Indiana Medicaid Releases Proposed Rule for Overhaul of Medicaid Integrity Requirements

By: Christa Roberts, PT, MPT, RAC-CT and Eleisha Wilkes RN, RAC-CT

The details of proposed rule LSA #18-251 were published on October 4, 2018 by the Indiana Family and Social Services Administration, and introduces plans to revamp the Medicaid program integrity requirements. LSA #18-251 is extensive and impacts the bulk of business facets for Indiana Medicaid providers, including claims filing time limits, medical record retention, provider enrollment, sanctions, audits, and provider appeals.

LSA #18-251 consolidates existing rules, clarifies requirements and adds new program integrity requirements affecting Medicaid providers. Some of the more significant changes are as follows:

Currently, providers have up to one year from the date of service to submit an original claim; however, under the proposed rule, providers would have to submit claims for payment within 180 days of the date of service or the claim would be denied (effective January 1, 2019).
Providers will be subject to a medical record retention for financial records period of 3 years following submission to Indiana Medicaid (there is currently no record retention policy).
The proposed rule consolidates and adds new provider enrollment requirements.
Medicaid payment suspension procedures authorized by Federal law are outlined.
A new section is added regarding provider exclusions and readmissions (specifically, the rule lists various offenses that could result in an exclusion and sets a duration of up to 3 years for such exclusion).
A new section describes prepayment review processes and procedures (previously only available in agency manuals).
The proposed rule revises existing Medicaid overpayment provisions to align with changes in Indiana law (adds a 3-year look back period for audits initiated after July 2, 2019, though may be extended to 7 years under certain circumstances).
Administrative appeals procedures are consolidated and changed to align with Indiana law.

LSA #18-251 is open for public comment until the public hearing, which is preliminarily scheduled for October 26, 2018. A copy of the proposed rule can be reviewed at: www.in.gov/legislative/iac/20181003-IR-405180251PRA.xml.pdf