REcently Asked Questions

  1. Is the county responsible for distributing the new claim form and instructions to funeral homes and cemeteries?

 

No.  Funeral homes, cemeteries and crematories can access all of the WFCAP material on-line, allowing them to print the claim form and instructions themselves.  If counties get phone calls from providers asking for forms, just refer them to the website:

 

http://www.emhandbooks.wi.gov/wfcap/fcap.htm

 

The Department will not be printing supplies of the claim form, instructions, manual or notices because these are all available on-line.

 

  1. Is the new claim form required for all WFCAP reimbursement requests received on and after February 14, 2005, or is the form required if the death is February 14 or later?

 

With regard to use of the new form, the date of death doesn't matter.  What does matter is the date the county receives the request for reimbursement. Any WFCAP reimbursement request that the county receives on or after 2/14/05 must be on the new claim form.  If it isn't, the request must be denied using the notice supplied on the website.  If we had based the effective date on the date of death (given that providers have 12 months to file a claim), counties would be dealing with two different sets of policies and processes for up to a year.
 

  1. Are counties required to contact their providers to share the new WFCAP policies and procedures?

 

Funeral homes and cemeteries were notified via their respective associations prior to implementation on February 14th.  Counties are not required to notify anyone, but certainly may if they choose to do so.

 

  1. Who is responsible for submitting the reimbursement request forms, the funeral home or the cemetery?
     

Ideally, we would like one form to be submitted for each deceased person, including funeral and cemetery charges.  Either the funeral home or the cemetery could submit it, whatever works best for the providers involved.  If it is not possible to coordinate the submission of a single form, it is certainly acceptable for the funeral home and cemetery to each submit separate forms, documenting their respective charges and reimbursement requests.
 

  1. Section 3 of the new claim form has space where the cemetery enters dollar amounts for each item. Can you add a line for the grave liner?  Since this is required in nearly all cemeteries, it is really a cemetery expense, although you understand there are instances where the cemetery might not sell the item and funeral homes act on their behalf.

 

We will consider this for the first revision of the claim form.

 

  1. Section 3 on the new claim form has space to list cemetery expenses, but not funeral expenses.  Is a Statement of Goods and Services adequate?

 

Yes, the Statement is adequate and required for reimbursement.

 

  1. Can the claim form be faxed to the county?
     

Faxes are fine, but for funeral homes, that means they'll have to fax the Statement of Funeral Goods and Services, along with any documentation related to verifying cash advances.  Also, note that we have received reports from counties that Section 6 (i.e., the shaded “Office Use Only” section) does not always fax well.  We intend to lighten up the shading, or remove it altogether, on the next version of the claim form.
 

  1. The family wants an urn and the funeral home supplies them, but this is not a  required need.  Is the county required to reimburse for it?  

 

The county does not determine whether there is a “required need” and this concept is not recognized in policy anyway (i.e., it is irrelevant).  If the family wants something and it is provided by the crematory or cemetery, it will count toward the $3500 cemetery expense limit.  If it is provided by the funeral home, it will count toward the $3500 funeral expense limit.  Note that if something is cash advanced by the funeral home (i.e., they purchased it on behalf of the family and charged only what they paid for it), it would not count toward the $3500 funeral expense limit.

 

  1. Should funeral homes and cemeteries call the county to check eligibility before submitting a claim form?
     

Yes, that is advisable.  We’re not entirely sure how each county has handled this in the past, but it makes sense to check eligibility first before completing all the paperwork.  It will save providers and counties time and resources.  On the other hand, the only way to preserve a provider’s right to appeal a county decision is to submit a claim.  For example, if you don’t submit a claim form because the county tells you that a person is ineligible for the benefit, then you cannot appeal if you later learn that the person was in fact eligible.  

 

(You could at that point, however, submit a claim and go on to appeal the county’s determination if you were not satisfied, assuming you were still within the 12 month filing period.)

 

  1. The policy says that  "If the good/service is provided by a funeral home (including cremation), consider the expense to be a funeral expense."  What if the funeral home creates a separate legal entity that only performs cremations?  Would they then be able to bill for the cemetery expenses separately?

 

Yes.  If the funeral home sets up a crematory as a stand-alone business, then the goods/services provided by the crematory would be counted as cemetery expenses.
 

  1. Are there two separate $3500 total expense limits, one for cemetery expenses and one for funeral expenses?

 

Yes.  If total cemetery charges exceed $3500, no reimbursement will be made for cemetery expenses unless special circumstances exist and are approved by the WI Department of Health and Family Services.  If total funeral expenses exceed $3500, no reimbursement will be made for funeral expenses unless special circumstances exist and are approved by the WI Department of Health and Family Services.

