Showing posts with label DMA. Show all posts
Showing posts with label DMA. Show all posts

04 June 2013

The Lost Art of LISTENING.

Before I launch into what will probably be my last post (though don't hold me to it), I want to introduce you to Raleigh Attorney Knicole C. Emanuel with Williams Mullen and her most excellently well written and legally sound Medicaid law blog. In my humble opinion, anyone who can so eloquently and factually draw a strong comparison and contrast between Shakespeare's "MidSummer's Night Dream" and the Medicaid providers' prepayment nightmare is nothing short of a poetic knight in shining armor (yes, chicks can be knights too - why not?)

Now, on with the show...

So, people keep asking where I've gone? Commenting that they've not heard much from me lately... Well, the truth is, that while I have been known to talk to myself on occation, there are some conversations that really need a active partner for successful dialogue. 

Frankly, I'm all talked out at the moment.

American author and journalist, Ernest Hemmingway was quoted as saying, "I like to listen. I have learned a great deal from listening carefully. Most people never listen."

Stephen R. Covey, author of The 7 Habits of Highly Effective People: Lessons in Personal Change said, "Most people do not listen with the intent to understand; they listen with the intent to reply.” 

Therein lies the problem. Nobody's listening.

Everyone has something to say in this Medicaid quagmire - the MCO's and LME's have plenty to say, providers have even more to say, DHHS and DMA have their say, facilities and group homes have something to say, advocacy groups keep trying to have their say, consultants and lobbyists get paid the big bucks to keep saying stuff, and members of the North Carolina General Assembly always seem to have the final say... and don't even get me started on the recipients and their family members that most everyone seems to conveniently forget in all this. 

Nobody can keep the stories straight, not even (and often, especially) the media, becasue it appears the right hand doesn't know what the left hand is doing while everybody's busy with their own personal diatribes and ass-saving.

Everybody's talking but nobody's listening.

Nevermind all of the asinine bureaucratic dynamics at play in the dirty politics of the NC Medicaid system - the inappropriate friendships, roles, relationships, mothers / daughters / board members, ethical conflicts of interest, and who's scratching who's back. Yep, we know about all that.

There are way too many egos on the line here (not to mention the obscene amount of money invested), meanwhile we continue to rearrange the deck chairs on the Titanic while ignoring the real issues of human concious. That's right, I said it again.

I find that this is especially true of the current political climate in North Carolina... For the first time in just over 100 years, the Republican party has finally won back the driver's seat and they seem to be hell-bent on making up for lost time with issues far more "important" than the welfare of our state's most vulnerable citizens, with such utter nonsense as nipples, fracking, abortion / right to choose, ending size limits for K-3 public school classrooms, teaching about abortion risks in public schools while lifting smoking bans on college campuses, imposing rediculous voting restrictions and flat out denying many the right to vote, slashing unemployment benefits, requiring a 2 year waiting period prior to divorce (ironically dubbed the Healthy Marriage Act), vain attempts to negate the first amendment with a state religion, and arresting peaceful protestors, among other idiocy. 

Handbasket anyone?

What with all that debauchery going on, who has time to worry about the threat of homelessness to residents of NC group home facilities (yet again)? Or whether developmentally delayed recipients and their tired-ass exhausted families have the resources to make it through yet another day, or even if they do - if they are actually receiving the services they are entitled through all this slimey red tape? 

I mean really? Who cares? We're such a small minority of the State's population when compared with the number of citizens who have nipples, for Christ's sake.

And speaking of Christ... Conservative politicians love to use the Bible as a platform and foundation for their arguments and justifications and while I've been known to agree with certain positions, it should be noted that countless infamous American psychopaths (Charles Manson, Jim Jones, Fred Phelps, etc.) have also used the good book as sources of inspiration and justification... just sayin'.

My Christ is not wrathful nor boastful, not judgmental nor unknind, and is not dis-compassionate nor cruel toward fellow man nor the world we live in. In the documented lifetime of Jesus, he exhibited love and compassion to all, even those who sought to destroy him and especially for those who could not do for themselves. 

I believe Christ to be alive in the very essence of our collective being, our hearts if you will, a state of mind we all should strive toward. --A perpetual state of love and forgiveness... a state of grace and joy I witness every single day in my own special daughter, Isabel, and her special peers. 

Where the hell are our priorities?

It's way past time for the North Carolina "powers that be" to start listening more to the people, their constituents and voting public, who must live with, and at times suffer from, the repercussions of their actions and decisions. 

You do NOT know what is best for me and mine; that, I can guarantee you. And I'm certainly not in the minority there.

Perhaps if everyone suddenly, miraculously began to listen more, really listen, and made an honest attempt at understanding one another, as I believe the late Steve Jordan had hoped, we wouldn't require knights in shining armor to mitigate such a shameful Comedy of Errors... though sadly, nothing seems to grab attention these days (and further waste taxpayer dollars) quite like a good ole American law suit, eh?

Hang in there folks.

