8.100 INTERNAL APPEALS, GRIEVANCES, NOTICES,
AND STATE FAIR HEARINGS ON MEDICAID SERVICES
(06/01/2018, GCR 17-090)
8.100.1 Introduction and Applicability
Rule 8.100 implements the responsibilities of the Medicaid
Program pursuant to 42 CFR § 438, Subpart F, regarding a grievance and
internal appeal system for Medicaid beneficiaries seeking Medicaid services The
rule also sets forth requirements for Notices of an Adverse Benefit
Determination, continuing services pending appeal and potential beneficiary
liability, and responsibilities regarding State fair hearings [1 ]
The services listed below are not subject to the grievance
rule at 8.100.8 and the internal appeal rule at 8.100.4. A Medicaid beneficiary
may request a State fair hearing, pursuant to 8.100.5, regarding these
services.
(a) Services funded with
state-only dollars because federal participation is prohibited, and
(b) Services that are a coverage exception to
Medicaid covered services.
For rules that govern Medicaid applicant and beneficiary
appeals regarding financial, non-financial, and categorical eligibility for
community Medicaid and Medicaid for long-term care services and supports and
Medicaid premium determinations, refer to Health Benefit Eligibility and
Enrollment Rules at Code of Vermont Rules 13-001-001 to 13-001-008.
8.100.2 Definitions
The following definitions shall apply for use in
8.100:
(a) "AHS" means the Agency of
Human Services as the Medicaid Single State Agency.
(b) "Authorized Representative" means an
individual, either appointed by a beneficiary or authorized under State or
other applicable law, to act on behalf of the beneficiary in the internal
appeal, grievance, or State fair hearing processes as permitted pursuant to 42
CFR § 435.923. Unless otherwise stated in law, the authorized
representative has the same rights and responsibilities as the beneficiary in
obtaining a benefit determination or in dealing with the internal appeal,
grievance, and State fair hearing processes.
(c) "Designated Agency/Specialized Service
Agency" means an agency designated or deemed by the Department of Mental Health
or the Department of Disabilities, Aging, and Independent Living to provide and
administer services, including service authorization decisions, for
beneficiaries with mental health needs or developmental disabilities.
(d) "Final Administrative Action" means a
final AHS order entered by the Human Services Board or, if the Secretary of AHS
reverses the order of the Human Services Board pursuant to
3 VSA §
3091(h), then the
Secretary's order.
(e) "Grievance"
means an expression of dissatisfaction about any matter that is not an adverse
benefit determination, including a beneficiary's right to dispute an extension
of time proposed by the Medicaid Program and the denial of a request for an
expedited appeal.
(f) "Internal
Appeal" means an internal review by the Medicaid Program of an adverse benefit
determination.
(g) "Medicaid
Program" means
(1) DVHA in its managed care
function of administering services, including service authorization decisions,
under the Global Commitment to Health Waiver ("the Waiver"),
(2) a State department of AHS (i.e.,
Department for Children and Families; Department of Disabilities, Aging, and
Independent Living; Department of Health; and Department of Mental Health) with
which DVHA enters into an agreement delegating its managed care functions
including providing and administering services such as service authorization
decisions, under the Waiver,
(3) a
Designated Agency or a Specialized Service Agency to the extent that it carries
out managed care functions under the Waiver, including providing and
administering services such as service authorization decisions, based upon an
agreement with a State department of AHS, and
(4) any subcontractor performing service
authorization decisions on behalf of a State department of AHS.
(h) "Provider" means a person,
facility, institution, partnership, or corporation licensed, certified or
authorized by law to provide services to a beneficiary.
(i) "State Fair Hearing Request" means a
clear expression, either orally or in writing, by a beneficiary to have a
decision by the Medicaid Program reviewed by the Human Services
Board.
8.100.3 Notice
Requirements
(a) General Requirements for
Notices Sent by the Medicaid Program or AHS Pursuant to 8. 100: The notice
shall be compliant with 42 CPR § 438.10 including that the notice shall
be:
(1) Written unless otherwise specified by
this rule,
(2) In plain
language,
(3) Accessible for
persons with limited English proficiency.
(A)
Persons with limited English proficiency shall be provided language services at
no cost to the individual, including:
(i)
Oral interpretation,
(ii) Written
translations,
(iii) Taglines in
non-English languages, including the availability of language services,
and
(4)
Accessible for persons with disabilities.
