Business as usual –
July 27, 2020 – RNP entered into contracts with the State of Connecticut Department of Social Services (“DSS”) to provide behavioral health and substance use disorder services to Medicaid beneficiaries. Medicaid reimburses methadone clinics, such as RNP, utilizing a weekly rate payment for each Medicaid patient provided methadone treatment. Regulations issued by the State of Connecticut in 2013 made it clear that the weekly payment was a “bundled” rate that included intake evaluation; initial physical examination; on-site drug abuse testing and monitoring; and individual, group and family counseling services.
On September 3, 2014, Medicaid issued a Provider Bulletin to all methadone clinics reminding them that the weekly rate payment included reimbursement for on-site drug abuse testing and monitoring. On February 1, 2015, DSS published on its website an Audit Protocol for methadone clinics. The Audit Protocol stated that if a DSS audit found Medicaid paid another laboratory provider for drug testing within a week of the date a methadone clinic was paid for methadone treatment, Medicaid would reduce the methadone clinic’s payment for the methadone treatment service by the cost of the laboratory service.
DSS conducted an audit of RNP and found that both RNP and an independent laboratory billed Medicaid for drug testing performed by the laboratory, contrary to DSS’ weekly rate payment regulation. In January 2016, DSS issued an Audit Report warning RNP that continued non-compliance with the weekly rate payment rule would result in financial disallowances in future audits.