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SMAA Program Update June 10, 2016

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Fiscal Year 2014/15 Q3 (Jan-Mar) Invoice Submission Deadline
SMAA invoices for the period of service of state fiscal year (SFY) 2014/15 Quarter 3 are due to the Department of Health Care Services (DHCS) no later than September 30, 2016.  Invoices received after this date may not be processed before the end of the two-year claiming period ending March 31, 2017.
Claiming Reimbursement for LEC/LGA Vendor Fees
In general, if the participation fee that the LECs/LGAs charge to the LEAs to be part of the SMAA program includes the DHCS participation fee, that fee has already been matched with federal funds and cannot be claimed for reimbursement on the LEA invoice.  However, when considering if LECs/LGAs can bill LEAs for certain ancillary services and how those amounts would be treated under the limits on vendor fees, there are essentially three different scenarios that may exist:


1. The LEC/LGA submits a Direct Charge Invoice to the SMAA program and provides vendor type services to LEAs, but does not invoice LEAs for those services – In this scenario, the LEC could include all of its allowable costs on its own invoice to DHCS and CMS would not consider the actual costs incurred as “vendor fees” subject to the 15% limit.


2. The LEC/LGA does not submit a Direct Charge Invoice to the SMAA program but invoices LEAs for vendor type services – In this scenario, because the LEC/LGA is not separately claiming for SMAA costs, CMS would recognize the payments made by the LEAs to the LEC/LGA for these SMAA activities essentially as “vendor payments” and those payments would be allowable costs on the LEA SMAA invoice subject to the 15% limit and other requirements (reasonable/allocable, etc.).


3. The LEC/LGA submits a Direct Charge Invoice to the SMAA program and also bills LEAs for vendor type services – In this scenario, the LEC/LGA must ensure that there are no duplication of costs (direct and/or indirect) between the two invoices (LEC/LGA and LEA).  In theory, the treatment of those costs would be a combination of the two scenarios described above but it may be difficult for the LEC/LGA to show that it did not receive any reimbursement for the costs it separately invoiced to DHCS.  If a LEC/LGA bills Medi-Cal for allowable costs under the SMAA program and then receives reimbursement for those same costs, that receipt should be treated as an applicable credit under Office of Management and Budget (OMB) Circular A-87 and CMS would expect reimbursement (similar to Third Party Liability).  That being said, if what the LECs/LGAs are referring to as a “payment” is simply the transfer back of the non-federal share of their cost, then CMS would treat that in the same manner as the participation fee where the LEA could not claim that transfer of funds on its invoice.

Last modified on: 6/10/2016 9:15 AM