(A)
Individuals with disabilities shall be provided with auxiliary aids and
services at no cost to the individual, in accordance with the Americans with
Disabilities Act and Section
504
of the Rehabilitation Act.
(b) Notice of Adverse Benefit Determination:
The Medicaid Program shall provide the beneficiary with timely and adequate
written notice of an adverse benefit determination.
(1) Content of notice of adverse benefit
determination: A notice of adverse benefit determination shall contain clear
statements of the following:
(A) An
explanation of the adverse benefit determination the Medicaid Program has taken
or intends to take,
(B) The reason
for the adverse benefit determination,
(C) The specific rule that supports the
adverse benefit determination,
(D)
The right to appeal, including how to request an internal appeal and the
timeframe,
(E) An explanation of
when there is a right to request a State fair hearing, including the exhaustion
requirement and when exhaustion is deemed,
(F) The circumstances under which an appeal
will be expedited and how to request it,
(G) The right to have services continue
pending resolution of the appeal, including how to request continuing services,
the timeframe for requesting continuing services, and under what circumstances
the beneficiary may be required to pay the costs of services that are provided
pending resolution of the appeal,
(H) The methods for requesting an appeal and
procedures for exercising other rights in 8.100.4, and
(I) The right of the beneficiary to be
provided, upon request and free of charge, reasonable and timely access to and
copies of all documents, records, and other information relevant to the
beneficiary's adverse benefit determination, including medical necessity
criteria and any processes, strategies, or evidentiary standards used in
setting coverage limits.
(2) Timing of Notice of Adverse Benefit
Determination, Including When Advance Notice is Required: The Medicaid Program
shall mail the notice within the following timeframes:
(A) For a termination, suspension, or
reduction of a previously authorized service, at least 11 days before the
change will take effect.
(B) For
denial of payment, at the time of any action affecting the claim.
(C) For standard service authorization
decisions that deny or limit services, as expeditiously as the beneficiary's
health requires but not more than 14 days following receipt of the request for
service.
(D) For expedited service
authorization decisions, as expeditiously as the beneficiary's health requires
but not more than 72 hours after receipt of the request for service.
(E) For service authorization decisions not
reached within the proper timeframes described in paragraphs (C) and (D) above,
on the date that the timeframe expires.
(i)
Service authorization decisions not reached within the proper timeframes
constitute a denial and thus are an adverse benefit determination.
(F) If the Medicaid Program meets
the criteria for extending the timeframe for standard and expedited service
authorizations, it shall:
(i) Give the
beneficiary written notice of the reason for the decision to extend the
timeframe and inform the beneficiary of the right to file a grievance ifs/he
disagrees with the decision to extend the timeframe, and
(ii) Issue and carry out its decisions as
expeditiously as the beneficiary's health condition requires and no later than
the date the extension expires.
(c) Notice of Resolution of lnternal Appeal
(1) Content of notice of resolution of
internal appeal
(A) The written notice shall
include clear statements of the following:
(i) The decision, including the basis for the
decision, in sufficient detail for the beneficiary to understand the decision,
(ii) A summary of the
beneficiary's appeal,
(iii) A
summary of the evidence or documentation used by the reviewer in making the
decision, including clinical review criteria used to make a decision relating
to medical care,
(iv) The date the
decision was completed and the effective date of the decision,
(v) The telephone number of the Health Care
Advocate at Vermont Legal Aid, Inc., and
(B) For appeals not resolved wholly in favor
of the beneficiary:
(i) The right to request a
State fair hearing, how to request a fair hearing, and the timeframe for doing
so,
(ii) The circumstances in
which a State fair hearing will be expedited and how to request it,
(iii) The right to have services-continue
pending resolution of the State fair hearing including how to request
continuing services and the timeframe for doing so,
(iv) The timeframes, whether standard or
expedited, in which AHS, which may include the Human Services Board, must take
final administrative action, and
(v) That the beneficiary may, consistent with
State policy, be held liable for the cost of continued services if the State
fair hearing process results in a final administrative decision that upholds
the Medicaid program's adverse benefit determination.
(d) Notice of
Resolution of Grievance: The Medicaid Program's written notice of resolution of
a grievance shall contain clear statements of the following:
(1) The decision, including the basis or
other rationale for the decision in sufficient detail for the beneficiary to
understand the decision,
(2) A
summary of the grievance,
(3) The
telephone number of the Health Care Advocate at Vermont Legal Aid, Inc.,
and
(4) If the decision is adverse
to the beneficiary, the notice must inform the beneficiary of his/ her right to
initiate a grievance review pursuant to 8.100.8U) and explain how to do so.
