Maternal, Child & Adolescent Health Division

Title XIX Frequently Asked Questions for Local Health Jurisdictions and Contracted Agencies

Federal Title XIX Medi-Cal (Medicaid) funds may be used to reimburse a percentage of expenses incurred for personnel and associated operating costs for matchable activities. This fiscal support is called Federal Financial Participation (FFP). Programs can claim FFP funds when activities meet at least one of the two FFP objectives:

assisting individuals eligible for Medi-Cal with enrolling into the Medi-Cal program
assisting Medi-Cal members with accessing Medi-Cal covered benefits and services

#	Question	Answer
1	Are MCAH Action activities eligible for FFP funding since those activities are related to work of the Local MCAH program?	MCAH Action activities are only eligible for FFP funding if they meet at least one of the two FFP objectives and align with a Scope of Work (SOW) activity.
2	Are Community Health Workers (CHW) considered Skilled Professional Medical Personnel (SPMP)?	No, CHW are not considered SPMP and are not eligible for enhanced matching. See DHCS Title XIX Website, Skilled Professional Medical Personnel (SPMP) Classifications.
3	Does it matter what type of license a Licensed Marriage and Family Therapist has to be considered SPMP? For example, is an Associate MFT with a master's degree in Marriage Family Therapy acceptable to be considered SPMP?	A Licensed MFT meets the federal requirements as SPMP. Licensure requirements are determined by the licensing board. Please refer to the DHCS Title XIX Website, Skilled Professional Medical Personnel (SPMP) Classifications.
4	Are the California Home Visiting Program (CHVP) Innovation staff able to leverage (claim) Title XIX?	Yes, CHVP Innovation staff are able to leverage (claim) Title XIX if the Innovation project is to provide Medi-Cal eligible service in accordance with Title XIX rules. See the Fiscal P&P (PDF), Federal Financial Participation, for more details on the requirements.
5	For staff members who have payroll costs included in their MIECHV or CHVP-State General Fund (SGF) budgets, should their Title XIX time study include hours charged to both CHVP budgets with the option to select codes 1-11A? Or do they only need to use Codes 1-11A for only CHVP – SGF? Should staff separate hours for the two different CHVP funding streams or can both CHVP funding streams be combined in the same rows in the Title XIX time study?	CHVP MIECHV and CHVP SGF have individual budgets; therefore, they must time study separately using each funding stream's different codes. The local agencies cannot combine the budgets.
6	If local staff are not included on the Local MCAH or CHVP MIECHV budget but 100% of their time is included in the CHVP SGF budget, should that staff complete a Title XIX time study?	Any staff listed on a budget drawing down TXIX must complete a TXIX time study, regardless of funding type. Duty statement must reflect Medi-Cal activities.
7	We are new to having non-SPMP staff, who support SPMP staff, claim enhanced coding for their support work. Can you please provide us with some insight on how the coding process works and any examples you can provide of coding?	Pursuant to 42 CFR 432.2, directly supporting staff are eligible for enhanced FFP as described in this regulation: secretarial, stenographic, and copying personnel and file and records clerks who provide clerical services that directly support the responsibilities of SPMP, who are directly supervised by the SPMP, and who are in an employer- employee relationship with Medi-Cal. The Duty Statement and Org Chart are required to substantiate the direct support. For more information on function code use cases, visit Title XIX Function Codes.
8	Can a subcontractor time study?	Yes, a subcontractor can time study for Title XIX. When the local health jurisdiction (LHJ) invoices the state, they are required to submit the subcontractor's time study as back up documentation for the subcontractor invoice.
9	Has there been any guidance regarding how Title XIX will work with Enhanced Case Management (ECM) if a LHJ's MCAH program is an ECM provider or does other CalAIM related work they invoice?	If an LHJ is providing ECM activities, those activities are not claimable under Title XIX. For example, if a nurse provided care coordination that is covered by ECM, it cannot also be billed to Title XIX.
10	Can a LHJ subcontractor claim an enhanced rate?	If the subcontractor is a public agency, such as a city, they can bill at the enhanced rate. CBOs are not to bill at the enhanced rate. A public agency (42 CFR §457.301) is defined as a State, county, city or other type of municipal agency, including a public school district, transportation district, irrigation district, or any other type of public entity. Title XIX enhanced SPMP (75/25) is available for staff of other public agencies as long as the requirements outlined in 42 CFR §432.50(d)(1) are met and the public agency has a written agreement with the Medicaid agency (Medi-Cal) to verify that these requirements are met.
11	One of our local programs subcontracts with UCSF. They want to match with Title XIX. Is UCSF considered a government agency for the purposes of Title XIX matching?	Yes, UCSF is considered a public agency. Federal regulations (42 CFR §457.301) define public agency as a state, county, city or other type of municipal agency, including a public school district, transportation district, irrigation district, or any other type of public entity. UCSF's subcontracts are eligible for Title XIX matching but not the enhanced rate unless the subcontractor is also a government agency. Only subcontracted public agencies may claim the TXIX enhanced SPMP rate. According to GOV §811.2, “public entity" includes the state, the Regents of the University of California, the Trustees of the California State University and the California State University, a county, city, district, public authority, and any other political subdivision of public corporation in the State. Title XIX enhanced SPMP (75/25) is available for staff of other public agencies as long as the requirements outlined in §432.50(d)(1) are met and the public agency has a written agreement with the Medicaid agency (Medi-Cal) to verify that these requirements are met.
12	Is Client Transportation matchable with Title XIX funding on MCAH program budgets?	Client Transportation may qualify for FFP matching only when one of the two FFP objectives are met, and payment is not also claimed under targeted case management (TCM).
13	Are there other limitations on Title XIX expenses? What is not allowable?	All allowable Title XIX expenses must meet at least one of the two FFP objectives and a scope of work activity, and payment cannot also be claimed under TCM. Confirmed unallowable Title XIX expenses include but are not limited to: Malpractice insurance Equipment used for providing medical treatment Medical Supplies Drugs and Medications Payments made to resolve audits Costs of elected officials and their related costs Costs for lobbying activities Fund Raising The above list as well as additional examples of unallowable activities can be located beginning page 9 of DHCS' CMAA Operational Plan.