The Arizona Health Care Cost Containment System (AHCCCS) announced an extension of the statewide moratorium on the enrollment of Behavioral Health Outpatient Clinic, Integrated Clinic, Non-Emergency Medical Transportation, Community Service Agencies, and Behavioral Health Residential Facility providers. This moratorium extension will expire on June 8,2024. The extension was approved by Centers for Medicare and Medicaid Services (CMS) to be effective December 8, 2023.

This moratorium extension is part of actions taken by AHCCS to eliminate fraudulent billing practices that were identified. Related to provider enrollment, these actions include:

  1. Elevated 3 behavioral health provider types to the high-risk category for all new registrants, requiring fingerprints, on-site visits, background checks and additional disclosures,
  2. Received federal authority to imposea moratorium on new provider registrations for all Behavioral Health Outpatient Clinics, Integrated Clinics, Non-Emergency Transportation providers, and Community Service Agencies.
  3. Ended approval of retroactive provider registrations without good cause documentation,
  4. Eliminated the ability for providers to bill on behalf of others,
  5. Added new reporting to flag concerning claims for review before payment, including, but not limited to, claims for services that could not be rendered as billed, claims for substance use treatment for minors age 12 and under, claims for services by different providers that should not be provided on the same day, and overlapping services of the same style,
  6. Set billing thresholds and imposed prepayment review for various scenarios including multiple providers billing the same client on the same day for similar services, excessive number of hours per day, and the age of patients,
  7. All codes intended for per diem services have been limited in the system and providers must bill each day separately rather than in date ranges, so per diem codes can not be billed more than once a day on any given date of service,
  8. Researched and confirmed that the National Correct Coding Initiative (NCCI) Medicaid coding methodologies, which allow for states to reduce improper payments, are in place and functioning correctly,
  9. Hired a forensic auditor to review all claims since 2019,
  10. Set a specific rate for billing code H0015 for drug and alcohol treatment services, a change from the previous rate that paid a percentage of the billed amount, and
  11. Revised AMPM Chapter 610 policy to address provider conflicts of interest.

See more information on the AHCCCS website: