Illinois EPA Change in Claim Reviews
In the past couple of months, Pinnacle EMS has seen a concerted change to the way the Illinois EPA (IEPA) is reviewing reimbursement submittals against approved budgets. Approved budgets became a requirement of the regulations on 6/8/2010. Until very recently, when the IEPA reviewed a claim, they would consider the approved budget in its entirety, rather than in a line by line fashion.
With a few exceptions, the agency did not take deductions in instances where a personnel title or task description in the claim did not match the approved budget as long as the category total was not exceeded. In other words, the agency was not comparing a claim to the individual line items in the budget. It was just making sure that the tasks in the claim were similar to the tasks in the budget, and that as a whole the claim did not exceed the budget (as a whole).
However, in the last few months the IEPA has changed their review methods. They are now indicating the reimbursement claim must match the budget in a line by line fashion. This means that there must be a match in personnel title, hours, and total line item cost with the rate being equal to or less than the budgeted rate. In some cases, the IEPA is allowing justification of a differing personnel classification to be submitted for consideration via email, but they have not accepted the justification in all cases. As a result, deductions are now being taken for many costs that would have been approved over the past seven years.
In order to minimize modifications or reductions to charges during claim preparation, it will now be very important to prepare budgets which include all level of personnel who will be working on a specific task. Since the IEPA is now matching task descriptions in the claim to task descriptions in the budget, it is also important that when a budget is prepared, you are using the same sort of work description that you are using on your invoices. Based on Pinnacle’s recent discussions with the agency, here are some recommended best practices for preparing budgets and generating invoices to maximize claim approvals.
Budgets:
Use clear task descriptions under each entry on the personnel section for work to be performed
Use separate line item for each possible level of personnel that may charge time to that task
Review previous submittals/results with Pinnacle to identify any costs that may have been deducted for an over budget determination under new agency review methods as well as costs that did not match up to previous budget
Invoices:
Provide detail task descriptions of each line item on an invoice
Be aware of and identify invoice line items that are not budgeted for future amended budget
Identify a strategy for capturing and budgeting tasks that have not been previously budgeted
Please reach out to discuss or ask questions. Thank you! Contact Lori Brashers, Illinois Program Manager at 754-220-4934.
