“The great cost associated with these translator services will be absorbed by small practices like mine, and those practices also will bear the brunt of the liability should there be a misinterpretation by the translator regarding the patient’s diagnosis and/or treatment plan. To expect small practices to provide these costly services will likely mean the decline of Medicaid providers, which will ultimately lead to MORE of a need for dental care and services rather than less, as I am sure was the intention behind this over-reaching piece of legislation.”
MDA asked that for the continuity and quality of care for patients, as well as the ability for Medicaid providers to continue providing services to those recipients, that MO HealthNet find a way to reimburse providers for the costs they will undoubtedly incur due to this requirement.
MO HealthNet responded with some information about services that are covered under the current managed care (MCO) contracts. They are researching how they can provide translation services for the fee-for-service side of Medicaid in Missouri.
The services that are required under the contract with the MCOs states: The health plan shall make interpreter services available as necessary to ensure that members are able to communicate with the health plan and providers and receive covered benefits. The health plan shall use certified interpreters. The health plan shall inform members of the availability of interpreter services, how to access them, and that there is no charge for the services.
How the Interpreter/translation Service works: It is our understanding that interpreter services will bill the MCOs directly. This takes the burden of billing off of the individual provider. This only works for the Managed Care patients.
As for NON managed care patients (fee-for-service), again, MO HealthNet is exploring how they can provide translation/interpretation services for those patients. The providers will be updated on what transpires as soon as we are made aware. There likely will be a MO HealthNet bulletin sent to all dental providers with regards to these services. For now, one company the MDA is aware of that can provide interpretation services remotely (which is allowable in the 1557 rules) is:
All Access Interpreters
They define interpretation services as oral communication and translation services as written communication. MO HealthNet has made MDA aware of this company, as they are an authorized Vendor of the State. The company has indicated that most offices that have an electronic dental record and a video camera can use their service. The installation of the software is coordinated with the IT Department at All Access Interpreters. This installation can be done remotely and only takes a few minutes. The configuration of the software is only done once, after which, interpreters can be accessed. See rate structure below. (This company does provide onsite services in the St. Louis area only at a cost of $45/hour). The company, when seeing an MCO patient, would bill the MCOs directly for managed care patients. If they don’t have an EDR, then other arrangements will need to be made, but it is pretty simple. As for the fee-for-service patients, the company also can provide the service and would bill the provider directly for that service at least for now until MO HealthNet determines if they can cover and outlines how that reimbursement would work.
Rates For Video Interpreting
|All other languages
|American Sign Language
In either case, the provider is responsible for making sure the service is available. In one case (MCOs) it is a paid service, in the other case (fee for service), right now, it is not.
Providers must remember that when you are working with a company for these services, you will need a business associate agreement to comply with HIPAA. The ADA has sample contracts that can be used (see No. 6 Auxiliary Aids and Services FAQ) and multiple other resources on this topic at www.ada.org/1557.
*The MDA has received calls for clarification about who is covered by, and needs to comply with, Section 1557? Dentists and dental practices that receive certain payment from the U.S. Department of Health and Human Services, such as Medicaid or CHIP reimbursement or “meaningful use” payments under the Medicare and Medicaid Electronic Health Records Incentive Program must comply with Section 1557. Section 1557 does not apply to dentists or dental practices who only accept reimbursement under Medicare Part B, including Durable Medical Equipment or DME that is reimbursed under Part B. It is not yet clear if dentists who accept payment through Medicare Part C (Medical Advantage plans) will be covered by Section 1557. The ADA plans to provide updates when more information is available.