Ashland, Bayfield counties outline Medicaid billing, documentation and telehealth rules for CCS providers

Julie Winter, quality control and improvement coordinator for Ashland and Bayfield counties, spent nearly three hours walking new and existing providers through the counties' Comprehensive Community Services (CCS) requirements, focusing on how supports are authorized, documented and billed under Medicaid.

Winter said CCS is “person centered,” adding, “the participant is the one that determines, with, of course, our support, their services,” and stressed that Medicaid rules drive many of the program's documentation and billing requirements. The training covered eligibility and service-authority steps, the ForwardHealth requirement that outpatient psychotherapy and adult mental health day treatment be billed through CCS when the participant is enrolled, and local procedures for submitting progress notes in the counties' ECHO electronic health record.

The training matters because CCS is Medicaid-funded and documentation errors can trigger audit recoveries. Winter told providers that service facilitators must read and review 100% of progress notes and “they have to be reviewing every two business days,” and that providers should not sign notes until a service facilitator messages them in ECHO approving the note for signature. She also emphasized that notes are part of the participant’s medical record and could be requested by participants.

Winter outlined the authorization process: a service facilitator and participant identify goals and barriers in a service plan meeting; natural supports must be explored per DHS 36 administrative code; then the facilitator writes a support into the plan and sends the authorization to the provider. She warned that only service facilitators can add or adjust supports and that providers should document suggested needs in progress notes so facilitators can follow up.

On billing and timekeeping, Winter explained two critical timing buckets. Billable time includes face-to-face or telehealth direct service, travel to and from an appointment, and the time spent writing the progress note. Certain coordination or reminder calls, no-show documentation and other time spent when the participant is not present are non-billable but should still be documented because counties use those figures in rate-setting. She advised providers to record the actual number of minutes spent documenting (documentation time) but to round direct-service and travel time to the nearest 15 minutes for billing; documentation time itself is recorded as the exact minutes and is used internally for audits.

Winter offered specific numeric policies from county practice: participants must engage in CCS services at least once every 90 days or risk administrative discharge; service plan reviews and comprehensive assessment reviews occur at least every six months; travel reimbursement is limited (the travel policy notes the counties will not reimburse more than three hours of travel for a single appointment); and providers must enter non-bill notes for no-shows so the counties can follow the no-show process and, if necessary, end a support after the prescribed steps.

The trainer reviewed which supports must be billed through CCS: ForwardHealth requires outpatient psychotherapy and adult mental health day treatment to be delivered and reimbursed via CCS when the member is enrolled. Other supports (for example, peer support, medication management or substance use counseling) can be provided and reimbursed outside CCS when available under other benefits, but Winter said programs must avoid duplicating services and ensure billing aligns with the participant's coverage.

On telehealth, Winter said providers must use a HIPAA-compliant platform (regular FaceTime and non-HIPAA Zoom were explicitly excluded), participants must consent to telehealth (it cannot be mandated), telehealth must be “functionally equivalent” to in-person services to be billable, and telehealth notes must document the participant’s surroundings and who else is present when that detail is relevant.

Winter also described the counties' ECHO workflow: providers start notes in ECHO but should save and not sign; service facilitators review and send an internal ECHO message indicating whether the provider can sign or must revise; once signed, the note becomes part of the official medical record and may be submitted for Medicaid reimbursement. Reopening a finalized note is possible only in limited circumstances and carries audit risk; if a signed note needs amendment the provider must immediately notify the service facilitator and the mental health professional so county billing staff can determine whether the note can be unlocked and corrected before submission.

Training and credentialing requirements were explained in detail. Providers with six months or more experience working with people with mental health or substance use needs must document 20 hours of initial training relevant to DHS 36; those without that experience must document 40 hours. Peer specialists and certain rehabilitation providers require an additional 30 hours (bringing totals to 50 or 70 hours). Providers must complete specified UW–Green Bay online modules and county-specific policy reviews, submit a training log and required documents, and may be subject to ongoing annual training (8 hours per year) and supervision or clinical-collaboration requirements tied to the provider's credential level and annual service hours.

Winter closed by pointing providers to the county vendor and provider resources page for the referral form, the progress-note rubric, redacted example notes, telehealth and travel policies, the no-show policy, and other materials the counties use to support consistent documentation and billing.

Providers should expect to follow the counties’ written policies and ForwardHealth billing rules, to coordinate with their service facilitators on authorizations and note corrections, and to keep careful documentation of both billable and non-billable time to support billing, rate-setting and audit defense.