Mar 18

E-PASRR systems – Key considerations and resources for state to state consultation

Federal PASRR determination criteria regulations at 42CFR-483.130 (o)(p) require states to have a record retention and tracking system in place for their PASRR system. The CFR requirements are:

(i) Record retention. The State PASRR system must maintain records of evaluations and determinations, regardless of whether they are performed categorically or individually, in order to support its determinations and actions and to protect the appeal rights of individuals subjected to PASRR; and

(ii) Tracking system. The State PASRR system must establish and maintain a tracking system for all individuals with MI or ID in NFs to ensure that appeals and future reviews are performed in accordance with this subpart and subpart E.

While there is no specific CFR guidance regarding how states meet the requirements, findings from the 2018 National Report: A Review of PASRR programs indicate that states are beginning to rely on electronic systems rather than paper based systems. Seventeen states reported use of an electronic PASRR (e-PASRR) tracking system, with eight states reporting having made upgrades or changes to an e-PASRR system in the preceding year. An e-PASRR system will normally track whether an individual has had a Level I screen or a Level II evaluation and the related findings, but it may also allow states to analyze an array of PASRR related items, including types of diagnosis and information related to any specialized services recommendations.

One factor that may be encouraging this shift to e-PASRR systems is that CMS offers an enhanced 75% match for the introduction and maintenance of electronic tracking systems. States can claim the enhanced match on training, hiring a vendor, and purchasing and maintaining an electronic tracking system. As with other claims of the 75% match, states must show that the e-PASRR system is legitimately considered a cost of administering PASRR, the activity must be properly documented, and an approved Cost Allocation Plan (CAP) must be in place. An approved CAP permits the PASRR agencies to bill an appropriate share of all resources devoted to the PASRR program, including staff time, training, electronic tracking systems, quality monitoring and quality improvement efforts.

A number of states with internal or vendor provided e-PASRR systems have agreed to be a resource for state to state consultation around their e-PASRR experience. A full listing of the states and a contact person may be found on the e-PASRR Resource Guide.

The following state PASRR contacts have agreed to be a resource for state-to-state consultation regarding their experience in developing or utilizing an electronic PASRR system. This information is provided solely for the purpose of helping states that may be considering the use of an electronic system. The states identified may have developed their own system or they may be using a vendor.

Iowa

Lila Starr

lstarr@dhs.state.ia.us

515-281-5318

Maine

Gretchen Zeh-Higgins

gretchen.zeh-higgins@maine.gov

207-287-8823

Michigan

Michelle Derose

derosem1@michigan.gov

517-241-5881