Exhibit 1 

 

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 1 of 40 PageID #:2224
From: "Elwell, Doug" <Doug.Elwell@Illinois.gov>

To: "jjshannon@cookcountyhhs.org" <jjshannon@cookcountyhhs.org>,

"james.kiamos@cookcountyhhs.org" <james.kiamos@cookcountyhhs.org>,

"eakpan@cookcountyhhs.org" <eakpan@cookcountyhhs.org>

Subject: CountyCare payments

Date: Mon, 23 Sep 2019 12:58:14 +0000

All, 

Does the County have a solution? If not the state will need to enter into the discussions at some point as we

doubt all providers will make it with the delay being up to 9 months in payment. 

Doug 

Sent from my iPhone 

State of Illinois - CONFIDENTIALITY NOTICE: The information contained in this communication is

confidential, may be attorney-client privileged or attorney work product, may constitute inside information

or internal deliberative staff communication, and is intended only for the use of the addressee. Unauthorized

use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be

unlawful. If you have received this communication in error, please notify the sender immediately by return email and destroy this communication and all copies thereof, including all attachments. Receipt by an

unintended recipient does not waive attorney-client privilege, attorney work product privilege, or any other

exemption from disclosure. 

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 2 of 40 PageID #:2225
Exhibit 2 

 

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 3 of 40 PageID #:2226
From: "Mendonsa, Robert" <Robert.Mendonsa@Illinois.gov>

To: "Cox, Kimberley" <Kimberley.Cox@illinois.gov>, "Kiamos, James"

<james.kiamos@cookcountyhhs.org>

Cc: "Momon2, Angelique" <Angelique.Momon2@Illinois.gov>, "Doran, Mary"

<Mary.Doran@Illinois.gov>, "Ray, Laura" <Laura.Ray@Illinois.gov>

Subject: RE: Need info by c.o.b. today for CMS regarding CountyCare's backlog in making

payments

Date: Tue, 3 Mar 2020 21:19:08 +0000

Inline-Images: image001.jpg

Update. We are actually pretty current in our payments to CountyCare. This issue is the CountyCare does not

pay their claims. It goes to Cook County to pay and is combined with all other outstanding payments and

revenue.

From: Cox, Kimberley

Sent: Tuesday, March 03, 2020 3:12 PM

To: Mendonsa, Robert ; Kiamos, James

Cc: Momon2, Angelique ; Doran, Mary ; Ray, Laura

Subject: RE: Need info by c.o.b. today for CMS regarding CountyCare's backlog in making payments

Thanks. In anticipation of followup questions, is a basic explanation of what’s changed with the County’s

revenue flow possible to provide?

From: Mendonsa, Robert <Robert.Mendonsa@Illinois.gov>

Sent: Tuesday, March 03, 2020 2:49 PM

To: Kiamos, James <james.kiamos@cookcountyhhs.org>

Cc: Momon2, Angelique <Angelique.Momon2@Illinois.gov>; Cox, Kimberley

<Kimberley.Cox@illinois.gov>; Doran, Mary <Mary.Doran@Illinois.gov>; Ray, Laura

<Laura.Ray@Illinois.gov>

Subject: RE: Need info by c.o.b. today for CMS regarding CountyCare's backlog in making payments

Thanks Jim. Can we get a weekly update on these numbers?

Also, my finance tells me we are now 3 months behind in capitation payments still owing December through

February. Correct?

From: Kiamos, James <james.kiamos@cookcountyhhs.org>

Sent: Tuesday, March 03, 2020 2:43 PM

To: Mendonsa, Robert <Robert.Mendonsa@Illinois.gov>

Cc: Momon2, Angelique <Angelique.Momon2@Illinois.gov>; Cox, Kimberley

<Kimberley.Cox@illinois.gov>; Doran, Mary <Mary.Doran@Illinois.gov>; Ray, Laura

<Laura.Ray@Illinois.gov>

Subject: [External] Re: Need info by c.o.b. today for CMS regarding CountyCare's backlog in making

payments

Robert,

Please see the answers to your questions below.