8.100.4
Internal Appeals
(a) Internal Appeal System:
The Medicaid Program shall maintain an internal appeal system, including an
expedited appeal process, for a beneficiary to appeal an adverse benefit
determination. The system shall not have more than one level of internal
appeal.
(b) Right to Internal
Appeal; Exception for Change in Law
(1) A
beneficiary may file an internal appeal of an adverse benefit determination
with the Medicaid Program.
(2)
There is no right to an internal appeal when the sole issue is a federal or
state law requiring an automatic change adversely affecting some or all
beneficiaries.
(c)
Provider Decisions: Network provider decisions that do not require a service
authorization are not adverse benefit determinations of the Medicaid Program
and are not subject to the internal appeal process.
(d) Exhaustion Requirement; Deemed
Exhaustion; Request for Review Made to Human Services Board Prior to Exhaustion
(1) Exhaustion Requirement: A beneficiary may
only request a State fair hearing after receiving notice of resolution of an
internal appeal under 8.100.3(c) that the Medicaid Program upheld an adverse
benefit determination, except that the beneficiary shall be deemed to have
exhausted the internal appeal process pursuant to paragraph (d)(2)
below.
(2) Deemed exhaustion: If
the Medicaid Program fails to comply with the requirements regarding notice
content and timing at 8.100.3(c) and 8.100.4(n), (o) and (p), exhaustion of the
internal appeal process shall be deemed and a beneficiary may immediately
request a State fair hearing.
(3)
Request for Review Made to Human Services Board Prior to Exhaustion: If a
beneficiary wrongly files a request for review with the Human Services Board
prior to exhausting the internal appeal process, where exhaustion is required,
AHS and the Medicaid Program shall provide the beneficiary with appropriate
assistance with filing an internal appeal with the Medicaid Program.
(e) Filing of lnternal Appeal,
Including Time for Appealing
(1) Who May File
Internal Appeal: A beneficiary or, as state law permits and with the written
consent of the beneficiary, a provider or authorized representative (if not
already specified in authorized representative's scope of authority), may
initiate an internal appeal.
(A) When
"beneficiary" is used in 8.100.4, it includes providers and authorized
representatives except that providers may not request that services be
continued pending appeal.
(2) How to Appeal: An internal appeal may be
filed orally or in writing.
(A) An oral
inquiry seeking to appeal an adverse benefit determination shall be treated as
an appeal for purposes of establishing the filing date for the
appeal.
(B) A beneficiary must
follow an oral appeal with a written appeal except when the beneficiary
requests expedited resolution of the appeal. The Medicaid Program shall have
discretion to find that a beneficiary has good cause for not following an oral
appeal with a written appeal.
(3) Time for Filing Appeal: A beneficiary
must file an appeal with the Medicaid Program within 60 days of the date the
Medicaid Program mailed the notice of adverse benefit determination. The date
of the appeal, if mailed, and the date the Medicaid Program mailed the notice
of adverse benefit determination, is the postmark date. For adverse benefit
determination notices that are mailed by the Medicaid Program, the postmark
date is one business day after the date of the notice.
(f) No Punitive Action Against Providers: The
Medicaid Program shall ensure that no punitive action is taken against a
provider who requests or supports a beneficiary's internal appeal.
(g) Assistance with Appeal and Requesting a
State Fair Hearing:
(1) The Medicaid Program
shall:
(A) Give beneficiaries any reasonable
assistance in initiating and participating in the internal appeal and the State
fair hearing processes including by helping the beneficiary to submit his/ her
request. Help shall include completing forms and taking other necessary steps,
(i) Assistance includes auxiliary aids and
services upon request, such as providing interpreter services and toll-free
numbers that have adequate TTY/TTD and interpreter capability.
(B) Provide appropriate assistance
in filing a request for a State fair hearing to any beneficiary who wrongly
filed a request for review with the Human Services Board prior to exhaustion of
the internal appeal, if the beneficiary wishes to pursue a State fair hearing,
and
(C) Respond to any clear
indication (oral or written) that a beneficiary wishes to present his/ her case
to a reviewing authority by helping the beneficiary to submit a request for an
internal appeal (or a State fair hearing, where appropriate).
