activities into one document. Colorado
has issued a specific IAA (CO#2) on HIPAA requirements;
other States such as Connecticut, Indiana, and
South Carolina have written their IAAs to focus
on data files and sharing of confidential data.
Iowa has submitted a separate IAA on EPSDT services.
Missouri maintains multiple cooperative agreements
focusing on very specific topics: prenatal case
management and/or service coordination for pregnant
women; well child outreach; the Head Injury
Program; administration of the medical home
and community-based service waivers to targeted
individuals with physical disabilities; non-emergency
medical transportation; and case management
for the Healthy Children and Youth Program.
Finally, several States used their IAAs to
include services to be provided by other State
programs. Maryland’s cooperative agreement
is between its Title V and Title XIX agencies
and the State WIC program; Wisconsin’s
MOU includes Title V, Title XIX, Title XXI,
and WIC.
(9) Cooperative Relationships
One of the main purposes of the IAA is to define
how the agencies that administer Title V and
Title XIX (hereafter referred to as the “Title
V and Title XIX agencies”) will work together
efficiently to provide services to a shared
population. As such, most documents are filled
with language emphasizing the need for cooperative
relationships at the State level. Many States
stress the need for cooperative interagency
ties by integrating relationship-building into
each agency’s required activities (e.g.,
CA, IN, MO, and WA). Such states emphasize activities
that need to be done in collaboration; by planning
and implementing services together, the State
Title V and Title XIX agencies are building
the cooperative relationships necessary to fulfill
the IAA’s objectives.
Many IAAs follow the example of Colorado, which
specifically requires agencies to “collaborate
via mutually agreed upon activities.”
Wisconsin requires its Title V, Title XIX, and
WIC programs to “establish cooperative
and collaborative relationships, including work
groups and periodic meetings, with respect to
[its] programs and services.” Idaho likewise
requires its respective agencies to “jointly
participate in implementation of collaborative
services, such as an outreach campaign and a
toll-free information line and referral service.”
As can be seen in these examples, the line
between strictly defining cooperative relationships
(described here in Section 9) and actively coordinating
plans for health services (Section 13, summarized
below) is often quite thin, since the establishment
of cooperative relationships should lead to
coordinated plans between agencies.
(10) Services Provided
by Local Agencies
While Federal Medicaid regulations require
a description of the kinds of services provided
by local agencies [42 CFR 431.605(d)(4)], most
of the IAAs do not deal directly with this issue
(indeed, 34 of the documents discuss local agency
services only in the most general terms or do
not include such services at all). Instead,
in most instances services provided by local
agencies are integrated within those provided
by the Title V agency.
However, one aspect relating to local health
agencies that is addressed in a number of IAAs
involves ongoing communication and coordination
between local groups and Title V/Title XIX agencies.
For example, the Illinois intragovernmental
agreement (IL#2) requires its Title XIX agency
to “provide to the local health departments
data related to children enrolled in the Medical
programs within their jurisdiction to increase
EPSDT participation, including immunizations
and lead screening.” The Indiana MOU requires
both Title V and Title XIX agencies to inform
local health departments of the agreement and
“of the responsibilities of the local
program staff affected” by it. Michigan’s
IAA requires its respective agencies to provide
accurate lists of clients due for screenings
to local health departments or other organizations;
however, it does not spell out the screening
services that are to be provided by the local
agencies. Nebraska requires the Title XIX agency
to inform and educate all local health departments
to make them aware of the Medicaid services
offered.
There are a few examples of strong coordination
with local agencies that stand out. North Dakota
lists a section for “local coordination”
under each one of its service categories (in
Section 8). Local agencies are thus tasked with
making Title XIX eligibility determinations
for potentially eligible individuals referred
by other programs; referring Title XIX eligible
persons to the appropriate services; and providing
information to eligible recipients about Medicaid
services. Wisconsin also discusses services
to be provided by local agencies in detail:
these agencies are to participate in Medicaid
managed care advisory groups; provide information
to HMOs about the services they provide; and
join in collaboration with WIC projects, HMOs,
Title V, and Title XIX.
(11) Identification
and Outreach
42 CFR 431.605(d)(5)(i) calls for a description
of the methods used for early identification
of
individuals under 21 in need of medical or remedial
services. States, however, are split as to whether
their IAAs address this topic to any great extent.