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 4 of 40 PageID #:2227
1) 703,405 unpaid clean claims older than 30 days.

2) $203,719,407 in unpaid clean claims older than 30 days.

3) Primary reason for delay in payment is funding as all plan revenue flows through Cook County.

Let me know what else you may need.

Jim

Sent from my iPhone

On Mar 3, 2020, at 1:52 PM, Mendonsa, Robert <Robert.Mendonsa@Illinois.gov> wrote:

Jim, please see below. Can you get us answers to the first 3 today or advise when. Please copy everyone on

your response. Thanks.

From: Cox, Kimberley

Sent: Tuesday, March 03, 2020 11:56 AM

To: Mendonsa, Robert <Robert.Mendonsa@Illinois.gov>

Cc: Ray, Laura <Laura.Ray@Illinois.gov>; Doran, Mary <Mary.Doran@Illinois.gov>

Subject: Need info by c.o.b. today for CMS regarding CountyCare's backlog in making payments

Hi Robert,

I just got a call from our CMS liaison who informed that “CMS leadership” wants a status update by c.o.b.

today on the status of CountyCare’s backlog of paying claims. Specifically:

1) # of unpaid clean claims older than 30 days

2) Dollar amount of those claims

3) primary reason(s) for CountyCare’s delay in payment

4) what HFS is doing to monitor and resolve

If all of this is not at hand and readily available by c.o.b., please send me what you can provide, and I’ll

advise the rest has been requested and will be provided when received.

Thanks

State of Illinois - CONFIDENTIALITY NOTICE: The information contained in this communication is confidential, may be

attorney-client privileged or attorney work product, may constitute inside information or internal deliberative staff

communication, and is intended only for the use of the addressee. Unauthorized use, disclosure or copying of this

communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error,

please notify the sender immediately by return e-mail and destroy this communication and all copies thereof, including all

attachments. Receipt by an unintended recipient does not waive attorney-client privilege, attorney work product privilege, or any

other exemption from disclosure.

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 5 of 40 PageID #:2228
Be counted in the 2020 census. Visit www.cookcountyil.gov/census for more information.

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 6 of 40 PageID #:2229
Exhibit 3 

 

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 7 of 40 PageID #:2230
IN THE UNITED ST A TES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

SAINT ANTHONY HOSPITAL, 

Plaintiff, 

V. 

THERESA EAGLESON, in her official capacity 

as Director of the Illinois Department of 

Healthcare and Family Services, 

Defendant. 

No. 20 CV 2561 

Judge Andrea Wood 

Magistrate Judge Sunil Harjani 

DECLARATION OF ROBERT MENDONSA 

1. My name is Robert Mendonsa. I am currently employed with the Illinois

Department of Healthcare and Family Services ("HFS"). I have been employed with HFS since 

February of 2013. 

2. In my current role as the Deputy Administrator of Medical Programs, my duties

include monitoring and overseeing administrative, operational and performance activities related 

to the Medicaid managed care program in the State of Illinois. 

3. One of my job duties is to serve as a point of contact with hospitals that provide

medical services to Medicaid enrollees and the State of Illinois' six managed care organizations 

("MCOs"), which are (1) Blue Cross and Blue Shield; (2) CountyCare; (3) IlliniCare; (4) 

Meridian Health; (5) Molina Healthcare of Illinois; and (6) NextLevel Health. 

BIWEEKLY MEETINGS 

4. Part of my job duties as the Deputy Director of Medical Programs with HFS is to

facilitate discussions between hospitals providing Medicaid services and the MCOs. 