25 February 2013

The NC Outpatient Mental Health Zeitgeist

-----Original Message-----
From: Geoffrey Zeger
To: ncadvocacy
Sent: Sat, Feb 2, 2013 4:34 pm
Subject: The NC Outpatient Mental Health Zeitgeist

NOTE: The following is somewhat long but is a reflection of the recent topsy-turvy, sinusoidal, and duplicitous events in the NC Outpatient Mental Health setting.......

During the summer of 2012, while I was standing outside of a clinic where I contract waiting for my next client, a car rapidly pulled up and out jumped 4 stony faced people with briefcases and a purpose in their steps as they entered the clinic.

It was an unannounced Medicaid audit.

Many clinicians and agencies knew these were occurring so it was not completely unexpected. At this particular free-standing private clinic which accepted Medicaid there was some anxiety (as any audit would produce) but we were pretty confident about our work - electronic medical records had fail safes for compliance, supervision occurred regularly, and the Clinical Coverage Policies for Medicaid were followed.

Over the next few months as the audit progressed a surrealistic Russian style bureaucratic nightmare occurred. Medical records were requested by the auditors and submitted by the clinic. CCME (Carolina Center for Medicaid Excellence) who was doing the audit would say 'we didn't get the records' and be elusive and dodgy. Medical records were re-submitted - hand delivered. Feedback from CCME was that the Treatment Plans did not meet standards. The Treatment Plans were being developed in line with the posted Clinical Coverage Policy and they were also in line with the recommendations of one of the LME/MCO's right over the county border but after much back and forth CCME continued to say they were not in compliance. CCME did not provide a clear indication of what compliance was nor did they provide a clear template for the Treatment Plans. (NOTE: The LME/MCO from the nearby county said the clinic's Medical Records per their site review were at a 92.5% accuracy!!!).

Staff at the clinic worked diligently to cooperate with CCME but every attempt at cooperation was met with a shift of the carrot on the stick. Conference calls were scheduled, emails were written, repetitive requests for clarification were pursued without any success or resolve.

The clinic was then put on a "pre-payment review" meaning claims for services rendered were not paid until the records were reviewed and approved. 'Pre-payment review' is an unguided process that could take 30 days - the approval of records is based on unclear standards so any clinical services rendered were like the lottery - maybe they'll get reimbursed if someone somewhere says documents meet some kind of unknown standards....or maybe they won't get reimbursed at all.

Eventually, so much unproductive hoop jumping occurred and time was wasted that a deadline for acceptance by the local LME/MCO came due. Because of the delays by the CCME, the LME/MCO which went live on 2/1/13 said to the clinic 'we can't enroll you' due to the 'pre-payment' status.

With only 3 days of lead time, over 100 clients - some of which were children in foster care or with PTSD or within the Juvenile Justice System - had to suddenly be terminated from treatment and referred to other agencies. Fortunately, the clinic will continue - contracted with the other county LME/MCO and accepting private insurance.

Was this top-down inefficient State bureaucracy? Was this effective Public Mental Health policy? Was there any consideration for how this would impact service provision and the clients? Was this purposeful - intended sabotaging of a clinic in order to reduce the number of providers within a community and save Medicaid dollars? Is this the CCME's way of insuring 'Excellence?'

I, and my colleagues who provide Public Mental Health services and who have weathered many pressures and changes, are not naive about accountability - we are ready to stand accountable and provide appropriate services with appropriate billing and documentation. I understand there are economic pressures at hand here but the current zeitgeist of audits, regulations and site reviews seems like a witch hunt and feels like a displacement for the past sins of others (http://www.inthepublicinterest.org/article/reform-wastes-millions-fails-mentally-ill). With the laser beam aimed at service providers - purposely geared to finding the smallest of errors in an effort to go 'GOTCHA' the zeitgeist is a culture of fear in order to insure accountability to DMA, CCME, DHHS, CMS, EDS, and the LME/MCO. Well what about accountability to our clients? Have policy makers forgotten about the clients in an effort to weed out the service provider playing field?

As a side note, it was rumored - and it may just be urban legend - that Medicaid auditors were paid based upon how much money they generated from the audit. If anyone has more information on this I would love to hear it - but at the community level it is understood that the contracted auditors were paid based upon how much money they were able to save Medicaid - how many claim denials they could find and how much money they were able to claw-back.

Wouldn't this contractual arrangement be considered a kickback?....'the more money you save or make us the more you will get from us?' Aren't kickbacks considered illegal within the Medicaid and Medicare system?

Clinicians, Clinics and Agencies believe that there has been an INTENDED consequence with the tightening of regulations (such as CABHA and Medicaid Waiver) - the intention is the eventual reduction of the number of private agencies that provide outpatient Mental Healthcare. Both, agencies that do enhanced services as well as core services, are being purposely circuitously and indirectly liquidated. When looking at lists of agencies that accept Medicaid over time, there was a 50% reduction of agencies after CABHA. With the implementation of the Medicaid Waiver the list has dwindled even further. Initially LME/MCO's have been accepting virtually all agencies that apply but it is anticipated that over the next year the bonsai tree will be trimmed even further with reviews of 'outcome measures.' More and more agencies will not be able to sustain. It is presumed that the final goal is to have a few large agencies contracted across the state.