(2) Request for Review by Human
Services Board Prior to Exhaustion: See 8.100.4(d)(3)
(h) Written Acknowledgement of Appeal: The
Medicaid Program shall mail acknowledgement of the appeal to the beneficiary
within five days of its receipt of the appeal.
(i) Withdrawal of Appeal: Appeals may be
withdrawn orally or in writing at any time.
(1) If an internal appeal is withdrawn
orally, the Medicaid Program shall acknowledge the withdrawal in writing within
five days.
(j) Parties
to the Appeal: The parties to an internal appeal are the beneficiary or his/her
authorized representative, or the legal representative of a deceased
beneficiary's estate.
(k)
Information to Resolve Appeal: The Medicaid Program shall act promptly and in
good faith to obtain any necessary information to resolve the appeal. For
purposes of this paragraph, "necessary information" may include the results of
any face-to-face clinical evaluation or second opinion that, may be required.
(l) Appeals Reviewer: Individuals
who make a decision on an internal appeal:
(1)
Shall not have been involved in any previous level of review or decision
making, nor be a subordinate of any such individual, *
(2) Shall have appropriate clinical expertise
in treating the beneficiary's condition or disease when deciding an appeal of a
denial based on medical necessity, and
(3) Shall consider all comments, documents,
records, and other information submitted by the beneficiary or his/her
representative or provider without regard to whether such information was
submitted or considered in the initial adverse benefit determination.
(m) Internal Appeal Process
(1) Participation in Appeal Meeting: The
beneficiary, his/her authorized representative, or his/ her provider, if
requested by the beneficiary, has the right to participate in person, by phone,
or in writing in the meeting in which the Medicaid Program is considering the
issue that is the subject of the appeal. Participation includes the right to
present evidence and testimony and make factual and legal arguments.
(A) The Medicaid Program shall inform the
beneficiary of the time available for participation in the internal appeal
sufficiently in advance of the resolution timeframe for the appeal including,
if an appeal meeting will be held, sufficiently in advance of the
meeting.
(2) Submission
of Information: The beneficiary, the authorized representative, or the provider
may submit additional relevant information that supplements or clarifies
information that was previously submitted.
(3) Right to Examine and Get Copies of
Record: Prior to the appeal meeting; the Medicaid Program shall timely provide
the beneficiary, his/her authorized representative, or his/her provider with an
opportunity to examine, and, if requested, get copies of all the information in
its possession or control relevant to the appeal process and the subject of the
appeal. The Medicaid Program shall not charge the beneficiary for copies of any
records or other documents necessary to resolve the appeal. These records shall
include:
(A) The beneficiary's case record,
including medical records, other records and documents, and any new or
additional evidence considered, relied on, or generated by the Medicaid
Program, or at its direction, that is related to the appeal, and
(B) Other information relevant to the
beneficiary's adverse benefit determination, including relevant policies or
procedures which shall include medical necessity criteria and any processes,
strategies, or evidentiary standards used in setting service limits.
(4) Scheduling the Appeal Meeting:
The Medicaid Program shall timely notify the beneficiary when the appeal
meeting is scheduled. If necessary, the appeal meeting will be rescheduled to
accommodate individuals wishing to participate.
(A) If an appeal meeting cannot be scheduled
within the timeframe for resolving the appeal, including if the timeframe is
extended pursuant to paragraph (o) below, the Medicaid Program shall make a
decision that resolves the appeal without a meeting with the beneficiary,
his/her authorized representative, or provider. The beneficiary, his/her
authorized representative, or provider shall have an opportunity to submit
evidence and argument by other means to the appeals reviewer for consideration
in making a decision.
(n) Standard Time for Resolution of lnternal
Appeal
(1) The Medicaid Program shall decide
an internal appeal and provide written notice as expeditiously as the
beneficiary's health condition requires, but not longer than 30 days after it
receives the appeal.
(o) Extension of Time to Resolve Internal
Appeal
(1) The Medicaid Program may extend
the time for resolving an internal appeal by up to 14 days under the following
circumstances:
(A) By request of the
beneficiary, or
(B) If the Medicaid
Program shows that there is need for additional information and how the delay
is in the best interest of the beneficiary.