Of the documents surveyed, 11 (AL, CA, HI, IL#2,
KS, MI, MN, MO#3, MO#5, MO#6, and UT) assign
the role of identification to one of the State
agencies or some combination of the 2. In such
instances when identification of potential eligible
beneficiaries is discussed, outreach to such
individuals is often paired with the discussion.
States are usually direct in their assignment
of an agency to identify potential beneficiaries.
Alabama’s provider contract states that
the Title V agency shall identify children who
have not received screenings and then follow
up with the appropriate sickle cell and metabolic
screenings, newborn hearing screens, and immunization
status. The contract also calls for the Title
V agency to utilize proper diagnosis codes to
identify high-risk children. California’s
IAA tasks its Title V agency to identify infants,
children, adolescents, and women who are potentially
eligible for Medicaid and, once identified,
assist them in applying. Title V must then collaborate
with the Medicaid agency in performing outreach
and informing all EPSDT eligible individuals
and/or their families about the program.
In Kansas, the Title V agency has the responsibility
of providing early identification and referral
of individuals of potential beneficiaries to
Medicaid and must also provide State and local
Title XIX offices with MCH program brochures
for distribution to these Medicaid consumers.
In the Minnesota interagency MOU, the Title
XIX agency is to receive screening and referral
information from managed care health plans that
is entered into a tracking system in order to
help identify children under 21 in need of medical
or remedial services. It then contracts with
counties to perform outreach and follow-up EPSDT
services to eligible children. Three of the
six Missouri cooperative agreements (MO#3, 5,
6) also require their Title V agency to identify
possible eligible beneficiaries for their respective
Head Injury, Non-Emergency Medical Transportation,
and Healthy Children and Youth Programs.
The topic of outreach is addressed in 25 of
the IAAs. Usually, this is done in a straightforward
manner as a subset of services to be provided
by agency. Most often outreach activities consist
of similar activities:
- Informing families about Medicaid benefits,
especially EPSDT services through a combination
of oral and written formats at venues such
as health fairs, immunization clinics, community
health services offices, physician and public
health offices, and hospitals.
- Conducting outreach (such as scheduling
appointments and reminding families when exams
are due) to ensure that families are benefiting
from Medicaid services.
- Developing brochures and other materials
for informing recipients about Medicaid services.
- Maintaining a toll-free number that women
and families can contact and receive information
from appropriately trained personnel who provide
information and referrals for prenatal care,
family planning, and well-child services.
Outreach activities often are seen as a joint
responsibility of the Title V and Title XIX
agencies (e.g., CA, CO#2), although they may
also be assigned specifically to one agency
(e.g., CN#2, FL) or split among agencies (e.g.,
HI). Some States (e.g., IA) have issued a separate
IAA dealing specifically with outreach activities
or have devoted large portions of Section 8:
Services Provided by Agency to outreach activities
(e.g., MD). These documents serve as good models
in defining the need for and activities related
to outreach.
(12) Reciprocal Referrals
Reciprocal referrals are dealt with briefly
yet effectively in the majority of the IAAs
collected. Most States include the responsibility
for reciprocal referrals to necessary services
within the listing of their services provided
by agency (see Section 8). Usually, the mandate
for the agency is quite simple, such as to “refer
the child and family to appropriate services”
(ID). The Kansas cooperative agreement is more
encompassing: “each party to this Agreement
will establish a system of referrals for those
services not directly rendered by the agency,
but which are essential to meet the individual’s
need. To the degree possible, these referrals
will be made at the time of client contact.
Programs such as [those provided by the Title
V and Title XIX agencies,] WIC, and Healthy
Start will fall into this category.”
Nebraska also includes a compelling requirement
for referrals in its IAA; it charges both its
Title V and Title XIX agencies to “encourage
comprehensive and continuous care to mutual
clients by encouraging or requiring providers
in each program enjoined by this Agreement,
to identify and refer potentially eligible individuals
through the use of reciprocal referrals.”
A few States go beyond a general mandate requiring
reciprocal referrals. As part of its program
planning activities, Idaho requires its Title
V and Title XIX agencies to work together in
developing a common referral form to be used
across the State. Iowa’s IAA on outreach
|