Now, be advised that I have seen with my own eyes heinous service and billing improprieties in 2005 and 2006 and received backlash from profiteers when I called out inappropriate activities....so, I agree that it is necessary to set clear standards and hold providers accountable... HOWEVER, the zeitgeist is an over-rotation.

Let's see how the pendulum swing, tightening of the noose and reduction of reimbursements is working....

One of the larger agencies that has satellite offices in 15 counties in the central NC area just closed two of it's offices in 2 counties. In a different county where this large agency still has an office the pay for clinicians was cut, then cut again, then cut again, and a colleague of mine who works at this agency said that there were sweeping layoffis in her office. What is interesting is that many community clinicians believed this big multi county agency was one of the golden children that would sustain and still be standing while all the other 'mom and pop' or 'pop up' agencies were dissolved. Well, it seems like no one is immune anymore.

Another colleague of mine described how his multi county agency had radical re-structuring recently, specific Medicaid services were cut and the providers of those services were laid off, and there were across the board pay cuts.

Clinicians have no recourse either - 'if you don't like the pay cut then you can always try to find another job...wait...there are no other jobs since everyone else is closing so I guess you are stuck.'

On another side note, I recently head about a survey of private Psychologists who had been accepting Medicaid. The survey showed that over 40% of them intended to stop taking Medicaid clients due to the increase of regulations and requirements and reduction of reimbursements (all of which makes service provision cost and time prohibitive). Many of these surveyed Psychologists had over 8 years of experience - the intended consequence of reducing providers ALSO reduces your qualified and experienced professional base - these are the providers who know the clients and know the community and know the collateral resources.

I am aware of several private multi-county/multi-provider agencies that used to accept Medicaid clients but have stopped due to the cuts in rates and arduous regulations. What is interesting is that these private non-CABHA agencies provide excellent care, are preferred by clients, and ironically they bill a FRACTION of what CABHA agencies bill.

On February 1st a therapist from NC had an 'opinion' published in the Washington Post called:
"The risk of skimping on mental health funding"
Below is the link to this article which describes his frustrations with the Medicaid cuts in Southern Pines:

http://www.washingtonpost.com/opinions/the-risk-of-skimping-on-mental-health-funding/2013/02/01/5cdf8ad4-6ba6-11e2-ada0-5ca5fa7ebe79_story.html

Since you may have to do a free 'Register' with the Washington Post online to see the article, here is an excerpt:

For mental health providers in North Carolina, 2013 marks another year of cuts to Medicaid reimbursement rates, which have declined steadily since 2008. States are responsible for a larger portion of mental health services than they are for physical services, which means mental health is hit hard by state budget negotiations. More than $4.3 billionhas been slashed from state mental health budgets nationwide since 2009, according to the National Association of State Mental Health Program Directors. South Carolina, Alabama, Alaska, Illinois and Nevada are among the states that have had the deepest cuts.

The director of our clinic in Southern Pines, N.C., in the center of the state, has told me that this year’s cuts are likely to force us to close. Our facility offers mental-health and substance-abuse counseling to 75 to 100 clients a week, half of whom are 18 years old or younger. Typically, they are referred to us from child protective services, doctor’s offices or the local domestic violence/sexual assault agency.

When the events at the service delivery level are brought to policy makers' attention, I deeply resent their disregarding platitude of "oh well....we know change is hard." Well, it has been change (2001 divestiture and privatization), and change (2005 slashing community support), and change (2006 ValueOptions authorization policy changes) and change (2010 CABHA), and change (2012 Medicaid Waiver) and change (2013 Medicaid rates rates slashed 40% effective 1/1/13 then returned to prior rate on 1/23/13 with delays of payment for 1/13) and change (2013 CPT code changes and Medicaid rate and service time reductions). You don't know how many times I have had to say to clients "....I am sorry but there are NEW Medicaid regulations which will effect you in the following way..." You don't know how many of my colleagues have said to me "....the agency where I was working closed....do you know who is hiring...."). 


Furthermore, I resent the proverbial 'pot calling the kettle black' when Community Agencies, Individual Clinicians, and Private Practices accepting Medicaid are being scrutinized and audited to the point of being inoperable ALL THE WHILE there is waste and mismanagement at the top - DMA mismanagement (http://pulse.ncpolicywatch.org/2013/02/01/problems-identified-by-medicaid-audit-largely-result-of-nc-republicans-own-budget/), cost over runs with Computer Sciences Corporation (http://www.newsobserver.com/2012/06/17/2142627/state-contract-for-updating-computer.html), "structural flaws," and more (http://www.wral.com/audit-mismanagement-costs-nc-medicaid-system-millions/12048026/).

I hope McCrory means what he says ( “We want to make sure that the money that’s supposed to help people is going to them, not to the administrative cost.”) and that 'Medicaid Reform' will have a positive result. I hate to be a 'Negative Nick,' but my fear (based on experience) is that if you squeeze on one side of the tube of toothpaste it gets smooshed (yes...a real word) to the other side....in other words, the ATTEMPT to reduce administrative waste may actually make its way down to the community level in the form of service and provider cuts. We shall see.....

I continue to provide services to Medicaid clients and IPRS clients through contracts with agencies, but it is unclear how much longer I will be able to provide Medicaid services through my own private practice. More to be revealed.


Please forgive the long ramble. I haven't written for a while and a lot has happened. Feel free to write back with your experiences, thoughts, and or comments.

Geoffrey Zeger, ACSW, LCSW
(919) 286-[ redacted ]
[ email address redacted ]

IMPORTANT: The sender intends that this electronic message is for exclusive use by the person to whom it is addressed. This message may contain information that is confidential or privileged and exempt from disclosure under applicable law. If the reader of this message is not an intended recipient, be aware that any disclosure, dissemination, distribution or copying of this communication, or the use of its contents, is prohibited. If you have received this message in error, please immediately notify the sender of your inadvertent receipt and delete this message from all data storage systems. Thank you.

21 February 2013

Maintaining Mental Health Services for All

Maintaining Mental Health Services for All

Help Dr. April Harris-Britt and staff continue to serve children, adults, and families who will lose access to much needed mental health services in NC.

[ original post and fundraising page ]

This campaign is to raise legal funds, so that we can continue to fight for the children, adults, and families who will have limited or no access to much needed mental health services.

Short Summary

Our mental health agency has served individuals in our community for 8 years. We provide therapy for children and adults of all ages and backgrounds. A considerable portion of our work is focused on working with children in the foster care system, children who have been abused, and those with developmental disabilities. We provide psychiatric medication management, parenting classes, social groups, and psychological evaluations. We employ more than 25 people, including a Psychiatrist, Psychologists, Counselors, Social Workers, a LMFT, support staff, and even a local high school intern. We are a group of highly skilled, dedicated clinicians who remain committed to serving individuals of all backgrounds and needs, including the Medicaid population ignored by many others. We are requesting your help to continue doing so.

As you have probably heard, there has been enormous scrutiny of the NC Medicaid program and mental health services over the past few years. In a recent effort to revise and improve the system, a process was put into place that has disproportionately and adversely affected licensed independent providers such as at our Agency, and our ability to offer Medicaid services in the future

One such process involves the State requiring providers to submit all of their paperwork to a contracting agency called CCME that will then review and possibly approve payment to be made months after the client has been seen. There is no surprise that CCME has many flaws, inaccuracies, and inefficiencies in their system for monitoring providers. Even worse, they have a financial advantage to rejecting the claims – they get to extend their contracts for saving money. A CCME representative told us directly that they would be "working themselves out of a job" as they moved people off of prepayment reviews. A CCME representative told us directly that there are "tricks" that could ensure that we were taken off of prepayment.We have not tried any tricks as we naively believed that the system would work out!

Believe it or not, providers can not appeal this process. Within the past few weeks, numerous small, large, and long term providers in the area have already either gone out of business completely or stopped taking Medicaid. You will likely be hearing more and more about providers who have either gone out of business or who are no longer going to provide such Medicaid services.

These are a few links that may be helpful for you to put the story into context and to understand that laws have been broken by the DMA/DHHS (the Agency that runs Medicaid), not the providers.

http://www.wral.com/audit-mismanagement-costs-nc-medicaid-system-millions/12048026/

http://medicaidlawnc.wordpress.com/

http://www.wral.com/nc-auditor-dhhs-improperly-paid-580k-in-overtime/12108305/

http://www.wral.com/providers-getting-squeezed-out-by-medicaid-rules/12085183/

The answer to these political problems should not be to cut Medicaid or to limit the number of providers. If we do, there will be individuals in our schools, workplaces, and communities without needed mental health services. They will likely face higher frequencies of academic, legal, and negative societal outcomes.

I have filed several legal motions due to this being an unconstitutional action and the DMA/DHHS/the State not following policies and procedures to support providers and families needing these services. Our Attorney, Knicole Allen Emmanuel has worked in the State Attorney General’s Office in the past and is now fighting on behalf of providers and small business. We need your help to raise $25,000 in legal funds to fight this process. The outcome of this fight may help establish a precedent that could benefit others. Any amount raised over this amount will be used to cover services for the many families who have already lost their therapy. No amount is too small and we do appreciate your support.

Other Ways You Can Help

If you can not make a contribution, we understand. But please share our campaign with others and spread the word about how these types of actions can and will impact the children and families in our schools, neighborhoods, and communities.

14 February 2013

FW: [ProviderNet] Hundreds of NC Lic. Mental Health Therapist unable to work



From: ProviderNet@yahoogroups.com
Sent: Thursday, February 14, 2013 11:56 AM
Subject: [ProviderNet] Hundreds of NC Lic. Mental Health Therapist unable to work


Hundreds of NC Mental Health Therapist unable to work.

Our newly licensed therapist in our office applied for Medicaid enrollment and were informed that in accordance with North Carolina session law 2011-399:

"The Department shall conduct provider screening of Medicaid and Health Choice providers in accordance with applicable State or federal law or regulation. The Department must screen all initial provider applications for enrollment in Medicaid and Health choice, including application for a new practice location, and all revalidation requests based on Department assessment of risk and assignment of the provider to a categorical risk level of "limited," "moderate," or "high." If a provider could fit within more than one risk level described in this section the highest level of screening is applicable."

Public Consulting Group (PCG) on behalf of the North Carolina Division of Medical Assistance (DMA) will be conducting an onsite screening.

Public Consulting Group (PCG)
877-522-1057
55 Capital Center Drive, Suite 550
Raleigh, NC 27606
 
The session law required the completion of 3- classes however, the classes are NOT available and NO ONE at PCG is answering the phones to provide information.

How can the legislature pass a law mandating the completion of training as a prerequisite for Medicaid Provider enrollment and not ENSURE that the training is available?

We are also being told that DMA will not back date the enrollment date.

So now we have two therapist that cannot provide services to Medicaid consumers and therefore do not earn enough money to support themselves. They are working PT and looking for other work to supplement their income. Many consumers that need therapy don't get it.

Does anyone at the North Carolina General Assembly care about the workers in this state?
Who will fix this?

13 February 2013

DHHS Invites Stakeholders to the Table: Begins Process for Long-Term Reform & Innovation in Medicaid


Dear All,

I know MANY of you have some terrific ideas on how to improve Medicaid service system... and here is the PERFECT opportunity to get them heard!

Please look over this Request for Information (RFI) from the new DHHS Secretary as they are looking for stakeholders who have ideas on how to better provide Medicaid services in our state.  Stakeholders definitely include consumers and families across the state, too!

This is a top level opportunity to provide needed input for reform in better utilizing dollars to meet the growing needs.  Please take a moment to read and consider how YOU can get involved in this work.

THANKS!!

Anna

p.s.  Doug Wright is the Director of Consumer Affairs for Alliance (Wake & Durham & now interlocally linked with Cumberland and Johnston)
Note:  CFAC stands for "Consumer Family Advisory Committee"  and has advisory requirements as set in NC Statute 122C

----- Forwarded Message -----
From: Doug Wright <DWright@alliancebhc.org>
To: Alliance CFAC Members
Sent: Tuesday, February 5, 2013 12:05 PM
Subject: FW: NEWS RELEASE: DHHS Invites Stakeholders to the Table: Begins Process for Long-Term Reform and Innovation in Medicaid

 
 
From: Ellen Holliman
Sent: Tuesday, February 05, 2013 11:56 AM
To: SeniorManagement
Cc: yvonne@nc-council.org
Subject: FW: NEWS RELEASE: DHHS Invites Stakeholders to the Table: Begins Process for Long-Term Reform and Innovation in Medicaid
 
 

DHHS Invites Stakeholders to the Table
Begins Process for Long-Term Reform and Innovation in Medicaid
 
RALEIGH, N.C. – Today, the North Carolina Department of Health and Human Services (DHHS) published a Request for Information (RFI) for recommendations to assist the DHHS Division of Medical Assistance (DMA) in improving the efficiency and effectiveness of the state’s Medicaid program.
“Reforming Medicaid is crucial to everyone in North Carolina,” said DHHS Secretary Aldona Wos, M.D. “By publishing this RFI, the Department of Health and Human Services is inviting North Carolina healthcare providers to the table and also encouraging citizens with innovative ideas to participate.”
Today’s RFI released by the department marks the beginning of a process to engage interested parties to bring long-term reform and innovation to the state’s Medicaid system. Recommendations will be evaluated by leadership and utilized as a platform for future discussions. All recommendations must be submitted to the Division of Medical Assistance by March 15, 2013 at 2 p.m.
“We are seeking information and input that will help build a state-of-the-art, sustainable Medicaid program,” said Carol Steckel, director of the Division of Medical Assistance. “We must prove to the residents of North Carolina that the program can provide high quality access to health care services while at the same time, manage the tax dollars entrusted to us in a better, more efficient way.”
The North Carolina Department of Health and Human Services (DHHS) and the Division of Medical Assistance (DMA) are charged with operating the state’s Medicaid program, which provides health care services for over 1.5 million North Carolinians. A recent audit of the program raised concern over multi-year cost overruns and the need to better manage the budget.
A copy of the RFI and an open letter from Secretary Wos is attached.  The RFI may be found at https://www.ips.state.nc.us/IPS/Default.aspx , search for 30-DMA100-13.
 ####

11 February 2013

NC DHHS Request for Information


Governor Pat McCrory and Aldona Z. Wos, M.D. Governor Ambassador (Ret.) Secretary DHHS 


To Whom It May Concern: 

The North Carolina Department of Health and Human Services (DHHS) is pleased to issue a Request for Information (RFI) requesting recommendations that will assist the Division of Medical Assistance in improving the efficiency and effectiveness of our state’s Medicaid program. As has been widely reported in the news media, the Division has not been managed in a way to use our resources most efficiently. This has not only resulted in a loss to the taxpayers through significant budget shortfalls for several years in a row, but also to patients, providers and other stakeholders in the state’s Medicaid program. 

Medicaid Director Carol Steckel and I are committed to transforming the operations of the Division of Medical Assistance through innovation and reform. We strongly believe that we must prove to the residents of North Carolina that the program can not only provide high quality access to health care services to our recipients, but also manage the tax dollars entrusted to us in a better, more efficient way. We intend to restore trust in the Division and look forward to a collaborative reform process. 
This RFI represents an effort on our part to quickly collect recommendations from any appropriate entity. We encourage bold recommendations. We also encourage recommendations that are both comprehensive in nature or address only one area of service such as long-term care. These recommendations will be evaluated by the Division’s leadership and utilized as a platform for future discussions regarding innovation and reform of the state’s Medicaid program. 

The due date is aggressive, but the importance of our task to the state of North Carolina requires the utmost urgency and innovative thinking. I encourage each of you to come to the table, respond to the RFI and be part of the transformation of the Medicaid program in our state. 

Sincerely, 
Secretary 

North Carolina Department of Health and Human Services 
Division of Medical Assistance 
Request for Information 
RFI-DMA100-13 
February 4, 2013 

Request for Information 

The North Carolina Department of Health and Human Services (DHHS), Division of Medical Assistance (DMA), is charged with operating the North Carolina Medicaid program which provides health care services for over 1.5 million North Carolinians. The current Medicaid budget is over $13 billion. Concern over multi-year cost overruns and the need to better manage the budget and improve the quality of care has led DHHS to seek information regarding innovative system and payment reform. 
DHHS is interested in receiving information, recommendations and suggested approaches regarding innovative system and payment reforms to the Medicaid program that are based on the following principles: 
  • Are market-based and utilize NC community-based providers 
    • In addition to complying with federal laws and regulations regarding access to services for recipients, DHHS expects respondents to utilize local providers
    • DHHS expects respondents to utilize cutting-edge reimbursement methodologies, incentives and other financial efforts in order to create a system that reimburses for proven and documented results
    • DHHS prefers to receive recommendations and information from respondents familiar with the North Carolina healthcare system and those recommendations and information include approaches that build on the current community care network by enhancing that system’s effectiveness and building partnerships with other primary care providers
  • Enhance recipients’ personal responsibility both for financial participation and health care decisions 
    • While this issue has been attempted in a variety of ways DHHS seeks any and all information that encourage recipients to make better choices and improve their health 
    • Use of co-pays, deductibles and other allowable financial incentives will be acceptable and encouraged 
    • Use of non-health service incentives, such as added services, weight loss program and other ways to encourage and achieve an improved health status of recipients 
  • Assess optimal level of benefits to appropriately meet the health care needs of Medicaid recipients 
  • Provide both short term savings for the Medicaid program and provide a sustainable, predictable Medicaid program for the future; respondents should describe how it will create more appropriate care, at lower costs and with better outcomes versus the fee-for-service system over the short, intermediate and long terms. 
  • Create payment policies that provide incentives to create a system that provides the right level of care at the right location 
    • DHHS seeks to build on the development of patient-centered medical homes that encourage recipients to build a long-term relationship with a primary care provider instead of utilizing the emergency department. 
    • DHHS seeks approaches in which the CCNC “patient portal” can be expanded beyond its current limitations (accessible only by care providers at present) to provide ED providers and hospital staff information currently available in the portal regarding the tests, prescriptions and services provided to Medicaid patients so that ED care can be better delivered and coordinated with the patient’s past medical history and providers. 
  • Utilize accepted and verifiable financial measures to evaluate and assess the efficiency of the program 
    • While DHHS seeks recommendations and information on the appropriate measures, DHHS proposes utilizing those measures already being used in the Medicare and Medicaid programs to avoid duplication in reporting. 
  • Utilize accepted and verifiable quality, utilization, customer satisfaction metrics to ensure efficacy and appropriate levels of care and service
    • While DHHS seeks recommendations and information on the appropriate measures, DHHS proposes utilizing those measures already being used in the Medicare and Medicaid programs to avoid duplication in reporting. 
  • Address the need for coordination between physical health and behavioral health 
  • May include information that address the full continuum of care, including long term care support and services 
  • Focus on improving the health of our citizens and lawful residents 
  • May require either Medicaid State Plan Amendments (SPAs) and/or waivers from Title XIX rules and regulations. DHHS encourages respondents to address how the Medicaid SPA and/or waiver would be phrased in order to enhance US DHHS approval in a rapid time frame. 

DHHS encourages respondents to address the use of North Carolina’s Health Information Exchange in order to provide health information to both the provider community and recipients as appropriate 

DHHS purposefully provided only an outline of goals for its program in order to receive recommendations, information and suggestions for approaches that are innovative. DHHS seeks information regarding programs that will build a state-of-the-art, sustainable Medicaid program. DHHS asks that respondents think boldly in the submissions. DHHS will consider all recommendations, information and suggestions for approaches including those that utilize the existing Community Care Networks or any other coordinated care proposal. 

Entities who submit documentation in response to this RFI may be invited to present their ideas in person to Agency leadership. An in-person presentation by an entity that submits documentation in response to this RFI will not serve as the basis for precluding that entity from responding to any future RFP or RFA regarding system reform. 

The responses to this RFI, any follow-up questions and the presentations to the DHHS may be used to design a system of health care for the North Carolina Medicaid program. 

RFI Response Requirements 

Respondents to this RFI are asked to be thorough but concise. The response to this RFI should include the following: 
  • The respondent’s name, address, place of business address(es), contact information, including representative name and alternative, if available, telephone numbers(s), and e-mail address(es). 
  • DHHS seeks to solicit recommendations and information from respondents that are North Carolina entities that are licensed providers participating in Medicaid, including provider groups that participate, hospitals, provider networks that are provider owned or provider based. DHHS recognizes that respondents to this RFI may include individuals in other settings such as academia. 
  • A description of the respondent’s business and/or its experience as it relates to the services outline in this RFI. This description should include a narrative explaining past experiences in which the respondent has engaged with other health care payers, health care agencies, health care providers or government agencies in the area of Medicaid, health system design, managed care, long term care programs. The respondent shall indicate any Medicaid experience it has for services similar in nature to those described in this RFI. 
  • A description of how the respondent’s approach will offer advantages or improvements over existing processes. The description should also identify known or potential concerns with or barriers to the approach. 

Confidential Information
In accordance with 01 NCAC 05B.1501 the State may maintain confidentiality of certain types of information described in N. C. Gen. Stat. 132-1 et. seq. Such information may include trade secrets defined by N.C. Gen. Stat. 66-152 and other information specifically exempted from the Public Records Act pursuant to N.C. Gen. Stat. 132-1.2. Respondent may designate appropriate portions of its response confidential, consistent with and to the extent permitted under the Statutes and Rules set forth above, by marking the pages containing confidential information with boldface type at the top and bottom of each such page stating, “CONFIDENTIAL”. By so marking any page, the Respondent warrants that it has formed a good faith opinion, having received such necessary or proper review by counsel and other knowledgeable advisers that the portions marked confidential meet the requirements of the Rules and Statutes set forth above. The State may serve as custodian of Respondent’s confidential information and not as an arbiter of claims against Respondent’s assertion of confidentiality. If an action is brought pursuant to N.C. Gen. Stat. 132-9 to compel the State to disclose information marked confidential, the Respondent agrees that it will intervene in the action through its counsel and participate in defending the State, including any public official(s) or public employee(s). The Respondent agrees that it shall hold the State and any official(s) and individual(s) harmless from any and all damages, costs, and attorney’s fees awarded against the State or official or individual in the action. The State agrees to promptly notify the Respondent in writing of any action seeking to compel the disclosure of Respondent’s confidential information. The State shall have the right, at its option and expense, to participate in the defense of the action through its counsel. The State shall have no liability to Respondent with respect to the disclosure of Respondent’s confidential information ordered by a court of competent jurisdiction pursuant to N.C. Gen. Stat. 132-9 or other applicable law. 

Response Submission 

Please note: This is a request for information only and not a request for services. 
Respondents to this RFI shall submit one electronic copy of its response. The response shall not exceed twenty one-sided pages in length. The electronic format shall be submitted on CD-ROM. The software used to produce the electronic files must be Microsoft Word 2010 or newer. 

The respondent shall also submit one electronic redacted copy of the response suitable for release to the public. Any confidential information should be either redacted or completely removed. The redacted response shall be marked as the “redacted” copy and contain a transmitted letter authorizing release of the redacted version of the response in the event the Agency receives a public record request. We request that all interested parties respond to this RFI by submitting your responses by 2:00 p.m. EST, Friday March 15, 2013. 

For responses sent via US Mail, responses should be sent to the following address: 
NC Department of Health and Human Services 
Office of Procurement and Contract Services 
Attn: David Womble 
2008 Mail Service Center 
Raleigh, NC 27699-2008 
Hand delivered responses, or responses sent other than via US Mail, should be sent to the following address: 
NC Department of Health and Human Services 
Office of Procurement and Contract Services 
Hoey Building 
Attn: David Womble 
801 Ruggles Drive 
Raleigh, NC 27603 
IMPORTANT NOTE: Indicate firm name, and RFI-DMA100-13 on the outside of the envelope or package. Faxed or emailed responses will not be accepted. 

Respondent Costs 

Respondents are solely responsible for all costs incurred by the respondent in preparing and/or submitting a response to this RFI. Neither the state of North Carolina, DHHS nor DMA shall be responsible for any respondent costs associated with preparing and/or submitting a response to this RFI or any costs associated with presentations if requested. 

Questions 

Verbal questions will not be accepted. Clarification questions related to this RFI must be emailed to David Womble by 2:00 PM February 14, 2013 at: 

If applicable, answers to the questions or any other information concerning this RFI will be posted to the IPS Website (www.ips.state.nc.us) by February 20, 2013 under RFI # 30-DMA100-13. 