(2) If the extension is not at the request of
the beneficiary, pursuant to paragraph (l)(A) above, the Medicaid Program
shall:
(A) Make a reasonable effort to give
the beneficiary prompt oral notice of the delay,
(B) Give the beneficiary written notice,
within two days of a decision based on paragraph (l)(B) above, of the reason
for its decision to extend the time and an explanation of the right to file a
grievance if the beneficiary disagrees with the decision, and
(C) Resolve the appeal as expeditiously as
the beneficiary's health requires and no later than the date the extension
expires.
(3) Maximum
Time for Resolution of Appeals
(A) The maximum
time, including any extensions, is:
(i) 44
days for standard resolution of an appeal (30 days plus 14 days), or
(ii) 17 days for expedited resolution of an
appeal (72 hours plus 14 days).
(p) Expedited Resolution of Internal Appeal
(1) The Medicaid Program shall have an
expedited process for resolving internal appeals when:
(A) It determines that the standard for
expedited resolution is met, when the request is from the beneficiary,
or
(B) The provider indicates that
the standard for expedited resolution is met, when a provider makes a request
on a beneficiary's behalf or supports a beneficiary's request.
(2) Standard for Expedited
Resolution: The standard for expedited resolution of an internal appeal is that
taking the time for a standard resolution could seriously jeopardize the
beneficiary's life, physical or mental health, or ability to attain, maintain,
or regain maximum function.
(3)
Denial of Request for Expedited Resolution of Appeal, Including Timeframe
(A) If the Medicaid Program determines that
the standard for an * expedited appeal is not met, the Medicaid Program shall:
(i) Resolve the appeal in accordance with the
standard timeframe,
(ii) Make
reasonable efforts to give the beneficiary prompt oral notice of the denial,
and
(iii) Send written notice of
the reason for the denial to the beneficiary within two days of the oral
notice. The notice shall explain that the request does not meet the criteria
for expedited resolution, that the appeal will be processed within the standard
30-day timeframe, and give notice of the right to file a grievance of the
denial of the request for expedited resolution.
(4) Approval of Request for
Expedited Resolution of Appeal, Including Timeframe
(A) If the Medicaid Program determines that
the expedited appeal request meets the standard for expedited resolution, the
Medicaid Program shall resolve the appeal and notify the beneficiary of the
decision within 72 hours of its receipt of the expedited appeal. The Medicaid
Program shall make reasonable efforts to give the beneficiary prompt oral
notice of the denial which shall be followed by written notice.
(5) Right to Expedited State Fair
Hearing: A beneficiary may request an expedited State fair hearing pursuant to
8.100.5(k) when the Medicaid Program approved the request for expedited
resolution of an internal appeal:
(A) But the
decision is wholly or partially adverse to the beneficiary, or
(B) The expedited internal appeal is not
timely resolved by the Medicaid Program.
(q) Notice of Resolution of lnternal Appeal:
See 8.100.3(c).
8.100.5
State Fair Hearings
(a) State Fair Hearing
System: AHS shall maintain a fair hearing system, including an expedited fair
hearing process, that meets the requirements of the United States Constitution,
the Vermont Constitution, 42 CFR § 431, Subpart E, the due process
standards set forth in Goldberg v. Kelly, 397 U.S. 254 (1970), the Americans
with Disabilities Act of 1990, Section
504
of the Rehabilitation Act of 1973, and Section 1557 of the Affordable Care Act,
and implementing regulations.
(b)
State Fair Hearing Entity: The Human Services Board is an independent part of
AHS that is designated by state law to conduct State fair hearings when the
final resolution of an internal appeal is adverse to the beneficiary. [2 ]
(c) Other Applicable Rules: pair
hearings shall be conducted in accordance with rules promulgated by the Human
Services Board pursuant to
3 VSA §
3091(b). [3 ]
(d) Notification of State Fair Hearing Rights
(1) AHS shall issue and publicize its hearing
procedures.
(2) AHS shall, at the
times specified at paragraph (d)(3) below, inform every applicant or
beneficiary in writing of the following:
(A)
The right to a State fair hearing and right to request an expedited State fair
hearing;
(B) The methods for
requesting a State fair hearing,
(C) That the beneficiary can represent him or
herself or use counsel, a relative, a friend, or other spokesperson,
and
(D) The timeframes in which AHS
must take final administrative action on a State fair hearing
request.
(3) AHS shall
provide the information at paragraph (d)(2) above:
(A) At the time an individual applies for
Medicaid, and
(B) When a
beneficiary requests a State fair hearing.
