Comments are needed from PCPA members on the Centers for Medicare and Medicaid Services (CMS) Interim Final Rule with comment period, Medicaid Program; Optional State Plan Case Management Services, that were issued in the December 4, 2007 Federal Register (http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/pdf/07-5903.pdf).
PCPA will submit comments by the deadline. Regardless of comments, the rule is scheduled to be effective March 3. Please submit comments to Betty Simmonds for inclusion with PCPA. Please also consider commenting directly to CMS as the volume of comments is important. PCPA would appreciate a copy of comments submitted directly to CMS by members. Comments should refer to file code CMS-2237-IFC and may be submitted electronically or by regular mail. Electronic submission is made through www.cms.hhs.gov/eRulemaking. Select the link Submit electronic comments on CMS regulations with an open comment period. CMS prefers that the attached comments submitted be in Microsoft Word format. Comments can be mailed with one original and two copies to:
Centers
for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-2237-IFC
PO Box 8016
Baltimore, MD 21244-8016
Mailed comments must be received before the close of the comment period on February 4.
The National Council for Community Behavioral Healthcare has identified several particular issues for consideration including the definitions of case management and targeted case management, requirements for a comprehensive assessment, strict separation between case management and service provision, limitation to a single Medicaid case management provider, and submission of a state plan amendment that addresses payment methodology. The Bazelon Center for Mental Health Law has a summary of the regulations available on its web site (www.bazelon.org/issues/medicaid/takeaction/TCMRegsSummary12-20-07.htm) that may be useful in developing comments.
A brief discussion of the regulations is on the agenda for the January Mental Health Committee meeting. Please contact Betty Simmonds with questions or comments about the regulations.