1 

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Mendonsa Declaration 

Ex. 1 

(OMITTED) 

 

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Mendonsa Declaration 

Exhibit 2 

 

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HFS 014265

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Mendonsa Declaration 

Exhibit 3 

 

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HFS 014266

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HFS 014267

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HFS 014268

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HFS 014269

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HFS 014270

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Exhibit 4 

 

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 25 of 40 PageID #:2248
From: Oliver, Tasha

To: HFS.AMrequests

Cc: Momon2, Angelique; Duszczak, Karolina; HFS Request

Subject: [External] RE: MCO ACCOUNT MANAGER ACTION: URGENT - Follow-Up Question due COB Monday, June 1st

Date: Monday, June 1, 2020 2:29:00 PM

Good Afternoon:

CountyCare reports that the average number of days from adjudicated to paid is 64.

Thanks,

David Allen

TashaLaJeanna Oliver, MBA

Managed Care Operations Manager

Cook County Health, Health Plan Services

Phone: 312.466.2929 | Mobile: 312.350.5048

Fax: 312.466.2997

“Give your smile away today ”

From: HFS.AMrequests <HFS.AMrequests@illinois.gov> 

Sent: Friday, May 29, 2020 2:33 PM

Subject: MCO ACCOUNT MANAGER ACTION: URGENT - Follow-Up Question due COB Monday, June

1st

Importance: High

MCO ACCOUNT MANAGER

05/29/2020

Health Plans –

Please respond with the average number of days between adjudication of a claim and payment of a

claim. Please respond by COB, Monday, June 1st.

Thank you.

HFS.AMrequests@illinois.gov

Jennifer Sawicki

HFS, Bureau of Managed Care

State of Illinois - CONFIDENTIALITY NOTICE: The information contained in this communication is confidential, may be

attorney-client privileged or attorney work product, may constitute inside information or internal deliberative staff

communication, and is intended only for the use of the addressee. Unauthorized use, disclosure or copying of this

communication or any part thereof is strictly prohibited and may be unlawful. If you have received this

communication in error, please notify the sender immediately by return e-mail and destroy this communication and

all copies thereof, including all attachments. Receipt by an unintended recipient does not waive attorney-client

privilege, attorney work product privilege, or any other exemption from disclosure.

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 26 of 40 PageID #:2249
Census 2020 Be Counted

Be counted in the 2020 census. Visit www.cookcountyil.gov/census for more information.

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 27 of 40 PageID #:2250
Exhibit 5 

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 28 of 40 PageID #:2251
From: "Gross, David" <DGross@team-iha.org>

To: "'Elwell, Doug'" <Doug.Elwell@Illinois.gov>

Subject: [External] FYI

Date: Fri, 22 Mar 2019 21:29:27 +0000

Attachments: 03-21-19_MCO_Oversight.pdf

Inline-Images: image001.jpg

Doug—

I want to apologize to you and the Director. I arrived late to the meeting and failed to provide copies to you

and the Director.

Take a look and let’s discuss your concerns after you have had a chance to review.

Dave

Dave Gross | Senior Vice President| Government Relations

T 217-541-1161 | M 217-836-3303 | dgross@team-iha.org

Illinois Health and Hospital Association

700 S. Second Street, Springfield, IL 62704

Your trusted voice and resource

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 29 of 40 PageID #:2252
MEDICAID MANAGED CARE: PRIORITY ISSUES 

Hospitals face an overwhelming array of challenges working with the six Medicaid Managed Care 

Organizations (MCOs) charged with serving more than two million Illinois Medicaid beneficiaries. IHA 

has identified priority areas where enhanced oversight of MCO operational performance, coupled with 

requiring the MCOs to immediately implement proven, common sense business practices, would lead to 

improved outcomes for patients and providers. 

Problem Lack of uniformity of key definitions related to MCO claims adjudication and 

service authorization terms. The MCOs use some terms interchangeably (e.g., 

rejection/denial), leading to confusion regarding how to appropriately resolve 

payment and authorization disputes.

