RD922 - Report on Community Service Boards (CSB) Billing for Medicaid Eligible Services – December 1, 2024


Executive Summary:

Community Service Boards (CSBs) bill Medicaid for the majority of Medicaid eligible services they provide. CSBs provide approximately 11 percent of Medicaid behavioral health services statewide and Medicaid payments account for 30 percent of CSB revenue. CSBs have significant documentation burden associated with Medicaid services as well as their numerous other federal, state, and local funding lines and report that these numerous requirements have made the transition to managed care more difficult for CSBs from a documentation and infrastructure perspective. Specifically, the difficulty associated with the transition to managed care include the credentialing process, service authorization process, and general administrative requirements of working with five Medicaid managed care organizations (MCOs). In general, some CSBs have implemented modernized revenue cycle management (RCM) systems to successfully participate as Medicaid providers in the managed care context. This includes increased billing and coding staff, expertise, EHR improvements, and additional back-end systems features. Other CSBs have not achieved this modernization frequently due to resource constraints or competing priorities. Some ambivalence regarding investment in RCM systems appears to be driven by uncertainty regarding the future of CSB payment structures, including the possibility of implementing an alternative payment model for STEP-VA services, such as a prospective payment system (PPS) akin to federal models. Through the review completed for this study, the Department of Medical Assistance Services (DMAS) and Department of Behavioral Health and Developmental Services (DBHDS) provide three recommendations for consideration which include:

1. Follow-up technical assistance for any unbilled Medicaid services and increased collaboration and training opportunities in coordination with MCOs.

2. Implementation of key performance indicators (KPIs) so that billing and claims issues can be tracked at the CSB or state level for more actionable insights.

3. Technical assistance for CSBs on how they can manage their revenue cycles.

A single, required central billing solution is not recommended at this time as no feasible concept for this type of solution emerged during the study. The method for this study focused on a review of the CSBs. The MCOs were not interviewed for this study, but any recommendations that move forward will be implemented collaboratively with MCOs.