NM 1115 Waiver Filed
The New Mexico Human Service Department filed a Medicaid 1115 Waiver on April 25, 2012 for an expected “go live” of January 
1, 2014. Largely consistent with the Centennial Care Concept Paper released early this year, the waiver represents an ambitious model of integration of the management of physical, behavioral, and long term services. The HSD request for proposals to select the vendors to managed the integrated program is anticipated to be released around September 1, 2012. Waiver Submission to CMS42512
New Mexico Medicaid Modernization
New Mexico has released a Concept Paper describing
“Centennial Care”, the framework for ambitious changes to Medicaid. Built on the values of health care integration, it seeks to combine up to 12 existing Medicaid waivers into one 1115 Demonstration Waiver. In addition it would integrate long term care, physical care, and behavioral healthcare, all of which would be administered and managed by 3-5 managed care organizations. Building upon their experience with a single statewide managed care entity for the management of Medicaid and non-Medicaid behavioral health services, New Mexico has set forth a vision that while integrating behavioral health, affords specific protections to ensure that any savings from behavioral health are not shifted elsewhere. The state intends to release their draft 1115 waiver application soon in order to stay on track with an expected “go live” date of October, 2013.
IL Plan for Williams v Quinn Pending Court Approval
The implementation plan and tasks/timeline for resolution of the Illinois class action suit, Williams v Quinn has been submitted to the court and is pending approval. Both are available for public review. On September 30, 2010 the consent decree representing agreement to offer community living arrangements to over 4300 individuals with mental illnesses currently residing in Illinois institutes for mental disease (IMDs) was approved. Over 5 years, Illinois will offer transition to permanent supported housing or similar community settings for the class members.
Illinois ACT/CST Rate Review Report
In preparation for transitioning Williams class members into community services, Parker Dennison was asked to assess whether the current rates for team-based services, ACT and CST, are adequate to support expansion of capacity for these services. The findings can be found in the complete report available to the public. ACT CST Summary Rept 6-30-11Final
Proposed HCBS Waiver Rules Released
On April 15, 2011, the federal Centers for Medicare and Medicaid (CMS) released proposed rules with the stated purpose of increasing states’ flexibility for use of the 1915(c) Medicaid Waiver. There are three major
provisions:
Option to Combine Disability Groups into One Waiver
The rule would allow multiple disability groups (aged or disabled, developmentally disabled, and mentally ill) into one waiver. Currently, rules require a separate waiver for each disability group.
Clarification of Allowed HCBS Settings
The proposed rule expressly defines settings where HCBS services may be provided as well as adds a provision whereby the Secretary has full discretion to determine if a setting has “qualities of an institution”. Under the proposed rule, the HCBS setting definition requirements include:
- Must be integrated into the community
- Must not be located in building that also provides institutional or custodial care
- Must not be located on the grounds or immediately adjacent to a public institution
- Must not be a housing complex designed expressly around an individual’s diagnosis or disability as determined by the Secretary
- Must not have qualities of an institution as determined by the Secretary including:
- Regimental meal and/or sleeping times
- Limitations on visitors
- Lack of privacy
- Other attributes that limit the individual’s ability to engage freely in the community
Person-Centered Planning Required
Previously optional, the proposed rule would require the state to adopt a person-centered planning model. Under the proposed rule, the person-centered planning requirements include:
- Must be based on a person-centered functional assessment with defined requirements including identifying the individual’s strengths, preferences, needs (clinical and supports), and the individual’s desired outcomes
- Directed by the individual and may include a representative(s) freely chosen by the individual to assist and include a team of their own choosing
- Include paid and non-paid services and supports
- Result in a service and support plan in the most integrated community setting
- May result in a personal service budget which the individual may direct.
Comments on these proposed rules will be taken through June 14, 2011. Complete copy of the proposed rule–HCBSProposedRule04152011.
New Proposed Meaningful Use Recommendations
On January 12, the Health Information Technology Policy Committee published its proposed Stage 2 and 3 Meaningful Use recommendations for public comment. The comment period ends Feb. 25 and the Health IT Policy Committee will consider all of the comments in making its final recommendations this summer to the Office of the National Coordinator for Health Information Technology at HHS. It’s helpful to have at least some general direction where the MU requirements may be headed after 2012. The link below has a good summary. http://geekdoctor.blogspot.com/2011/01/proposed-stage-2-and-3-meaningful-use.html
EHR Return on Investment Webinar
Parker Dennison and Qualifacts Systems, Inc. hosted a webinar on January 21, 2011 discussing the return
on investment analysis on implementing an electronic health record for behavioral health. Presenters Susan Parker and Craig Fair, discussed:
- Operating metrics that will be positively influenced with the use of an EHR
- How you can predict the impact on your bottom line
- Examples of behavioral health providers who have experienced net financial improvement as a direct result of implementing an EHR
Download the handouts from this presentation here.
EHR Registration & Payment Begins
On January 3, 2011, the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) started registration for the Medicare and Medicaid electronic health record (EHR) incentive programs. Two states, Kentucky and Oklahoma, initiated incentive payments during the first week in January, and three additional states are expected be begin payments before the end the month.
http://www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp
New EHR Consulting & Tools
Parker Dennison and BMS, Inc. are please to announce an array of tools, resources and consulting services
designed to assist organizations with the selection of certified EHR technology, ROI measurement inclusive of the EHR incentives and the redesign of operational flows to meet the requirements of Meaningful Use. For more information http://parkerdennison.com/focus-areas/ehrmu. Parker Dennison and BMS, Inc. have a long history of assisting behavioral health organizations with operational improvements and implementation of new initiatives.
Goodbye UR, Hello “Quality Improvement”
With the interim final rule (MLRFinalInterimRule 11-22-2010) defining allowable costs to meet the health plan medical loss ratio (MLR) requirements under healthcare reform published on December 1, 2010, the federal Department of Health and Human Services (HHS) has given the managed care industry a significant incentive to evolve their utilization management practices. Under the Rule, health plans can include the costs of quality improvement activities as a medical expense toward the MLR, but not the costs of retrospective and concurrent utilization reviews.
Some health plans will no doubt attempt to re-label and slightly modify UR activities and argue that it is quality improvement but the most plans will likely shift focus to more pro-active care management, and clinical consultation for protocol outliers. This will also be consistent with the growing focus on evidence-informed and evidence-based practices.
Now is the time for providers to start the process of revamping their own utilization review processes to focus on quality improvement rather than utilization controls or singular cost containment.