Proposed Remedy MCOs should use uniform clear definitions for the following regularly 

misunderstood terms: Claims Rejections, Claims Payment Rate Adjustments, 

Claim Recoupment Adjustment, Claim Denial and Service Authorization.

Problem Non-uniform list of essential clinical information requested by MCOs to 

adjudicate and pay an otherwise clean claim. Each of the six MCOs have their 

own, unique list of clinical or other documentation, outside of the standard 

information reported on a claim, that may be required to support payment. 

Moreover, these lists change constantly, with little or no warning given to 

hospitals. Navigating these ever-changing payment rules increases the 

administrative burden on hospitals and diverts resources from patient care. 

Proposed Remedy Require the MCOs to use a single, standard list of essential clinical information or 

other documentation to support payment of claims. To provide stability, this 

standard list would be developed by HFS, posted on the agency’s website and 

only updated annually. 

Problem Non uniform claim coding and messaging. Each MCO has a proprietary list of 

codes that identify the reason a claim has been paid or not paid and any action 

that must be taken to change the claim from unacceptable to acceptable. The 

code descriptions often lack the detail needed for the hospital to determine why 

the MCO has reduced or refused payment, requiring staff to conduct substantial 

manual research to determine the real reason for the denial and whether the 

issue can be corrected. Adhering to six different sets of insufficiently defined 

instructions unnecessarily increases the administrative cost of seeking payment 

for services.

Proposed Remedy The MCOs should adhere to a single, standard list of payment determination 

codes that are cross-referenced with the national standard codes. This would 

provide uniformity and consistency to help providers bill correctly and effectively 

manage denials, and significantly mitigate the rising administrative costs being 

passed on to the provider community. 

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 30 of 40 PageID #:2253
Medicaid Managed Care Priority Issues 

March 21, 2019 

Page 2 

Problem Medical necessity documentation and service authorization uniform 

guidelines. Hospitals have noted wide ranging rules related to medical necessity 

and service authorization requests. Often MCO rules change with little or no 

notice. MCOs vary in how they confirm receipt of service authorizations, and 

many require a non-electronic, cumbersome system of faxing that is prone to 

error. Hospitals may not know if their requests were ever received. MCOs will 

often conduct audits after services are provided and take back payments

without giving providers sufficient notice or a rationale for why the funds are 

being recouped. All these obstacles ultimately result in significant administrative 

burden and cost on the hospitals, barriers to receiving payment, and delays in 

providing medically necessary care. 

Proposed Remedy A comprehensive and uniform set of common sense business practices related 

to service authorization process:

 MCOs must maintain and make available to providers an electronic

tracking system of all service authorization requests, including a tracking

number and identification of services being requested.

 MCOs must respond within four days, or 48 hours for urgent cases, and

if the MCO does not respond within these timeframes, the service is

deemed authorized.

 Once an MCO has approved a service, no further clinical information

should be requested to determine if the provider will be paid, unless the

services billed are substantially different than those approved by the

MCO.

 Once a service is approved, the MCO should not be allowed to

downgrade the service.

 MCOs should follow standard post-payment audit rules and give

providers sufficient notice and identify the reason for the recovery when

MCOs seek to take money back from providers.

 MCOs should be penalized when they deny payment for a service that

was authorized by the MCO prior to delivery, but claim that service

authorization was not obtained.

 MCOs should be penalized for claims that are denied due to insufficient

documentation when it can be shown that the original submission

contained all necessary information.

Problem Timely MCO requests for additional information and clarifying the timeline 

associated with clean claims for purposes of timely payment interest penalties 

under the insurance code. Often, hospitals receive a request for additional 

clinical information long after a claim has been submitted. The request for 

additional information has been deemed by the MCOs as justification that the 

timely payment provision of the Illinois Insurance Code does not apply once the 

request has been issued. Often, hospitals receive the request near the end of 

the 30-day required payment period, essentially delaying payment for a service 

and avoid paying the timely payment interest penalty.

