Non-Compliance with PCS Service Place Requirements

Author: Long-Term Services and Supports

Effective March 2018, DMA will begin a quarterly review of providers identified as non-compliant with the timely completion of the online Personal Care Services (PCS) service plan as required by Clinical Coverage Policy 3L, State Plan Personal Care Services.

DMA Clinical Policy has partnered with the Office of Compliance and Program Integrity (OCPI) to explore educational options and opportunities to best equip providers with the necessary knowledge to meet policy requirements. In addition, Medicaid Clinical Policy in conjunction with its IT Vendor and Independent Assessment Entity is working to identify providers that are continually non-compliant.

Currently, there are 566 outstanding online PCS service plans that are more than 7 days outstanding and out of compliance with Section 6.1.4 (i) of Clinical Coverage Policy 3L. In addition, there are 426 outstanding on-line PCS service plans that are 14 or more days outstanding and are out of compliance with Section 6.1.4 (j) of Clinical Coverage Policy 3L.

Providers identified as non-compliant will receive a notification which will state Clinical Coverage Policy 3L requirements and indicate that the online PCS service plan must be completed within seven business days of the date on the letter. Failure to comply with Clinical Coverage Policy 3L within the designated seven-day period may result in referral to the OCPI, require face-to-face meetings with representatives of the NC Division of Medical Assistance (DMA), and if non-compliance continues, providers will be subject to the voiding of service authorizations.

Clinical Coverage Policy 3L, State Plan Personal Care Services, Section 6.1.4 (i), requires providers to develop an online Personal Care Services (PCS) service plan through the Provider Interface. The PCS service plan must be developed and validated within seven business days of the provider accepting the Independent Assessment Entity referral.

In addition, Clinical Coverage Policy 3L Section 6.1.4 (j) states that the provider organization shall obtain written consent in the form of signature of the beneficiary or their legally responsible person within 14 business days of the validated service plan. This written consent of the service plan must be printed out and uploaded into the Provider Interface.

The PCS online service plan must be completed any time a provider accepts a beneficiary’s referral and any time there is a change in hours. A change in hours may occur due to:

  • Annual assessments
  • Medical and non-medical change of status requests
  • Mediations
  • Court settlements, and
  • Appeals when Maintenance of Service hours have been granted.

Per policy, prior approval for PCS hours or units is not granted until the online PCS service plan is entered and validated by the Provider Interface.

DMA has provided trainings on the completion of the online PCS service plan since implementation in June 2015. These trainings can be found on the Liberty Healthcare Corp. of NC website. In addition to this training, an extensive list of Frequently Asked Questions directly related to the completion of the online PCS service plan can be found on the Provider Portal (providers must be registered with QiRePort.net to access these questions and answers).

It should be noted that the PCS service plan is not a plan of care as defined by the applicable state licensure requirements that govern the operation of the provider organizations. Provider organizations are expected to complete a separate plan of care in accordance to licensure requirements as specified in 10A NCAC 13F, 13G, 13J and 27G.

Providers with questions regarding the Service Plan Requirement or the PCS Clinical Coverage Policy may contact PCS_Program_Questions@dhhs.nc.gov.

Long-Term Services and Supports
DMA, 919-855-4360

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