Community First Services and Supports (CFSS)

Posted: September 26, 2024

· Overview

· Eligible Providers

· Eligible Members

· Roles and Responsibilities

· Service Delivery Models

· Covered Services

· Service Authorization

· Billing

· Submitting CFSS Claims

· Managed Care Members

· Legal References

Overview

Community First Services and Supports (CFSS) offer flexible options to meet the unique needs of Minnesota Health Care Programs (MHCP) members with disabilities. CFSS allows members greater independence in their homes and communities. This includes the elderly and others with special health care needs. CFSS services are provided in members’ homes or in the community when normal life activities take them outside the home. CFSS will replace personal care assistance (PCA) and the Consumer Support Grant (CSG) October 1, 2024. PCA and CSG will be phased out over time. See the CFSS Policy Manual for CFSS policy information.

Eligible Providers

MHCP enrolls and reimburses the following types of provider agencies to provide CFSS services:

· Home health agencies

· CFSS provider agencies

· Consultation services providers

· Financial management services (FMS) providers (CFSS financial tasks, billing and employer-related responsibilities)

· Personal emergency response systems (PERS) providers (See PERS section of the CFSS Policy Manual for eligible provider requirements)

FMS and consultation providers must be contracted with the Department of Human Services (DHS) to provide or bill for CFSS services.

CFSS provider agency enrollment

Provider agencies must do the following to enroll or maintain enrollment with MHCP to provide CFSS services:

· Follow the requirements and steps described in Community First Services and Supports (CFSS) Provider Agency Enrollment Criteria and Forms.

· Complete revalidation when required and report organization or individual provider changes when they occur.

Home health agency enrollment

Home health agencies who wish to provide CFSS, refer to Home Health Agency Enrollment Criteria and Forms.

Enrolling CFSS individual workers

CFSS provider agencies and financial management services (FMS) providers must enroll individual CFSS workers with MHCP and affiliate workers with their provider agency or FMS. Before enrolling and affiliating a worker, the CFSS provider agency or FMS must ensure that each individual CFSS worker:

· Meets the requirements listed in Direct Support Worker (DSW), Individual Enrollment Criteria and Forms.

· Successfully completes individual PCA and CFSS training requirements. DHS will require current CFSS workers with a PCA support worker training certificate dated before April 15, 2020, to obtain a new certificate.

· Does not appear on the Office of Inspector General (OIG) Exclusion list.

· Successfully completes the background study using NETStudy through DHS Licensing.

CFSS provider agencies submit claims to MHCP on behalf of their workers. MHCP pays the agency for CFSS services that individual CFSS workers provide to participants on both fee for service and managed care organization (MCO) plans. MHCP does not pay individual CFSS workers directly.

FMS providers submit claims to MHCP on the behalf of the CFSS participant. See the FMS for CFSS policy manual page.

Noncompete ban

CFSS provider agencies and FMS providers cannot have or enforce any agreements, requirements or noncompete clause prohibiting, limiting or restricting an individual worker from working with a member or different CFSS provider agency or FMS provider after leaving a CFSS provider agency, regardless of the date the agreement was signed.

Eligible Members

MHCP members with eligibility for one of the following MHCP programs are eligible to participate in CFSS services:

AC	Alternative Care Program
EH	Emergency
KK	MinnesotaCare for children 18 years and younger and pregnant women (state funded)
LL	MinnesotaCare for children 18 years and younger and pregnant women (state and federally funded)
MA	Medical Assistance (even if they are also eligible for QM)
NM	State-funded Medica Assistance (MA)
RM	Refugee

Roles and Responsibilities

Lead agencies

CFSS services are person-centered. Members who participate in CFSS services must first request a lead agency (a county, tribal government or managed care organization) to conduct an assessment for CFSS services. A lead agency must conduct an assessment within 20 business days of receiving the request. During the assessment, the assessor determines:

· The CFSS participants’ ability to direct his or her own care, or the need for a representative to act on their behalf.

· CFSS services are appropriate to meet the CFSS participant’s assessed needs.

· Amount of service units or dollars or both that the CFSS participant is eligible for.

Consultation providers

After the lead agency assesses the CFSS services to be appropriate, the participant or participant’s representative (responsible party) will choose a consultation services provider. The consultation services provider assists the participant (member). Refer to CFSS consultation services provider requirements for more information.

CFSS participants or participant representatives

· The member participating in CFSS or the participant’s representative (responsible party) will write the service delivery plan. Refer to Person’s rights and responsibilities in CFSS.

· Their service delivery plan must meet all requirements described on the PCA/CFSS service delivery plan.

