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Factors to Consider When Choosing Coverage Options: Two Illustrative Services 91for a range of case management functions thatare not specifically covered under the casemanagement service for waiver beneficiaries(e.g., eligibility determination; administrativefunctions involving case managers such asprogram planning, development and outreach;and certain licensing and contractingfunctions).• When points of entry are organized along targetpopulation lines, administrative claimingmay be used to avoid some of the problemsassociated with service-based claiming, especiallywhen most of the individuals receivingservices are Medicaid-eligible in any case.• Administrative claiming is consistent withmodels where a state has established, by lawor regulation, a distinct network of local pointof-entry/casemanagement authorities.• In addition to helping a state underwrite thecosts of its point of entry/service coordinationsystem, administrative claiming can play animportant role in helping states operate theirhome and community service systemsthrough activities that are not keyed to meetingthe needs of specific consumers (suchactivities can be conducted directly by theMedicaid state agency or provided by a vendor).Such activities include:— Outreach to make individuals and familiesaware of the availability of home and communityservices.— Quality assurance/quality improvementactivities associated with the delivery ofMedicaid home and community services.— Automated data systems to compile awide range of information concerning beneficiariesof home and community services,including data to support qualityimprovement activities or aid in strategicplanning.— “Hot lines” and similar administrativeactivities to aid beneficiaries in locatingservices or registering complaints.— Various state-level administrative systemsactivities—including conducting statelevelreview and approval of HCBS waiverplans of care and other types of serviceplans, operating payment systems, determiningprovider rates, responding to consumercomplaints, and conducting servicequality reviews.• The administrative claiming option for casemanagement activities provides states withthe capability of securing FFP for external casemanagement services furnished to institutionalizedpersons that does not hinge on whetherthe person’s discharge from the facility isimminent. Administrative claiming may beemployed to provide external oversight of thewell-being of institutionalized persons as wellas support “in-reach” activities to provideinformation concerning the availability ofhome and community services.Administrative claiming may also span casemanagement activities that are directly tied toarranging and assisting a person’s return tothe community without respect to length oftime involved. However, such activities mustbe tied to arranging Medicaid home and communityservices. The state Medicaid agencymay obtain case management services forinstitutionalized persons via contract with astate program office or through local humanservices agencies. Organizing case managementfor institutionalized persons under theadministrative claiming option may simplifyuse of Medicaid dollars to underwrite suchservices in comparison to other available serviceoptions.Drawbacks to states of using administrativeclaiming for case management services:• Federal reimbursement of administrativeexpenses is generally limited to 50 percent ofallowable costs. In states where the servicerate is greater than 50 percent, administrativeclaiming will yield less FFP.• Administrative claiming is limited to activitiesrelated solely to administration of the Medicaidplan. Thus, the costs of activities that