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Medicaid Managed Care Priority Issues 

March 21, 2019 

Page 3 

Proposed Remedy MCOs should request any additional information necessary to adjudicate a claim 

within five days of receiving the claim. MCOs should not require the submission 

of additional information for a claim which the MCO previously approved. The 

request for additional information may only suspend the 30 day payment 

requirement under the timely payment provisions of the insurance code. The 

mere presence of a request for additional information should not remove the 

claims from a clean claim status in perpetuity. Once the additional information 

has been supplied by the hospital, the clock should begin on the balance of the 

30 days. This will incentivize the MCOs to respond in a timely manner.

Problem Automation of the calculation and payment of penalties and clear delineation 

of any payment under the timely payment penalty provisions of the Illinois 

Insurance Code. On the rare occasion when hospitals receive the timely 

payment interest penalty, the MCOs fail to identify the penalty on a payment 

voucher, making it nearly impossible to attribute the penalty to the correct 

claim. By not clearly identifying the applicable case due the penalty, the 

provider cannot determine if the payment is compliant with the statue. 

Furthermore, not all MCOs automatically calculate and pay the penalty, instead 

requiring the provider to separately request these payments. This added billing 

step increases the cost of doing business and often serves as a barrier to getting 

paid. Hospitals will simply decide to not “chase” a penalty payment due them 

because of the added administrative burden.

Proposed Remedy Providers need to be paid timely interest penalties in a transparent manner. 

MCOs should be required to automatically calculate timely payment interest 

penalties in accordance with the Illinois Insurance Code and separately identify 

payments for services from payment of interest. Both of these requirements are 

consistent with how interest is paid under the FFS Medicaid program. The 

provision makes the automatic calculation and reporting requirements 

consistent between the MCOs and the FFS system.

Problem Providers need to have the option of bringing payment disputes to an 

independent arbitrator much like how individuals can do so when appealing a 

coverage denial. Attempts to resolve payment denial disputes take too long 

and, after months of haggling, hospitals are given an offer to settle the disputed 

claim at a substantial discount. MCOs should be held accountable for improper 

denials. 

Proposed Remedy Providers should have the right, after exhausting their internal appeal rights 

within the MCO contract, to have the final decision of an MCO that denies 

payment of a claim, in whole or in part, to be reviewed by an external 

independent third party. 

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Medicaid Managed Care Priority Issues 

March 21, 2019 

Page 4 

Problem There has never been a verification of how much the MCOs spend on medical 

care. Although the state is required to verify the payout ratios of the MCOs, the 

Auditor General found that this has not occurred. Therefore, we do not know if 

the MCOs are in compliance with their contract with the state.

Proposed Remedy HFS should calculate the payout ratios reported by MCOs no less frequently than 

annually and post these calculations on its website. For an MCO not meeting the 

85 percent payout threshold, the MCO should refund to the State the difference 

between what was paid to medical provers and the payout ratio and 85 percent. 

MCOs that do not pay the refund should be excluded from the Medicaid 

program.

Problem Untimely MCO provider roster updates, resulting in denial of payment for 

services rendered while a contracted provider waits to be added to the publically 

viewable roster. Although HFS has centralized the credentialing process, the 

MCOs continue to deny claims due to untimely MCO updating of provider 

rosters once the provider has been placed under contract with the MCO. 

Frequently, MCOs will reject a claim submitted by a provider not contained on 

the MCOs publically available roster, despite the provider having a valid innetwork contract. Additionally, the delay in loading rosters with updated 

information creates an access to care issue for hospitals wishing to notify their 

regular patients that a new physician has become available under the associated 

MCO. This results in a period of time when the physician is in limbo and unable 

to bill and receive reimbursement from the MCO.

Proposed Remedy Any provider under contract with an MCO on the date services are provided to a 

covered enrollee should be reimbursed for medically necessary services, 

regardless of the provider being identified on the MCO’s roster. Because the 

MCOs currently have little incentive to load physicians timely, the MCOs should 

be required to update their rosters within seven days of all newly contracted 

providers. 