· The CFSS participant can choose from two service models (CFSS agency model or CFSS budget model).

Financial management services providers

An FMS provider is an organization that members use to help them with employer-related responsibilities, purchase goods and services and complete other financial tasks. DHS contracts with all FMS providers for these services and enrolls them as Minnesota Health Care Programs (MHCP) providers. For more information about the services, FMS fee and background study see Financial management services (FMS) provider requirements for CFSS

CFSS participants who use the CFSS agency model and do not purchase goods and services do not need to choose an FMS provider.

The following CFSS participants must choose an FMS provider:

· Participants who use the CFSS budget model.

· Participants who use the CFSS agency model who also purchase goods and services.

CFSS provider agencies

CFSS participants who use the CFSS agency model must choose a CFSS provider agency. For more information see PCA/CFSS provider agency requirements overview.

CFSS provider agencies must ensure the supervising professional has the appropriate licensing, certifications and meets appropriate requirements.

CFSS provider agencies must follow the direction of the Minnesota Department of Labor and Industry (DLI) for individual CFSS workers who provide CFSS services. CFSS provider agencies are also responsible for the requirements found in the following:

· PCA/CFSS provider agency worker wage and benefit requirements (agency model only)

· enhanced rate requirements (both agency and budget model)

· parent/spouse requirements (both agency and budget model)

PERS Providers

People who receive CFSS services have the option to purchase personal emergency response systems (PERS) as an electronic backup system. A PERS provider is enrolled with MHCP to provide PERS services (installation and monitoring of the device). For more information, refer to PERS in the CFSS Policy Manual.

Service Delivery Models

The participant will choose between one of the following service delivery models.

CFSS agency model:

· The lead agency authorizes units (1 unit is 15 minutes of service) for the CFSS participant to the CFSS provider agency. The participant (member) or participant’s representative (responsible party) selects a CFSS provider agency that serves as the employer for the CFSS worker. This means the CFSS provider agency is responsible to recruit, hire, train, supervise and pay CFSS support workers.

· The CFSS participant and CFSS provider agency are responsible to monitor the effectiveness of the service delivery plan together.

· If the CFSS participant will purchase goods or services, the participant must also select an FMS provider.

CFSS budget model:

· The lead agency authorizes dollars (the total budgeted amount of money) for the CFSS participant. The participant (member) is the employer of their support workers and will recruit, hire, train and supervise their support workers. The participant will select an FMS provider to help with employer-related tasks.

· The CFSS participant or the participant’s representative is responsible to monitor the effectiveness of the service delivery plan.

If a participant wants to switch CFSS service models:

1. the participant works with their consultation services provider to update their CFSS service delivery plan,

2. the consultation services provider submits the participant’s revised plan to the lead agency for approval, and

3. the lead agency approves the plan and either updates the participant’s service agreement (people receiving waiver or AC services) or submits the PCA/CFSS Request Form (DHS-4292) to request that DHS update the service delivery plan (person not receiving waiver or AC).

The CFSS participant or participant’s representative also chooses whether they want to receive the shared service option for PCA/CFSS, which allows the CFSS participant to receive services from the same individual CFSS worker, at the same time and in the same setting as another participant receiving CFSS services. Participants who share services must use the same service delivery model and the same CFSS provider agency or FMS.

Covered Services

CFSS services are eligible for payment from Medical Assistance:

· The services listed at PCA/CFSS covered personal care services

· Travel time (personal care services)

· Accompanying the CFSS participant into the community to provide covered CFSS personal care services

· Driving the CFSS participant into the community, including to medical appointments

· CFSS agency policies, procedures and agreements with CFSS participants determine whether that agency allows an individual CFSS employee to transport a participant using the CFSS’s or a CFSS participant’s vehicle. CFSS agencies must consult with their legal advisors or business consultants about the liabilities of transporting CFSS participants. (Applies to agency model only.)

· The service delivery plan documents the person’s chosen mode of transportation.

· The provider agency or FMS must meet the documentation requirements described on PCA/CFSS covered personal care services,

· Background Study (personal care services)

· For CFSS workers providing services through the budget model, the FMS provider can include the cost of the CFSS worker’s background study in a personal care (T1019) claim for covered CFSS services performed by that worker. If the background study fails, FMS providers can bill for the failed background study using a specific procedure code and modifiers.

· The CFSS provider agency cannot bill for background studies under the agency model.

· The purchased Goods and Services defined in the CFSS Policy Manual

· In both (agency or budget) models, if the participant wishes to purchase goods and services, the participant must work with the FMS provider to coordinate the purchase.