(e) Right to a State Fair Hearing; Exhaustion
Requirement: Except for a beneficiary who seeks review of a service not subject
to the internal appeal process pursuant to 8.100.1, a beneficiary shall have a
right to request a State fair hearing only after exhausting the internal appeal
process or ifs/he is deemed to have exhausted the process pursuant to
8.100.4(d).
(f) When a Hearing is
Required; Exception: AHS shall grant an opportunity for a hearing to any
beneficiary who is dissatisfied with the final resolution of the internal
appeal. There is no right to a hearing if the sole issue is a state or federal
law requiring an automatic change adversely affecting some or all
beneficiaries. A beneficiary retains the right to a State fair hearing in an
appeal of the application of the law to the facts of an individual's
case.
(g) Filing of State Fair
Hearing Requests, Including Ongoing Continuing Services, and Timeframe
(1) Who May Request a State Fair Hearing: A
beneficiary may request a State fair hearing, and a provider or an authorized
representative may request a State fair hearing on behalf of the beneficiary,
as consistent with state law and with the written consent of the
beneficiary.
(2) How to Request a
State Fair Hearing and ongoing continuing services:
(A) A beneficiary may request a State fair
hearing and ongoing continuing services orally or in writing:
(i) By telephone,
(ii) Via mail,
(iii) In person,
(iv) -Via the internet, and
(v) Through other commonly available
electronic means.
(B)
Time for Requesting a State Fair Hearing and ongoing continuing services: A
beneficiary must request a State fair hearing within 120 days of the date the
Medicaid Program mailed the notice of resolution of the internal appeal, or,
when regarding services not subject to the internal appeal process pursuant to
8.100.1, within 120 days from the date the Medicaid Program mailed the notice
of decision. A beneficiary who is receiving continuing services must request a
State fair hearing and the continuation of services pending the outcome * of
the State fair * hearing within 11 days after the Medicaid-Program mails the
notice of resolution of the internal appeal. The date of mailing by the
Medicaid Program is the postmark date. The postmark date is one business day
after the date of the notice.
(h) AHS Responsibilities Related to State
Fair Hearing Requests: AHS shall:
(1) Assure
that the methods for requesting a State fair hearing include an opportunity for
the beneficiary to request an expedited State fair hearing,
(2) Assist the beneficiary in submitting a
State fair hearing request, and
(3)
Not limit or interfere with a beneficiary's freedom to request a State fair
hearing.
(i) Parties to
the State Fair Hearing: The parties to the State fair hearing are the Medicaid
Program and the beneficiary or his/her authorized representative or the legal
representative of a deceased beneficiary's estate.
(j) Standard Timeframe for Final
Administrative Action [4; ] Extension of Time
(1) AHS, which may include the Human Services
Board, shall take final administrative action within 90 days from the date the
beneficiary filed an internal appeal with the Medicaid Program, not including
the number of days the beneficiary took to subsequently file for a State fair
hearing. For services not subject to the internal appeal process pursuant to
8.100.1, AHS shall take final administrative action within 90 days from the
date the beneficiary requests a State fair hearing.
(2) Extension of Time: AHS, which may include
the Human Services Board, shall take final administrative action within the
timeframes in paragraph U)(l) above except in unusual circumstances. If there
are unusual circumstances, AHS shall document the reason for the delay in the
beneficiary's record. Unusual circumstances occur when:
(A) AHS cannot reach a decision because the
beneficiary requests a delay or fails to take an action that is required for
resolution of the State fair hearing request, or
(B) There is administrative or other
emergency that is beyond the control of AHS.
(k) Expedited Resolution of State Fair
Hearing, Including Timeframe
(1) Standard for
Expedited Resolution: AHS shall maintain an expedited State fair hearing
process for a beneficiary to request expedited resolution of a State fair
hearing when the Medicaid Program has determined that the time for standard
resolution may jeopardize the beneficiary's life, health, or ability to attain,
maintain, or regain maximum function.
(A)
Right to Expedited State Fair Hearing: A beneficiary may request expedited
resolution of a State fair hearing when the Medicaid Program has determined
that the standard for such resolution, described at paragraph (k)(l) above has
been met, and, for services that are subject to the internal appeal process:
(i) The Medicaid Program did not adhere to
the time limit for resolution for an expedited internal appeal, or
(ii) The Medicaid Program timely resolved the
expedited internal appeal but the notice of resolution was wholly or partially
-adverse to the beneficiary.
