|
|
State of Wisconsin Wisconsin Funeral and Cemetery Aids Program (WFCAP) Manual Release 11-01 March 30, 2011 |
|
|
State of Wisconsin Wisconsin Funeral and Cemetery Aids Program (WFCAP) Manual Release 11-01 March 30, 2011 |
2.1 Claim Form for Reimbursement
2.2 Who May Request Reimbursement
2.3.1 Reporting Total Funeral Expenses
2.3.2 Reporting Total Cemetery Expenses
2.4 Determining Whether it is a Funeral or Cemetery Expense
2.5 Reimbursement for Funeral Expenses
2.5.1 Total Funeral Expense Cap
2.5.2 Funeral Expense Reimbursement Limit
2.6 Reimbursement for Cemetery Expenses
2.6.1 Total Cemetery Expense Cap
2.6.2 Cemetery Expense Reimbursement Limit
Total funeral and cemetery expenses must be reported by the funeral home, cemetery or crematory, using the F-10141 "Wisconsin Funeral and Cemetery Aids Program Reimbursement Request” form. Local Agencies should accept only this form. Deny reimbursement requests not submitted on the proper form.
Funeral homes, cemeteries and crematorys are encouraged, but not required, to submit a single reimbursement request form covering both funeral and cemetery expenses for an individual. The funeral home or the cemetery may submit the reimbursement request form for cemetery and funeral charges.
If it is not possible to coordinate the submission of a single form separate forms may be submitted.
For Instructions on how to complete the F-10141, see F-10141A "Wisconsin Funeral and Cemetery Aids Program Reimbursement Request Instructions."
Local agencies may accept reimbursement requests only from funeral homes, cemeteries and crematories.
Deny reimbursement requests from family members or other non-providers of goods or services. Deny reimbursement requests from providers of goods or services that are not funeral homes, cemeteries or crematories.
"Total Funeral and Cemetery Expenses” are defined as actual charges, not estimates, for all funeral and cemetery goods/services provided (i.e., sold) by the funeral home, cemetery or crematory, whether provided before or after death.
Note: Throughout this manual, "provided” means "sold.”
The funeral home must report the total actual charges associated with the goods/services that it, or other funeral homes in the same corporation, provided whether those goods/services were provided before death or after death. The funeral home must also report total actual charges associated with goods/services provided by others but, for which, the funeral home pays. Such " cash advances ” are generally not counted toward the total funeral expense cap (2.5.4), however, they must still be reported as part of the reimbursement request and clearly identified as cash advances. Funeral homes are not responsible for reporting charges associated with goods and services provided by others that are not cash advanced.
|
Example 1: Funeral Home A and Funeral Home B are both owned by the XYZ Corporation. |
|
Example 2: On behalf of the family of the deceased, Funeral Home A purchases flowers, pays for the obituary notice, reimburses the pastor and purchases an outer burial container from the XYZ Vault Co. Funeral Home A charges the family exactly what has been advanced. Funeral Home A must report the associated charges as a cash advance, but these charges will not be counted toward the $4500 total funeral expense cap. |
|
Example 3: After discussions with the director of Funeral Home B, the family of the deceased purchases flowers on its own, pays for the obituary notice and reimburses the pastor for presiding over the service. Funeral Home B does not provide or cash advance any of these services. Funeral Home B is not responsible for reporting the charges associated with these services as part of the total funeral expense. |
|
Example 4: Mr. and Mrs. D purchase their coffins over the internet and store them in the garage pending their deaths. Mr. D, a categorically needy Medicaid recipient, dies. Funeral Home A is not responsible for reporting the charges associated with Mr. D’ s coffin as part of the total funeral expense, because Funeral Home A did not provide the coffin. |
|
Example 5: Mr. and Mrs. Q purchase their coffins from Funeral Home A. Mr. Q, a categorically needy Medicaid recipient, dies. Funeral Home A must report the charges associated with Mr. Q’s coffin as part of the total funeral expense because Funeral Home A provided the coffin. |
Cemeteries and crematories must report total actual charges associated with the goods/services that they provide, whether those goods and services are provided before death or after death.
