CONSUMER DIRECTED SERVICES TAX REMINDER

August 21, 2018

The Missouri Medicaid Audit and Compliance (MMAC) unit conducts post-payment reviews (audits) of Medicaid-enrolled providers’ billing.  As a service to our enrolled providers, MMAC wishes to remind providers of the requirements to file and pay taxes.   

 

Consumer Directed Services (CDS) providers/vendors are required to pay taxes on behalf of the participant. You may find the requirements in the following areas:

Paragraph 5.25 of your company’s Participation Agreement for Home and Community Based Care to provide Consumer Directed Services requires you to “… perform all services under this Agreement in compliance with this Agreement and in compliance with all applicable state and federal statutes and all regulations lawfully promulgated.”

 

19 CSR 15‐400(2) states “Vendors shall perform, directly or by contract, payroll and fringe benefit accounting functions for consumer, including but not limited to: (C) Ensuring all payroll, employment and other taxes are paid timely.”

 

The three main oversight entities who the provider will deal with are the Internal Revenue Service (IRS), Missouri Department of Revenue (DOR) and Division of Employment Security. Providers are also responsible for City taxes, if applicable.

 

The EIN number is not the property of the CDS provider but belongs to the participant. When a participant changes providers, the current provider should notify the IRS, DOR and Division of Employment Security that they are no longer serving the participant. When the provider receives a release from the new provider, they should supply the requested information.  It’s MMAC’s expectation that providers work in a cooperative effort to make this a seamless process.

 

Documentation of paid taxes must be maintained by the provider for five (5) years in a secure location that is easily accessible so the documents may be produced for audit purposes.

 

Helpful websites:

IRS:   https://www.irs.gov/filing

DOR:   https://openforbiz.mo.gov/

Division of Employment Security:   https://labor.mo.gov/des

IRS number the participant can call if they have lost or misplaced their EIN – 800-829-4933

EHR AND EVV SYSTEMS DOCUMENTATION

August 16, 2018

MMAC employees conduct announced or unannounced reviews (audits) of MO HealthNet providers to collect documentation supporting claims that were submitted for services provided to Medicaid participants.  Providers are increasing utilization of Electronic Health Record (EHR) and/or Electronic Visit Verification (EVV) systems to generate and retain their documentation of services provided.  Those records are usually pulled up on the EHR or EVV system by one of the provider’s authorized users and then transferred onto a CD, DVD, or thumb drive for MMAC personnel.

 

MMAC is noticing that the staff responsible for managing providers’ EHR and/or EVV systems frequently encounter difficulties producing the requested records during MMAC’s visit.  MMAC encourages all MO HealthNet providers to make sure appropriate staff are familiar with their EHR or EVV system and know how to retrieve and transfer records for specified Medicaid participants and service dates.