(2) Time for Expedited Resolution: AHS, which
may include the Human Services Board, shall take final administrative action as
expeditiously as the beneficiary's health requires but not later than three
working days after AHS receives, from the Medicaid Program, the case record and
information for an appeal that the Medicaid Program indicates met the standard
for expedited appeal.
(3)
Extension of Time for Resolution: AHS, which may include the Human Services
Board, must take final administrative action within the timeframe in paragraph
(k)(2) above except in unusual circumstances. Unusual circumstances are defined
at paragraph U)(2) above. If there are unusual circumstances, AHS may extend
the time for resolution consistent with paragraph U) (2) above: AHS shall
document the reason for the delay in the beneficiary's record.
(l) Request for Review Made To
Human Services Board Prior to Exhaustion: See 8.100.4(d)(3)
8.100.6 Continuation of Services
While Internal Appeal or State Fair Hearing is Pending; Beneficiary Liability
for Services
(a) Request for Continuing
Services: The Medicaid Program shall continue the beneficiary's services if the
following circumstances are met:
(1) The
beneficiary appeals in a timely manner,
(2) The beneficiary timely files for
continuing services which means within 11 days of the Medicaid Program sending
the notice of adverse benefit determination, or before the effective date of
the proposed adverse benefit determination, whichever is later,
(3) The appeal involves the termination,
suspension, or reduction of a previously authorized service,
(4) The services were ordered by an
authorized provider, and
(5) The
period covered by the original authorization has not expired.
(b) Duration of Continuing
Services: At the beneficiary's request, the Medicaid Program shall continue or
reinstate services while the internal appeal and State fair hearing is pending,
until one of the following occurs:
(1) The
beneficiary withdraws the internal appeal or request for a State fair
hearing,
(2) The beneficiary fails
to request a State fair hearing and continuation of benefits within 11 days of
the date the Medicaid Program mails the notice of resolution of the internal
appeal.
(3) There is a final
administrative decision on the State fair hearing request that is adverse to
the beneficiary.
(c)
Exception: Continuation of services without change does not apply when the
appeal is based solely on a federal or state law requiring an automatic change
adversely affecting some or all beneficiaries, or when the decision does not
require the minimum advance notice pursuant to
42 CFR §
431.213.
(d) Beneficiary Liability for Services
Furnished While Internal Appeal or State Fair Hearing is Pending:
(1) The Medicaid Program may recover from the
beneficiary the cost of services furnished to the beneficiary while the
internal appeal and State fair hearing were pending if the following criteria
is met:
(A) The services were furnished solely
because of the beneficiary's request for continued services,
(B) The beneficiary withdraws the appeal
before the internal appeal decision or State fair hearing decision is made, or
following the final resolution of an internal appeal or a State fair hearing
upholding the Medicaid Program's adverse benefit determination, and
(C) Recovery from the beneficiary is
consistent with AHS policy on recovery and the Medicaid Program determines that
the beneficiary should be liable for the service costs.
(2) If an internal appeal or a State fair
hearing relates to a concurrent review determination for emergency services or
urgent care, the service shall be continued without liability to the
beneficiary until the Medicaid Program has notified the beneficiary of its
final resolution, consistent with State fair hearing rules.
8.100.7 Providing or
Paying for Services Following Resolution of an Internal Appeal or a State Fair
Hearing
(a) Services Not Furnished While
Appeal Pending: If the Medicaid Program or AHS, including the Human Services
Board, reverses a decision to deny, limit, or delay services that were not
furnished while the internal appeal or State fair hearing was pending, or if
AHS decides in the beneficiary's favor before the hearing, the Medicaid Program
shall authorize or provide the disputed services as expeditiously as the
beneficiary's health condition requires but no later than 72 hours from the
date the Medicaid Program receives notice reversing the
determination.
(b) Services
Furnished While Appeal Pending: If the Medicaid Program or AHS, including the
Human Services Board, reverses a decision to deny, limit or delay services that
were furnished while the appeal was pending, the Medicaid Program shall pay for
those services in accordance with State policy.
