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OMAP - Medical Assistance Bulletin Number 99-03-13, attachment D

Pennsylvania Medicaid (DHS)·PA·Provider Bulletin
Effective date
Not stated
We identified it
Aug 16, 2026
Days to comply

Summary

This policy establishes continuity of care protections for Medicaid recipients transitioning between delivery systems (FFS to MCO, MCO to MCO, or MCO to FFS). Ongoing courses of treatment not requiring prior authorization must continue uninterrupted for up to 60 days (or longer if clinically appropriate), and services must be covered by the new MCO even from non-participating providers during the transition period. Billing teams must ensure claims for continuity-of-care services are processed without denial during designated transition windows.

Action Required

Action needed
REQUIREMENTS: - Immediately: Billing team must update claims processing workflows to recognize and honor continuity-of-care transition periods when members enroll in new MCOs or switch from FFS/MCO delivery systems. - Establish policy in billing system: Do NOT deny or require prior authorization for ongoing courses of treatment during the 60-day continuity-of-care transition period, even if services are from non-participating network providers. - Add verification step: Before processing claims for members with recent enrollment changes, verify with previous provider/delivery system whether member is receiving an ongoing course of treatment that qualifies for continuity protections. - For OB-GYN cases: Flag that pregnant members and postpartum cases receive extended continuity (throughout pregnancy and postpartum period related to delivery), not just 60 days—ensure billing system accommodates extended coverage periods. - Update denial procedures: If concurrent clinical review after 60 days results in treatment modification/denial for adults age 21+, billing team must ensure proper written notice is issued and claims must continue to be processed if grievance/fair hearing is filed within 10 days (services continue pending decision). - Train billing staff: Ensure team understands that MCOs cannot deny coverage for services provided during continuity-of-care periods under same terms as participating providers, and that continuity applies to children under 21 indefinitely if services require prior auth under new system. - Coordination with providers: Establish internal protocol to request approval/prior authorization information from previous providers when member transitions, as this information must be conveyed to new providers per policy.
OMAP - Medical Assistance Bulletin Number 99-03-13, attachment D | Pennsylvania Medicaid (DHS) | PolicyChanges.app