Children's Long-Term Support Program: Provider Medicaid (MA) Agreement and Qualification Process

DHS began completing the background checks for sole proprietors beginning January 1, 2025. DHS will update the CLTS Waiver Program Manual in February 2025 to reflect this change. We acknowledge the need for interim guidance on background checks.

• Provider agencies will remain responsible for the staff they employ.
• There is no change to individual providers who are hired and paid via financial management service (FMS) agencies.

CWAs should report concerns with providers that may warrant termination from Wisconsin Medicaid to the Bureau of Children's Services (BCS) by emailing the provider relations inbox at dhscltsproviderrelations@dhs.wisconsin.gov.

DHS requires providers to provide evidence of insurance for transportation, foster care staff, and agencies as outlined in the waiver manual.

DHS will not be entering into an indemnification agreement with the CWAs, as they do not need DHS to indemnify them. The CWAs are not liable for the actions of the CLTS Program providers.

CWAs cannot replace POS contracts with MOUs or different agreements/contracts to authorize services. CWAs will need to use other strategies to establish a shared understanding and a process for sharing information with providers.

For the review period beginning January 1, 2025, Section 4: Qualified Providers and Measure 4.1: Documentation of State and waiver training specific to participant needs, prior to service authorization will no longer be included as record review measure conducted by MetaStar.

Instead, Measure 4.1 will be reported as an administrative measure and DHS will be responsible for collecting necessary documentation from CLTS Program providers. The calendar year 2025 record review tool will be published to reflect this information in early 2025.

Per the 2025 Purchase of Service Memo and Guidance on Purchasing Care and Services Under Wis. Statutes 46.036, P-80048 (PDF) issued on November 4, 2024, Medicaid and Medicaid home and community-based service payments are to be excluded when calculating the cumulative total of DHS funds that count towards the $100,000 threshold.

Medicaid fee-for-service providers are exempt from audits per 2 CFR Part 200 Uniform Guidance.

This change is effective for audit periods ending on or after December 31, 2024, and no retroactive adjustments or allowances for prior periods will be made.

2024 CLTS provider audits are not required, and an audit waiver is also not necessary or appropriate. Do not request or require audits of these providers that you contracted with for CY2024.

Beginning January 1, 2025, DHS "approves" providers instead of the CWA until we are able to remove this functionality within the system. CWAs will continue to have access to all information for approved providers in their county.

The statewide rate methodology primarily sets rates for CLTS services with a direct care provider component. Services exempt from the rate methodology will continue to be paid at market rates.

Market rate providers must provide the CWA with their market rate service cost.

Support and service coordinators (SSCs) enter and use the service provider's market rate for the individual service plan (ISP) development and in parental payment limit (PPL) calculation.

There is no impact to subcontracted relationships for support and service coordination.

Individual service plan (ISP) development and provider selection is very important. Support and service coordinators (SSCs) work with families to identify providers who are qualified, willing, and able to provide the service(s) to meet the identified outcome(s).

Once the participant chooses the provider, CWAs should work with the family and provider to ensure the outcome(s) is being met effectively. If not, everyone should work together to support service provision to meet the outcome(s). This may mean deciding to change the staff person from a provider agency or switch to a different provider.

When there are provider issues that cannot be resolved through communication with the service provider and that may warrant termination from Wisconsin Medicaid, contact the DHS CLTS Provider Relations Coordinator at DHSCLTSProviderRelations@dhs.wisconsin.gov.

Qualification information is gathered based on the type of enrollment and the required licensure and certification of the service selected. DHS collects qualifications information and documentation based on provider type and the provider standards for the service the provider is enrolling in. All providers enrolling through the CLTS Provider Registry are required to submit a signed CLTS Waiver Program Medicaid Agreement, F-03344 (PDF), which is a contract between providers and DHS. Information on the provider enrollment process is located on the How do I Become a Provider? webpage.

Provider agencies

• DHS collects qualifying information at the agency level. If an agency is required to submit a license or certification at the agency level for the service type, DHS will collect that information.
• Agencies are responsible for the staff they employ and are required to ensure they have the required training, certifications, experience, and background checks.

Sole proprietors

DHS will collect all the required licenses and certifications, the CLTS Waiver Program Medicaid Agreement, and conduct a caregiver background check, as needed.

Fiscal Management Services (FMS)

• DHS will collect required license, training, and experience of the FMS agency.
• FMS agencies collect necessary documentation for individually selected providers. FMS agencies are required to ensure individually selected providers meet the qualifications required in the Provider Standards and Documentation for the service(s) being provided.

Providers are enrolled in Wisconsin Medicaid through the CLTS Provider Registry. DHS is responsible for qualifying willing providers. Per chapter 4.2.2 of the CLTS Waiver Manual, P-02256 (PDF), CWAs are responsible for:

• Reviewing and confirming the provider’s enrollment status on the CLTS Provider Registry. This includes confirming the provider is enrolled to provide the service identified on the child’s ISP.
• If the provider’s enrollment is approved by DHS, confirming the CLTS Waiver Program Medicaid Agreement and any required licensure and/or certification is current. CWAs should email DHS at DHSCLTSProvider@dhs.wisconsin.gov within 10 calendar days to conduct provider outreach if qualifying documents are not current.

CWAs are not responsible for ensuring agency providers have the qualifying documentation for the direct support professionals they employ. The agency provider must collect and maintain qualifying documents for their employees.

CWAs have an important responsibility in authorizing CLTS Program services and verifying that those services are in scope of waiver policy. By authorizing a CLTS Program service on the ISP, the CWA is affirming that the service is appropriate to meet the child’s outcome, and that the service is being delivered within the scope of waiver policy. Services must be authorized prior to service delivery. Continued authorization of a service may be completed after an evaluation of effectiveness and progress towards meeting the identified outcome.

In addition to authorizing CLTS Program services, the CWA’s responsibility also includes denying services that are out of scope of the CLTS Program. A service can be denied based on policy within the CLTS Waiver Manual, including General Medicaid Waiver Limitations listed in chapter 4.4 of the CLTS Waiver Manual, P-02256 (PDF), and service-specific limitations or exclusions listed in the service description.

The SSC should work with the family to find alternative funding sources for services outside the scope of waiver when available, e.g. educational related services. A denial based on the family’s choice of qualified provider would be a violation of participant rights.

Yes, CWAs should have regular communication with providers. Communication with providers is essential in assuring that authorized services are meeting a child’s outcomes. CWAs can help families communicate a child and family’s needs in service provision, ensure the effectiveness of services, and help resolve case specific issues that may arise. CWAs should use strategies to establish a shared understanding and a process for sharing information with providers.

CWAs should report persistent quality or health and safety concerns with providers that may warrant termination from Wisconsin Medicaid to the Bureau of Children's Services (BCS) by emailing the provider relations inbox at dhscltsproviderrelations@dhs.wisconsin.gov.

No, incident reports should only be sent in via CITR if they meet the definition of the types of incidents to be reported. Refer to chapter 9.3 in the CLTS Waiver Manual, P-02256 (PDF) for incidents that must be reported to DHS.

CWAs should report persistent concerns with providers that may warrant from Wisconsin Medicaid to the Bureau of Children's Services (BCS) by emailing the provider relations inbox at dhscltsproviderrelations@dhs.wisconsin.gov.

The CLTS Program is a Home and Community-Based Services (HCBS) Waiver program, federally authorized under §1915(c) of the Social Security Act. As a condition of waiver approval, DHS must make satisfactory assurances to the Centers for Medicare & Medicaid Services (CMS) concerning qualified providers, health and welfare, and other elements of waiver operations. Incident reporting and provider quality concerns fulfill different federal requirements. Further information on those federal requirements can be reviewed in the 2025 Children’s Long-Term Support (CLTS) Program Quality Guide, P-03535 (PDF).