8.100.8 Beneficiary Grievances
(a) Grievance System and the Right to Grieve:
The Medicaid Program shall have a grievance system that allows beneficiaries to
grieve a matter that is not an adverse benefit determination including denial
of a request for an expedited appeal, an extension of time by the Medicaid
Program for deciding a service authorization or resolving an internal appeal,
quality of care or services provided, aspects of interpersonal relationships
such as rudeness of a provider or employee, and the failure to respect a
beneficiary's rights.
(b) Filing a
Grievance
(1) Who May Grieve: A beneficiary,
authorized representative, or provider may file a grievance with the Medicaid
Program consistent with the requirements at 8.100.4(e)(l).
(2) How to Grieve: A beneficiary may file a
grievance orally or in writing.
(3)
Time line for Filing Grievance: A beneficiary may file a grievance at any
time.
(c) Assistance:
The Medicaid Program shall give beneficiaries assistance for the grievance
process consistent with the requirements of 8.100.4(g).
(d) Written Acknowledgement: The Medicaid
Program shall mail the beneficiary acknowledgement of the grievance within five
days of receipt of the grievance.
(e) Withdrawal of Grievances: Grievances may
be withdrawn orally or in writing at any time. The Medicaid Program shall
acknowledge a beneficiary's oral withdrawal in writing within five
days.
(f) No Punitive Action
Against Providers: The Medicaid Program shall ensure that no punitive action is
taken against a provider who files a grievance or supports a beneficiary's
grievance.
(g) Grievance Process
(1) Grievance Reviewer:
(A) Individuals who are making the decision
on a grievance shall not have been involved in any previous level of review or
decision making, nor be a subordinate of such individual.
(B) A grievance shall be decided by an
individual who possesses the requisite clinical expertise in treating the
beneficiary's condition when deciding:
(i) A
grievance regarding the denial of a request for expedited resolution of an
appeal, or
(ii) A grievance that
involves clinical issues.
(2) Information to Resolve Grievance: The
Medicaid Program shall act promptly and in good faith to obtain any necessary
information to resolve the grievance. "Necessary information" may include
information described at 8.100.4(k).
(3) Opportunity to See Records: The Medicaid
Program shall provide the beneficiary, free of charge, with all the information
in its possession or control relevant to the grievance process and the subject
of the grievance, including:
(A) The
beneficiary's case record, including medical records and other records and
documents related to the grievance, and
(B) Other information relevant to the
beneficiary's grievance including relevant policies and procedures.
(h) Time for Resolving;
Grievance Not Timely Resolved; Extension of Timeframe
(1) Time for Resolving: The Medicaid Program
shall decide the grievance and provide notice of the decision as expeditiously
as the beneficiary's health condition requires but not more than 90 days from
its receipt of the grievance.
(2)
Grievance Not Timely Resolved: If the Medicaid Program does not act upon the
grievance within the time for resolution, the beneficiary may request an
internal appeal pursuant to the definition of adverse benefit determination at
1.101.
(3) Extension of timeframe:
The Medicaid Program may extend the timeframe for deciding a grievance
consistent with the requirements of 8.100.4(o).
(i) Requirements of Notice of Resolution: See
8.100.3(d).
(j) Grievance Review
Process
(1) Filing a Grievance Review: If a
grievance is decided in a manner adverse to the beneficiary, the beneficiary
may request a review by the Medicaid Program within 11 days after the Medicaid
Program mails the notice of resolution of the grievance. The mailing date of
the notice is the postmark date. The postmark date is one business day after
the date of the notice.
(2) Written
Acknowledgement: The Medicaid Program shall acknowledge a grievance review
request within five days of receipt.
(3) Grievance Reviewer: The grievance review
shall be conducted by an individual who was not involved in deciding the
grievance under review and is not a subordinate of such individual.
(4) Disposition
(A) The grievance review shall assess the
merits of the grievance issue, the process employed in reviewing the issue, and
the information considered in making a final determination. The primary purpose
of the review shall be to ensure that the grievance process has functioned in
an impartial manner and that the response was consistent with the issues and/or
facts presented.
(B) The
beneficiary shall be notified in writing of the findings of the grievance
review within 90 days.
33 V.S.A. §
1901
[1 ] The Human Services Board Fair Hearing Rules are at
Code of Vermont Rules 13-020-002 (Part 1000).
[3 ] Human Services Board Fair Hearing Rules, Code of
Vermont Rules 13-020-002 (Part I 000)
[4 ] The State fair hearing process is subject to
3 VSA §
3 091
(h).