 

  1. Section 3 - Total Funeral and Cemetery Expenses.  Is there any way to document the need to verify all Cash Advances on the claim form and in the instructions?

 

Yes.  We'll add text to both the claim form and the instructions when we do the first revision.  
 

  1. What is considered to be “adequate verification” of cash advance items?
     

A receipt from the third party vendor is the preferred method of verification.  If it is not possible to obtain a receipt, indicating the following on the Statement (or a separate document) will be sufficient: the third party vendor name and telephone number, purchase date, amount of the cash advance and amount of the service fee, if any.
 

  1. Why do cash advances need to be verified under the new procedures?

 

Some counties expressed concerns that the cash advance policy presented an opportunity for providers to circumvent the $3500 total funeral expense limit, since cash advance items are generally not counted.  The new verification policy is in response to those concerns and will be evaluated at the end of the first year of operations (i.e., February 2006).  
 

  1. Some funeral homes have expressed concern about the requirement that funeral directors verify any additional funding sources.

 

There really is no such requirement.  The following is what funeral homes agree to in signing the form:

 

“By signing below, the Provider certifies that: 1) the charges indicated here represent total actual charges for goods/services provided by the Provider, and 2) funds to which the Provider is entitled as the beneficiary of a pre-arranged burial agreement are included in the "Paid by Estate/Other" amounts.”

 

Here is what the executor/family agrees to:

 

"By signing below, the Executor or Family Representative, certifies that the "Paid by Estate/Other" amounts indicated here represent the total funds available from the estate and other funding sources to cover funeral, burial and cemetery expenses of the decedent."

 

As such, the requirement relating to verification of funding sources is really placed on the executor/family, not the provider.  In addition, note that verification is accomplished through a "self-declaration" by the family representative.  There is no expectation that providers check up on what they are told by the family, but there is an expectation that providers report funds to which they have access as the result of a pre-need agreement.  The Department will be looking at this issue on a post-reimbursement basis by taking random samples of claims and checking third party data sources relative to the deceased's available resources.  If we learn that the "self declaration" policy is not effective, it will be changed.

 

  1. Does the county reimburse cash advances that aren't counted toward the total expense limit as long as they are verified?

 

No.  If a cash advance item is not counted toward the total funeral expense limit, then it is not part of the total charges.  Reimbursement under this program is not made for something that is not included as part of the total charges.

 

  1. Why have a policy that limits countable goods and services to only those provided by funeral homes, cemeteries and crematories?  What about people who purchase their caskets from someone other than a funeral home?  You’re missing out on these expenses.

 

Prior to implementing this policy, there was no policy.  It was unclear what charges to count toward the limits and what charges not to count. The result was much confusion and inconsistent treatment of providers and families by counties throughout the state.

 

As such, we felt it was necessary to draw a line somewhere with regard to the goods, services and providers that would be considered for reimbursement under this program.  We decided to draw that line around the main providers of services, i.e., funeral homes, cemeteries and crematories, as well as the services that they routinely provide.  We know we're missing out on some services, but it seems a small price to pay for having some clarity about what to count and what not to count.

 

  1. Why have a policy that counts goods and services provided before death?

 

It seems reasonable to us to limit countable goods/services to those provided by funeral homes, cemeteries, and crematories.  It also seems reasonable to expect these providers, to the extent they want to be reimbursed under this program, to report everything they provided, whether provided before or after death.

 

  1. This question is regarding a funeral that took place before the new requirements went into effect in February 2005.  The funeral home is just now submitting the reimbursement request and says it can't get the signature of the family member who represented the deceased because that person is out of state and correspondence sent to them has been returned with no forwarding address.  Can the funeral director just sign for the family?  

 

No.  The county must get proof from the funeral home that they have tried unsuccessfully to reach the family representative.  The funeral home must verify that they tried to get the family rep's signature on the claim form and failed to do so.  In addition, assuming this verification is provided, someone from the county needs to sign the claim form as the family rep and make a note of the circumstances.  The funeral home must not sign as the family representative.

 

  1. Can funeral homes be reimbursed for cemetery expenses that they have cash advanced?
     

Yes.  Cemetery charges that are cash advanced by the funeral home count toward the $3500 total cemetery expense limit.  Anything that counts toward either the funeral or cemetery total expense limits may be considered for reimbursement.  Since the cemetery has already been reimbursed for such charges by the funeral home (i.e., they have been cash advanced), the funeral home could be reimbursed the amount of their cash advance (assuming the $3500 cemetery expense limit has not been exceeded).  We will revise the form to make it easier to bill and process regarding this situation.