|
Example 6: Mr. and Mrs. Z purchase their burial plots from Cemetery A. Two years later, Mr. Z enters a nursing home, becomes eligible for Medicaid, subsequently dies and is buried at Cemetery A. Cemetery A provided the burial plot and therefore, must report the actual charges associated with the plot as part of the total cemetery expenses. |
|
Example 7: Mr. and Mrs. Z commission a renowned sculptor to create their headstones. Two years later, Mr. Z enters a nursing home, becomes eligible for Medicaid, subsequently dies and is buried at Cemetery A. Cemetery A is not responsible for reporting the charges associated with Mr. Z’s headstone as part of the total cemetery expense because Cemetery A did not provide the headstone. |
Funeral expenses are subject to the total funeral expense cap and reimbursement limit (see 2.5). Cemetery expenses are subject to the total cemetery expense cap and reimbursement limit (see 2.6) (If the funeral home sets up a crematory as a stand-alone business, then the goods/services provided by the crematory may be counted as a cemetery expense.)
Accurate reimbursement depends on knowing whether an expense is a funeral or cemetery expense.
If the good/service is provided by a funeral home (including cremation), consider the expense to be a funeral expense. If the good/service is provided by a cemetery or crematory, consider the expense to be a cemetery expense. If a good/service is provided by an entity other than a funeral home, cemetery, or crematory and cash advanced by the funeral home, apply the cash advance policy in 2.5.4.
Exception: There is one exception to this policy. Many small, rural cemeteries rely on a funeral home to provide certain goods and services on their behalf (e.g. The outer burial vault, opening and closing of the grave, etc.)
Under this circumstance, and only this circumstance, count the good or service as a cemetery expense, even though it is provided by a funeral home. Funeral homes should document this circumstance on the "Statement of Funeral Goods and Services Selected." If there is no indication that this is indeed the case, do not apply the policy exception and, instead, count the good or service as a funeral expense.
Apply the following policies in determining correct reimbursement of funeral expenses.
If the total funeral expenses exceed $4,500, do not reimburse any of the funeral expenses, unless DHS has found that there are special circumstances (see 2.7).
|
Example 8: Total expenses for the funeral charged by the funeral home are $4,700. The estate is able to pay $3,700. Do not reimburse the provider for any of the funeral home expenses, unless DHS finds that there are special circumstances. |
$1,500, or
Any amount for which the estate of the deceased is insufficient to pay and that is not paid by other persons.
|
Example 9: Total expenses charged by the funeral home are $3,000. The estate is able to pay $2,200 toward the funeral expenses. Reimburse the provider for $800 of the funeral expenses. |
The US Federal Trade Commission (FTC) requires funeral directors, nationwide, to use a "Statement of Funeral Goods and Services Selected,” as a way of indicating to their customers what is being purchased and their charges. The FTC does not mandate a specific format for the "Statement of Funeral Goods and Services Selected". FTC requires certain information be included on the Statement. Additional information regarding the Statement, as well as many other federal requirements that apply to the funeral business is available at the following website.
http://www.ftc.gov/bcp/edu/pubs/consumer/products/pro26.pdf
A copy of the Statement of Funeral Goods and Services Selected must accompany the Wisconsin Funeral and Cemetery Aids Program Reimbursement Request. Deny the request for reimbursement of funeral expenses if the Statement is not submitted.
"Cash advances” are goods/services obtained by a funeral home from a third party that are paid for by the funeral home on behalf of and subject to reimbursement from a person purchasing services from the funeral home. Cash advances are commonly made by funeral homes for services such as cemetery or crematory services, pallbearers, public transportation, clergy honoraria, flowers, musicians or vocalists, nurses, obituary notices, gratuities and death certificates. Cash advances are not limited to these goods/services.
