BEFORE THE DEPARTMENT OF PUBLIC
HEALTH AND HUMAN SERVICES OF THE
STATE OF MONTANA
In the matter of the amendment of ARM 37.86.3515 pertaining to case management services for adults with severe disabling mental illness, reimbursement
NOTICE OF AMENDMENT
TO: All Concerned Persons
1. On December 9, 2010, the Department of Public Health and Human Services published MAR Notice No. 37-529 pertaining to the public hearing on the proposed amendment of the above-stated rule at page 2807 of the 2010 Montana Administrative Register, Issue Number 23.
2. The department has amended the above-stated rule as proposed.
3. The department has thoroughly considered the comments and testimony received. A summary of the comments received and the department's responses are as follows:
COMMENT #1: A commenter was concerned that the rate setting methodology was not being applied uniformly.
RESPONSE #1: The Addictive and Mental Disorders Division (AMDD) within the Department of Public Health and Human Services is responsible for the provision of targeted case management for adults with severe disabling mental illness. AMDD used a methodology that has been approved by the Centers for Medicare Services (CMS) in order to determine the cost of providing this service and has adjusted the reimbursement rate accordingly. The proposed rule amendment applies only to targeted case management for adults with severe disabling mental illness.
AMDD understands the commenter's concern that another division within the department that participated in the time study did not adjust the reimbursement rate suggested by the outcome of the study. The approval of the methodology by CMS did not obligate the department to adjust rates in all programs.
COMMENT #2: There were two requests for a copy of the rate methodology used by the department to set the case management rates.
RESPONSE #2: The rate methodology has been put on the department's web site and can be found at www.dphhs.mt.gov/amdd/services/index.shtml.
COMMENT #3: A commenter stated the data used in setting rates was for Fiscal Year 2008 which is too old.
RESPONSE #3: The time study was started January 5, 2009. The Addictive and Mental Disorders Division did not receive all of the results until April 2009. AMDD requested the most current data on employee wages and benefits and used paid claims in FY 2009 to determine the adjusted rate.
/s/ Geralyn Driscoll /s/ Anna Whiting Sorrel
Rule Reviewer Anna Whiting Sorrell, Director
Public Health and Human Services
Certified to the Secretary of State March 14, 2011