· CFSS worker training and supervision

· The lead agency authorizes a CFSS worker training and development budget that the worker’s employer (the agency or CFSS participant) can use flexibly to pay for training, observation, monitoring and coaching of CFSS workers.

· Personal Emergency Response Systems (PERS)

· Consultation Services

· FMS services

Service Authorization

All CFSS services require a lead agency assessor to complete a service authorization (SA).

A service authorization allows the provider to provide services and then bill DHS to receive payment. MHCP will pay only services listed on the service authorization. However, an approved service authorization is not a guarantee of payment.

For DHS to pay claims:

· Providers must be actively enrolled and have current credentials to provide the approved service(s).

· The CFSS participant must maintain their MHCP eligibility for the authorization to be valid.

· Providers are responsible for ensuring the service authorization is accurate when they receive their service authorization letters (SAL) in their MN–ITS mailbox.

· Providers must verify program eligibility for each CFSS participant each month through the MHCP phone-based eligibility verification system (EVS) or online via MN–ITS.

CFSS service authorization changes

· Case managers and care coordinators update service authorizations for people who receive waiver or Alternative Care (AC) that also receive CFSS services.

· DHS updates service authorizations for people not on a waiver or AC and not receiving CFSS services through a managed care organization (MCO) when a CFSS provider agency, FMS provider, consultation services provider or lead agency requests a change. Refer to PCA/CFSS service agreement technical changes and corrections in the CFSS Policy Manual.

Billing

All CFSS provider types must follow general MHCP billing policies and guidelines in the Billing Policy section when submitting claims to MHCP.

Documentation

CFSS provider agencies and FMS providers must have documentation supporting that a CFSS worker provided a CFSS service. MHCP requires CFSS provider agencies to ensure that the individual CFSS worker documents all of the minimum requirements by completing the agency’s PCA time and activity documentation process (New form DHS-6893C coming, use PCA form until the new form is available.). CFSS agencies determine the documentation methods used for recording time and activity.

CFSS Provider Agencies

CFSS provider agencies must have all the following documentation on file before submitting a claim to MHCP for reimbursement of a CFSS claim:

· A copy of the CFSS participant’s Assessment (DHS-6893A) (PDF) or the MnCHOICES CFSS Provider Report

· A service authorization for CFSS services

· CFSS time and activity documentation for all individual CFSS support workers delivering services to the member. Refer to electronic visit verification (EVV).

· Any CFSS workers training and supervision

· A written agreement signed by the agency and CFSS participant or participant’s representative

· Shared services agreements signed by all CFSS participants sharing CFSS services (if applicable)

FMS Providers
FMS providers must have the following documentation:

· A written agreement signed by the agency and CFSS participant or participant’s representative.

· Shared services agreements signed by all CFSS participants sharing CFSS services (if applicable).

See the FMS provider documentation and reporting for CFSS in the CFSS Policy Manual.

Consultation Providers
Consultation providers must keep documentation for services they provide. Refer to CFSS consultation services provider requirements in the CFSS Policy Manual.

Submitting CFSS Claims

Bill only for services already provided and approved on the service authorization (SA).

When you submit claims for CFSS services:

· Bill on 837P claim format. Refer to the MHCP MN–ITS 837P Professional User Guides.

· Enter a diagnosis code when submitting claims for CFSS services. Use the most current and approved diagnosis code on the SA.

· Enter the approved service authorization number in the claim. Note: Services that require a service authorization cannot be billed on the same claim as services that do not require an SA.

· Enter one line per date of service, per HCPCS or procedure code and modifier combination.

· T1019 code requires the rendering CFSS worker(s) UMPI/NPI on the service line per date of service.

· Refer to the Community First Services and Supports codes table for a complete list of CFSS codes and modifiers. Some modifiers are claim only and do not require to be on an SA.

· Follow the directions on enhanced rate/budget for all people eligible for the enhanced rate. CFSS provider agencies and FMS providers can verify that a worker is qualified for the enhanced rate by following the steps in the PCA Providers A – Z list.

Managed Care Members

CFSS provider agencies providing CFSS services to eligible participants (members) aged 65 and over who are enrolled in a health plan must follow the managed care organization’s rules and guidelines to enroll with, obtain authorizations and bill the health plan.

For CFSS participants enrolled in the Special Needs BasicCare program and the Medical Assistance for Families and with Children and Adults program, follow fee-for-service guidelines to obtain authorizations.

Legal References

Minnesota Statutes, 245.462 (Definitions)
Minnesota Statues, 256.8 (Community First Services and Supports)
Minnesota Statutes, 256B.04, subdivision 21 (Provider enrollment)