Each year, Missouri Medicaid Audit and Compliance (MMAC) sends “DRA Attestations” to Medicaid providers that received at least five (5) million dollars in annual Medicaid payments during the previous federal fiscal year.
The Deficit Reduction Act (DRA) of 2005 states that those providers (receiving at least $5 million in payments) shall:
establish written policies for all employees about the False Claims Act include provisions in those policies about how to detect and prevent fraud, waste, and abuse, and include this information in any employee handbook
State regulation requires Medicaid providers to make an annual attestation of compliance with these requirements, by March 1 of each year. If you received an annual attestation form and have not completed it and returned it to MMAC, you will receive a second notice, providing you with another opportunity to comply. MMAC encourages providers who receive the annual attestation to complete it and return it, in order to avoid any possible sanctions.
Click here to read the regulation.
Click here to read about the Deficit Reduction Act.
If you have any questions, please contact MMAC at dss.mmac.compliance@dss.mo.gov
Medicaid providers have expressed concern to Missouri Medicaid Audit and Compliance (MMAC) about accessing their Electronic Health Records (EHR) during an audit. Some providers have been unfamiliar with the process to access the records due to having a newly acquired EHR system.
Per state regulation, providers may maintain records in an electronic medium, and paper records may be transferred to an electronic medium, as well, as long as all information contained in the original record, including signatures, handwritten notations, or pictures, is contained in the durable medium. Records may be retained in any form that can be made available for review at the same site at which the service was provided or at the provider’s address of record with the Department of Social Services.
Copies of records must be provided upon request regardless of the media in which they are kept. Providers are encouraged to be familiar with their EHR systems and know how to produce the records upon request. Electronic records do not need to be printed off in paper form for MMAC during an audit; electronic form is preferable. MMAC auditors will accept the records in electronic form on a CD, DVD, or portable drive.
Missouri Medicaid Audit and Compliance (MMAC) has seen a recent increase in fraudulent prescriptions passed across Missouri. The prescriptions contain similarities, listed below, and illustrated in a sample template.
(click here to view the template)
Common characteristics of the fraudulent prescriptions:
St. Louis area prescribers Prescriptions are usually written for Oxycodone-Acetaminophen 10-325 for quantities of 120-180 tablets Patient addresses are invalid. The invalid street addresses are usually in the same city as the pharmacy where the prescriptions are presented Prescriptions usually presented to the pharmacy after the doctors’ offices have closed Some were presented on tamper-resistant paper.
Unless an exception exists, MO HealthNet prescriptions must be written on tamper-resistant paper. (Exceptions include prescriptions reimbursed by a MO HealthNet managed care entity, prescriptions provided in certain facilities such as nursing facilities and hospitals, and prescriptions faxed, telephoned, or e-prescribed.) As a reminder, to be compliant with this requirement, a prescription pad must contain the following characteristics:
An industry-recognized feature designed to prevent unauthorized copying of a completed or blank prescription form (such as a high security watermark on the reverse of the blank or the use of thermochromic ink) An industry-recognized feature designed to prevent erasure or modification of information written on the prescription by the prescriber (such as tamper-resistant background ink that shows erasures or attempts to change written information) An industry-recognized feature designed to prevent the use of counterfeit prescription forms (such as sequentially numbered blanks or duplicate or triplicate blanks)As noted above, some of the fraudulent prescriptions were presented on tamper-resistant paper, , highlighting the need to check for all three required features.If you suspect prescription fraud regarding a Medicaid participant, please contact MMAC.LOCKIN@dss.mo.gov or call (573) 751-3399). As well, if you suspect any person is breaking the law in your pharmacy, contact local law enforcement.
If you have any questions, please contact MMAC at MMAC.REPORTFRAUD@dss.mo.gov
Missouri Medicaid Audit and Compliance (MMAC) receives questions from Medicaid providers about our audit procedures. Click here to view audit information and guidance. The audit information and guidance covers commonly used terms, important information found in state regulation, and MMAC audit procedures.