Usually, the funeral home asks the family to reimburse it an amount equal to what was advanced. A funeral home can, however, charge additional sums for the service of making cash advances on behalf of the family of the deceased. For example, a funeral home may advance a $175 payment for an obituary charge to the local newspaper; when billing the family, the funeral home adds a $20 service fee for a total of $195. By FTC rule, whenever the funeral home bills for more than the actual amount of the cash advance, it must identify this to the purchaser/family with a standard phrase added to the Statement of Funeral Goods and Services Selected; the phrase is "We charge you for our services in obtaining...”
When the funeral home requests the family to reimburse it for cash advances in the same amount as the advance that was made, do not count the advance toward the $4500 funeral cap.
Note: Cash advances made by the funeral home for cemetery expenses must still be counted toward the $3,500 cemetery cap.
If the funeral home charges an amount greater than the advance, count the cash advance, plus the amount in excess of the advance against either the $4,500 funeral expense cap, or the $3,500 cemetery expense cap, or both, as appropriate.
If a cash advance is not counted toward the total funeral expense limit, then it is not part of the total charges and will not be reimbursed.
Apply the following policies in determining correct reimbursement of cemetery expenses:
If the total cemetery expenses exceed $3,500, do not reimburse any of the cemetery expenses, unless DHS has found that there are special circumstances (see 2.7).
|
Example 10: The total cemetery expenses are $3,800. The estate is able to pay $2,900, leaving $900 still owed. Do not reimburse the provider for any of the cemetery expenses as the expenses exceed the $3,500 cap (unless DHS has found that there are special circumstances). |
Reimburse the cemetery or crematory whichever is less:
$1,000
Any amount for which the estate of the deceased is insufficient to pay and which is not paid by other persons.
Under certain circumstances (e.g., over-sized casket, transporting the deceased over long distances), the total expense caps (2.5.1 and 2.6.1) as well as the reimbursement limits (2.5.2 and 2.6.2) may be exceeded. The Department of Health and Family Services determines whether circumstances justify exceeding these limits.
Unless DHS determines that special circumstances exist:
Never issue reimbursement when the total expense caps have been exceeded, and
Never issue reimbursement above the specified reimbursement limits.
Special circumstances must be documented by the provider and submitted to the local agency, along with the reimbursement request form.
Fax the form and all related documentation to:
608-261-6861, attention Funeral and Cemetery Aids Program or
Forward the form and all related documentation to DHS at the following address:
Department of Health Services
Division of Health Care Access and Accountability
Bureau of Enrollment Policy and Systems
Attention: Funeral and Cemetery Aids Program
P.O. Box 309
Madison, WI 53701-0309
DHS will notify the local agency of its decision within 10 calendar days of receipt.
Reimbursement under the WFCAP must be requested within 12 months of the date of death. This means that the request must be received by the local agency no later than the end of the 12th calendar month following the month of death.
|
Example 11: Mrs. Smith was receiving SSI during June 2009, when she died. The funeral home requests reimbursement in January 2010. The reimbursement request is timely. |
|
Example 12: Mr. Jones was receiving SSI when he died May 15, 2009. On June 1, 2010 the local cemetery requests reimbursement. The request for reimbursement is late. Deny the request. The last possible date for this request to be considered timely was May 31, 2010. |
2.8.1 Time limit for Claim adjustments
Claim adjustments made within the 12 month filing deadline should be considered for payment. Claim adjustments are subject to existing reimbursement policy.
Providers may appeal the outcome of their reimbursement request. Requests for a hearing must be made in writing to:
Division of Hearings and Appeals
P.O. Box 7875
Madison, WI 53707-7875
Requests should include: provider's name and mailing address, a brief description of the problem, which county or state agency took the action or denied the service, and provider's social security number and signature.
This page last updated in Release Number: 11-01
Release Date:03/30/11
Effective Date: 03/30/11