Problem MCOs are not adhering to the same payment timelines as the state’s FFS 

expedited provider list. The Illinois Pubic Aid code identifies providers who are 

financially vulnerable and who require regular payment of claims submitted. 

These providers are identified as expedited providers and are given priority for 

payment at the Illinois Comptroller’s office and are largely paid on a weekly 

basis. MCOs have been encouraged by HFS to make accommodations to pay 

these providers timely, but it is not currently required.

Proposed Remedy MCOs should be required to pay all hospitals qualifying under the expedited 

provider rules on a schedule at least as regular as the state FFS system pays the 

expedited provider list. MCOs may meet this requirement by entering into a 

Periodic Interim Payment (PIP) program. The parameters of a PIP program must 

be mutually agreed to and documented between the MCO and provider and 

must be voluntary. The program must assure that the hospital provider is paid 

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 33 of 40 PageID #:2256
Medicaid Managed Care Priority Issues 

March 21, 2019 

Page 5 

on a regular basis, consistent with the FFS system. The program should allow for 

a reconciliation provision for any overpayments or advances. 

Problem Hospitalization beyond medical necessity, resulting from lack of post discharge 

care coordination placement. Hospitals are increasingly being required to 

retain Medicaid enrollees in the hospital, beyond the date when the enrollee has 

been deemed ready for discharge by their attending physician. These “Beyond 

Medical Necessity” stays typically do not receive reimbursement resulting in 

additional hospital expenses that are not reimbursed. MCOs are required to 

coordinate placement or transfer to the appropriate setting of care post 

discharge but currently do not have an incentive to do so in a timely manner 

when the patient can remain in the hospital at no cost to the MCO. 

Proposed Remedy MCOs should be required to fulfill their obligations to arrange placement or 

transfer to the proper setting of care in a timely fashion, once notified by the 

hospital of a physician’s discharge order. Placement or transfer should occur 

within 24 hours, or the MCO should reimburse the hospital at a rate equal to the 

per day rate (per diem) for the associated stay, including any and all add-ons, 

such as Medicaid High Volume Adjustments (MHVA), Medicaid Percentage 

Adjustment (MPA) and Safety Net Hospital adjustments. These stays often result 

in unreimbursed cost for the most financially vulnerable hospitals, such as Safety 

Net and Critical Access Hospitals. 

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 34 of 40 PageID #:2257
Exhibit 6 

 

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 35 of 40 PageID #:2258
From: "Elwell, Doug" <Doug.Elwell@Illinois.gov>

To: Karen Brach <karen.brach@mhplan.com>, "Dawn.Kingsley@centerstone.org"

<Dawn.Kingsley@centerstone.org>, "Mendonsa, Robert" <Robert.Mendonsa@Illinois.gov>

Subject: Fwd: [External] RE: Request for Settlement of Harmony Claims

Date: Wed, 12 Feb 2020 16:42:36 +0000

Karen

I am concerned about this settlement. I value what you have accomplished in this type of situation in the past

and am asking if you can get this resolved.

Ms. Kingsley is copied so you can reach her directly.

Thanks in advance.

Doug

Sent from my iPhone

Begin forwarded message:

From: Dawn Kingsley <Dawn.Kingsley@centerstone.org>

Date: February 12, 2020 at 9:31:24 AM CST

To: "Elwell, Doug" <Doug.Elwell@illinois.gov>

Cc: "Mendonsa, Robert" <Robert.Mendonsa@illinois.gov>

Subject: Re: [External] RE: Request for Settlement of Harmony Claims

That is fine. Thank you for intervening. Would you mind copying me on your email. Thank you.

Dawn.

On Feb 12, 2020, at 8:07 AM, Elwell, Doug <Doug.Elwell@illinois.gov> wrote:

[External Email - Please check the email address before clicking on any links in the email.]