 

  1. Can a denied request be resubmitted for payment one or more times as long as the resubmittal occurs within 12 months of the date of death?

 

Yes.  See the next few questions for additional information.

 

  1.  A funeral home submits a claim for reimbursement for $4,900.  The services and charges are documented in detail on the Statement of Funeral Goods and Services Selected attached to the claim.  The claim is denied because the total charges exceed $3500.  The funeral home adjusts the total charges and resubmits the claim.  Should the claim be considered for payment?

 

Yes, it should be considered for payment, but not necessarily paid.  If, for example, the adjustment was made to correct an error in the total charges (e.g., items were inadvertently counted toward total charges that were actually cash advanced with no service charge), or to reflect a change in goods or services selected, then the claim could be considered for payment and paid, if all other requirements were met.

  1.  I received a reimbursement request from a funeral home, along with the Statement of Goods and Services Selected.  The Statement indicates that the coroner’s fee and the cremation were cash advanced with no service charge, so I did not apply these charges to the $3500 total expense limit and, as such, was not able to reimburse them for these items.  Now, the funeral home is resubmitting the claim and has moved the coroner’s fee and cremation from the “cash advance” section on the Statement to the “goods and services provided” section.  Are they allowed to do that and should they now be reimbursed for those items?
     

They’re allowed to correct mistakes, but if they verified the cash advances with the original claim (which they are required to do), then they are not allowed to “un-verify” them for the purpose of obtaining reimbursement through this program.  If they did not verify the cash advances with the original claim, then the claim should have been denied for that reason.

 

  1. Can counties accept reimbursement requests for additional payments once the initial payment has been made?  For example, a funeral director receives a late bill from the florist. The county has already made payment to him of $1100.00 for the funeral costs. He now submits another request for reimbursement for the bill from the florist for $300.00.  Even with the $300 request, the total funeral charges still do not exceed $3,500.  Can the county pay him?
     

As long as the claim adjustment is made within the 12 month filing deadline, it should be considered for payment, subject to all existing reimbursement policy.  

 

  1. Do assets specifically designated as burial assets for the purpose of applying for Medicaid, including “exempt burial assets,” have to be used to pay for funeral and cemetery expenses?
     

Yes.  “Burial trusts,” “burial insurance,” “life insurance funded burial contracts,” and “burial funds” must be used to pay for funeral and cemetery expenses.  If the funeral or cemetery provider is named as the beneficiary of any such agreement, they must indicate the amount of funding from the agreement in the “Paid by Estate or Other” section of the reimbursement request.  In other words, such funds must be used to offset total funeral/cemetery charges.  If county staff find evidence in CARES that burial assets were declared when the deceased applied for Medicaid, but those assets are not indicated on the reimbursement request, the reimbursement request will be denied and returned to the provider for clarification.
 

  1. Sometimes, contributions have not been made to fully fund a burial asset (it is then not worth what the value appears to be on CARES), while in other instances the value far exceeds what is indicated in CARES, depending on when it was last verified by county staff.  Has any consideration been given to requesting verification of burial assets as part of the reimbursement process, right along with verification of cash advances?

 

We are considering making this policy change.
 

  1. Providers are asking counties what the “Statement of Goods and Services Selected” form is and where they can get it.  What should we tell them?
     

Tell them that the “Statement of Goods and Services Selected" is not a State of WI form.  Rather, it is mandated by the Federal Trade Commission (FTC) for all funeral homes to use with their customers.  We require that it be included with the WFCAP reimbursement request form simply because it is essentially an itemized statement of the funeral goods and services provided or cash advanced…all of the information that we need in order to make proper reimbursement under WFCAP.  We decided to require that the Statement be submitted along with the claim form so that providers would not have to transcribe everything from the Statement to our claim form.  The FTC does not mandate a specific format, only that certain information be present on the Statement.  The result, of course, is that there are countless varieties of the Statement.  All of that said, something called the "Statement of Goods and Services Selected" that itemizes goods, services and cash advance items must be submitted along with the claim form.  Claims submitted without a Statement must be denied.

See the following website for additional information regarding the Statement, as well as many other federal requirements that apply to the funeral business:

 

www.ftc.gov/bcp/conline/pubs/buspubs/funeral.pdf
 

  1. Can the state provide a listing for providers of county WFCAP contacts?

 

We provide a website address on the claim form that lists general county contact information.

 

 

This page last updated in Release Number: 05/02

Release Date: 04/26/05

Effective Date: 04/26/05

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