With the support of the Blue Shield of California Foundation, the CIBHS DMC FORUM creates a collaborative think tank to support county behavioral health leaders and key local stakeholders in the planning and implementation of the Drug Medi-Cal Organized Delivery System. Working with CBHDA, the FORUM will identify issue areas that warrant a policy and practice deep dive. We know that there is a rich base of successful practices, programs,and innovation, going on in counties throughout the state. We want to capture these ideas.
In 2010, the leadership of the mental health and substance abuse treatment fields, both public and private, successfully advocated to include mental health and substance use disorder services as one of Ten Essential Benefits in the Patient Protection and Affordable Care Act (PPACA). In 2014, the California Department of Health Care Services applied for an 1115 Medicaid Waiver to initiate a Drug Medi-Cal Organized Delivery System in California. This demonstration project is one earlier step in the larger health care system changes that includes California Medi-Cal 2020.
I had the opportunity to attend the County Behavioral Health Directors Association (CBHDA), Substance Abuse Prevention and Treatment (SAPT) Committee and to meet with county administrators to discuss the Drug Medi-Cal Organized Delivery System Waiver (DMC-ODS) Implementation. There are 10 counties that have submitted Drug Medi-Cal Organized Delivery System Implementation Plans including, San Francisco, San Mateo, Riverside, Santa Cruz, Santa Clara, Marin, Los Angeles, Contra Costa, Napa and Monterey. DHCS reports that San Francisco, San Mateo, Santa Cruz, and Santa Clara County Plans have been approved. After reading each of the posted plans, I am impressed by the diversity of each county system, its stakeholders, providers, service populations and the enormity of the changes that are on the horizon.
Last week the Department of Health Care Services released the CMS approved DMS-ODS Intergovernmental Agreement, which will serve as the contract between the Department and the counties implementing the DMC-ODS Waiver Standard Terms and Conditions. The creation of a full continuum of care for Medi-Cal beneficiaries for substance use disorder treatment is revolutionary. As stated in the contract, “the objective of this Intergovernmental Agreement is to make SUD treatment services available to [all] Medi-Cal beneficiaries through utilization of federal and state funds … for reimbursable covered services rendered by certified DMC providers.” Following this good news, I had the opportunity to speak with the Director of the San Mateo County Behavioral Health and Recovery Services, Stephen Kaplan LCSW, about his County Plan which was the first plan submitted to CMS back in January 2016 – it was the first plan approved in April 2016 – and will be the first implemented this fall, if all goes smoothly. When asked how SMCO achieved all of these firsts, Steve commented that the ideas and innovations contained within this plan are the culmination of the work of many dedicated professionals and stakeholders over many years, as incremental changes were made to establish Health Care Reform in San Mateo County.
With the support of the Blue Shield of California Foundation, the CIBHS DMC-ODS WAIVER FORUM creates a collaborative think tank to support county behavioral health and substance use disorder leaders in the planning and implementation of the Drug Medi-Cal Organized Delivery System. Working with the CBHDA SAPT Committee, the first FORUM was held in September 2016 and focused on the transition from the current county alcohol and drug services administration to a specialty managed care organization.
One of the key components of the California DMC-ODS 1115 Waiver approved by CMS in August 2015, is the use of selective contracting arrangements to create a network of providers meeting the Terms and Conditions of the Waiver. Selective Contracting is one of the primary means used by health care insurers to control costs in a managed care environment vs. contracting practices used in a grant environment. Selective Contracting limits beneficiary freedom of choice to those providers within the selected network. On December 5, 2016, the staff of the CIBHS DMC-ODS Forum and the CIBHS DMC Training Project, hosted a Webinar on Selective Contracting. Bill Manov, Ph.D. and three county administrators, each at different stages of the application and implementation process, were invited to provide the fundamentals and lessons learned over the past year.
With the support of the Blue Shield of California Foundation, the CIBHS DMC-ODS WAIVER FORUM creates a collaborative think tank to support county behavioral health and substance use disorder leaders in the planning and implementation of the Drug Medi-Cal Organized Delivery System. Working with the California Behavioral Health Directors Association (CBHDA) Substance Abuse, Prevention, and Treatment (SAPT) Committee, the second FORUM was held in December of 2016, to explore Building Successful Partnerships with Managed Care Plans. A prevailing challenge for individuals served by the public-sector safety net is their lack of access to physical and behavioral health services. With the expansion of Medi-Cal eligibility, health care is available to them for the first time; however, treatment for substance use disorders remains a carve-out and requires planned coordination. We will now need to build the on ramps and bridges between providers for these individuals to access coordinated care.
When a county agrees to opt into participation in the DMC-ODS, it does so as a managed care organization known as Prepaid Inpatient Hospital Plan (PIHP). The county as such agrees to comply with all federal managed care plan conditions and requirements, including very defined standards and requirements related to the protection of the beneficiaries. Under the administration of the Substance Abuse Prevention and Treatment Block Grant services, SUD delivery system prioritizes standards related to waiting list fairness and a great deal of diversity in service access. These standards and practices change and will develop under the DMC-ODS in an environment of service entitlement, beneficiary rights, and care coordination.
DHCS monitors the quality of all care provided to Medi-Cal beneficiaries in a number of ways. For mental health and substance use disorder benefits, the Center for Medicare and Medicaid Services requires that states which contract with Medicaid Managed Care Organizations (MCO) or Prepaid Inpatient Health Plans (PIHP) conduct an External Quality Review (EQR) of each entity. These regulations have been in effect since January 2003. The DHCS Mental Health and Substance Use Disorders Services Division contracts with Behavioral Health Concepts, Inc. (BHC) to provide EQRO services for Mental Health Plans and for DMC-ODS opt in counties or PIHPs. At the June 2017 CBHDA Substance Abuse Prevention and Treatment Committee meeting, Rama Khalsa, Ph.D., Director DMC-ODS EQRO, provided an overview of the work that has been done by BHC to develop quality outcome measures, in addition, those system measures required by the Waiver Special Terms and Conditions. This work has been done in collaboration with counties through a Clinical Steering Committee over the past year. Core areas for measures include the DMC-ODS Waiver Special Terms and Conditions, metrics linked to timely access to care, positive client treatment outcomes, initiation, engagement, retention, and recovery supports.
“Diversity”, “underrepresented”, “underserved” – these are terms that we often use to describe populations that require cultural and linguistic considerations in service provision. Counties and their contracted providers choosing to participate in the California Department of Health Care Services (DHCS) Drug Medi-Cal Organized Delivery System (DMC-ODS) demonstration project through the State Medicaid Plan waiver are responsible for compliance with the provisions of the Code of Federal Regulations Section 438 (42 CFR 438) pertaining to Medicaid managed care health plans. These requirements include specific instructions for oral and written communication with enrollees in non-English languages and enrollee access to culturally competent services. (DHCS) also, requires counties to comply with National Standards for Culturally and Linguistically Appropriate Services (CLAS) established by the federal Office of Minority Health. These seem like reasonable DHCS provisions for publicly-funded substance use disorder (SUD) service providers.