Dawn

I was under the impression Meridian was moving forward with all the settlements. With your permission I

would like to forward your email to Karen Brach the Meridian CEO.

Doug

Sent from my iPhone

On Feb 11, 2020, at 4:53 PM, Dawn Kingsley <Dawn.Kingsley@centerstone.org> wrote:

Hi Doug,

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 36 of 40 PageID #:2259
I wanted to check in as I believe Friday is your last day. Can you tell me where this stands and if anything came

out of the meeting yesterday?

Please let us know the next steps and how we can file a complaint. We still have not received the settlement

proposal promised by Meridian. Thanks for your help and best of luck to you in your new endeavors.

Dawn S. Kingsley, MSHA

Vice President, Payer Contracting & Strategy

p. (615) 463-6253 | m. (615) 957-1670

44 Vantage Way, Suite 400, Nashville, TN 37228

Connect With Us | Centerstone

From: Elwell, Doug <Doug.Elwell@Illinois.gov>

Sent: Thursday, February 6, 2020 6:33 AM

To: Dawn Kingsley <Dawn.Kingsley@centerstone.org>; Mendonsa, Robert <Robert.Mendonsa@Illinois.gov>

Cc: Melanie A. Adkins <Melanie.Adkins@centerstone.org>; Anne Tyree <Anne.Tyree@centerstone.org>; John

Markley <John.Markley@centerstone.org>; Marvin Lindsey <mlindsey@cbha.net>

Subject: RE: Request for Settlement of Harmony Claims

[External Email - Please check the email address before clicking on any links in the email.]

Dawn,

I am not an expert on the DOI process, but I will ask Robert Mendonsa to connect you to the correct people. On

Monday we will call this issue out. Today I will ask the Meridian President to address.

Doug

From: Dawn Kingsley

Sent: Wednesday, February 05, 2020 10:07 PM

To: Elwell, Doug <Doug.Elwell@Illinois.gov>

Cc: Melanie A. Adkins <Melanie.Adkins@centerstone.org>; Anne Tyree <Anne.Tyree@centerstone.org>; John

Markley <John.Markley@centerstone.org>; Marvin Lindsey <mlindsey@cbha.net>

Subject: [External] FW: Request for Settlement of Harmony Claims

Importance: High

Good Evening Doug,

Our billing and contracting teams have been working with Meridian for nearly 2 years to get unpaid claims

resolved dating back to 2017. Below is recent email communication between Meridian and our team at

Centerstone as we try to resolve claims that are nearly 3 years old. The unpaid claims total more than $300K for

DOS prior to the WellCare Harmony/Meridian merger. We have had numerous meeting, both in persona and via

phone. Our team has spent countless hours jumping through hoop after hoop trying to get these claims resolved

and paid for services provided to Medicaid members managed under WellCare Harmony. It has been an

exhausting and frustrating process as every time we adhere to their guidance Meridian come back with yet

another onerous requirement.

As you can see in the communication below we gave Meridian until January 31st to provide us with a settlement

proposal. We heard from them on January 22ndth saying they would have something by January 30th, 2020. As of

COB today (February 5, 2020) we have not heard back or received a promised proposal. We attempted to file a

complaint through the state website but it required us to submit individual complaints for each and every claim.

We are not able to submit individual claims complaints so we collectively decided to start with you to find out

what the right process would be to file a formal complaint with the State of Illinois Department of Insurance.

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 37 of 40 PageID #:2260
We have documentation of all communication, promises, instructions dating back to our work with Harmony and

then Meridian. We can provide as much detail as you and/or Meridian requires. We need to get these claims

resolved urgently and quickly.

Can you please provide me with some guidance on this process and we will be happy to work within those

guidelines. Thank you for your time and attention to this issue.

Dawn S. Kingsley, MSHA

Vice President, Payer Contracting & Strategy

p. (615) 463-6253 | m. (615) 957-1670

44 Vantage Way, Suite 400, Nashville, TN 37228

Connect With Us | Centerstone

From: Karen Amazigo <Karen.Amazigo@mhplan.com>

Sent: Wednesday, January 22, 2020 1:39 PM

To: Melanie A. Adkins <Melanie.Adkins@centerstone.org>

Cc: Karen Brach <karen.brach@mhplan.com>; Anne Tyree <Anne.Tyree@centerstone.org>; John Markley

<John.Markley@centerstone.org>; Tasha Brown <Tasha.Brown@mhplan.com>; Michelle Mittleman-Horner

<Michelle.Mittleman-Horner@mhplan.com>

Subject: RE: Request for Settlement of Harmony Claims

[External Email - Please check the email address before clicking on any links in the email.]

Hi Melanie.

Thank you for your email. As mentioned in my voicemail message, I will forward the settlement proposal to our

leadership team for review and consideration. We will provide a response with our decision by January 30th.

Regards,

Karen

Karen Amazigo

Manager of Network Development

Meridian

300 South Riverside Plaza, Suite 500

Chicago, IL 60606

www.mhplan.com

p. 312-705-2900 x28302

f. 312-508-7225

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From: Melanie A. Adkins <Melanie.Adkins@centerstone.org>

Sent: Wednesday, January 22, 2020 12:12 PM

To: Karen Amazigo <Karen.Amazigo@mhplan.com>

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 38 of 40 PageID #:2261
Cc: Karen Brach <karen.brach@mhplan.com>; Anne Tyree <Anne.Tyree@centerstone.org>; John Markley

<John.Markley@centerstone.org>

Subject: Request for Settlement of Harmony Claims

Importance: High

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Hi Karen,

I am following up with you regarding the unpaid Harmony claims. I left you a voicemail, but wanted to follow up

with an email regarding the details.

Our leadership team reviewed the spreadsheet of claims. We also met internally for discussion. Our AR team is

concerned about the fact that the spreadsheet does not really give much information. For example, there is no

explanation for individual claims as to why each one was assigned a particular bucket. We would have to research

every single claim on the spreadsheet to determine whether we agree with the bucket. We are no longer willing to

spend staff time going through these claims.

Here are the issues:

At a glance, we know for sure that at least some of the claims are in the wrong bucket.

$300,000 + is still owed to Centerstone

On April 9, 2018 we were advised by Claudia that she would get the timely filing waived.

We are charged $3.90 as a copay for claims because we are an HFS Provider. No other health plans assess

this charge to us. We are requesting to have it waived on our claims and to be paid for those claims to

which it was assessed.

Last year our Mobile Crisis was cut, then it was reinstated. We are requesting payment for those claims

that were denied during that period of time.

Karen, our senior leadership team is extremely concerned about these outstanding claims and are watching the

progress very closely. At this point, Centerstone is unwilling to continue our attempt to resolve every single

claim. There are simply too many claims with too many issues. It feels like we have not made any progress

toward getting reimbursement even after a tremendous amount of effort.

This email is an official request for Meridian to propose an appropriate settlement. We have gone without

payment far too long. There will be no more staff hours spent combing through claim by claim. I have been

instructed by leadership that Centerstone is requesting fair and appropriate settlement offer from Meridian by

January 30th. If we have not received an offer by this date, we will file a complaint with the Commissioner of

Insurance immediately on the morning of January 31st.

Please understand that Centerstone wishes to be a good partner in providing care for Meridian members.

However, we can no longer carry this large amount of outstanding AR.

Thank you and I look forward to hearing from you.

Melanie Adkins

Senior Director of Payer Contracting

p. (615) 948-1058

Connect With Us | Centerstone

Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 39 of 40 PageID #:2262
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Case: 1:20-cv-02561 Document #: 57-1 Filed: 06/29/20 Page 40 of 40 PageID #:2263