Rights to Submitted Materials 

All responses, inquiries, or correspondence relating to or in reference to this RFI, and all documentation submitted by the various respondents shall become the property of DHHS when received. Ideas, approaches, and options presented by respondents may be used in whole or in part by the State in developing a Request for Proposal (RFP) should DHHS decide to proceed with an RFP. Further, combinations of ideas from various respondents may also become part of a RFP, based on consideration of RFI various submissions and the needs of DHHS, which may differ from respondent’s experiences in other places. 

Obligations of the State 

DHHS may choose to issue an RFP for the development and implementation of innovative system and payment reforms to the Medicaid program. However, this RFI is not a guarantee that an RFP will be issued for some or all of the services about which ideas and approaches are being sought. 
If the state does determine that these services are of a benefit to the state an RFP will be issued. Until then all information sent in by respondents for this RFI will remain confidential until after the award of the RFP or until the state makes the decision to not issue an RFP. 

08 January 2013

Special Medicaid Bulletin on b/c Waivers

Good Afternoon,

Please see the Special Medicaid Bulletin on the 1915 b/c waivers posted today. Please share with your stakeholders.

http://www.ncdhhs.gov/dma/bulletin/pdfbulletin/0113_1915bc_waiver_expansion.pdf

Thanks.

Kelly Crosbie, LCSW
Chief, Behavioral Health Section
Clinical Policy & Programs
Division of Medical Assistance
1985 Umstead Drive
2501 Mail Service Center
Raleigh, NC 27699-2501
(919) 855-4293
kelly.crosbie@dhhs.nc.gov

Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized State official. Unauthorized disclosure of juvenile, health, legally privileged, or otherwise confidential information, including confidential information relating to an ongoing State procurement effort, is prohibited by law. If you have received this e-mail in error, please notify the sender immediately and delete all records of this e-mail.

23 October 2012

CAP-IDD ... this is NOT NC Innovations

From Mary K. Short:


The links to the announcements and guidance are below.  The changes from CAP-MR/DD to CAP-IDD are approved by CMS on 10/1/2012 BUT are not implemented until 1/1/2013.  If you are in an LME that is supposed to convert to an MCO before or on 1/1/2013 THIS DOES NOT APPLY TO YOU (or if you are already on the NC Innovations waiver) because you should be working on the transition to the NC Innovations waiver for your LME/MCO "go live" date prior to or on 1/1/2013.  The Special Medicaid Bulletin is specific about timelines and who is and who is not impacted.
Additionally, this is part of what Doug Sea sent out to providers/case managers.  I know he works with DRNC (Disability Rights North Carolina www.disabilityrightsnc.org) and you should probably contact them if you have questions.  If you are in Legal Services of the Southern Piedmont area (Mecklenburg & surrounding), then contact LSSP at www.lssp.org.
The instructions do not include the right to request continuation of current services as a reasonable accommodation under the ADA. Nor do the instructions provide for the right to a notice with appeal rights if such a request is made and denied. It will be up to advocates and providers to let families know they have the right to submit such a plan and to appeal to OAH if denied if they are at serious risk of institutionalization without continuation of their current services. Please make families aware of this.  
Essentially the same issue will occur for families transitioning to the Innovations waiver on January 1 .  Those 36 counties are also listed in this bulletin.
Here are some other possible specific issues to look for as CAP-DD families transition to the new CAP-IDD waiver (for a short time) and to the Innovations waiver:
A.      if LME doesn’t have adequate provider network, can family continue to be paid to provide home support services?
B.      If rate paid to provider is changing (eg no more enhanced personal care services or enhanced respite) and new rate is inadequate to attract qualified provider for this recipient, can recipient appeal rate reduction/loss of enhanced service?
C.      Does the requirement that  Intensive In home support have a fading plan and the 6 month limit for intensive night services violate the ADA or EPSDT?
D.      Does the restriction on services during school hours violate EPSDT if the child requests personal care (not hab serv) in excess of that limit?
E.       Does child recipient have right to case management in addition to care coordination under epsdt if medically necessary in that case because the LME staff are not adequately trained or don’t do medically necessary work the current case manager has been doing?
F.       Does the LME violate due process by “crosswalking” to new services without explaining right to request continued current service and to appeal if denied?
Mary K. Short
828-632-5888 or 704-451-4144 (cell)
Special Medicaid Bulletin:
http://www.ncdhhs.gov/dma/  (SCROLL down, it's the first bullet point on the left.)
OR direct link to the Bulletin:
CLINICAL POLICY 8M:
(Clinical Policy 8M ... this is the IDD 8M.  I do not have an answer for how it got approved and posted without an additional comment period!)

10 October 2012

Crisis in PCS in NC, & How to Address It

From The Arc of North Carolina
Crisis in Personal Care Services in NC, and How to Address It

[ original post ]

Issue:

For thousands of North Carolina citizens with intellectual and developmental disabilities (I/DD), as well as people with mental illness, the Medicaid State plan service "Personal Care" (or PCS) has provided supplemental funding for housing supports in small licensed group homes.

Earlier this year, the General Assembly raised the level of disability needed to receive PCS. Now, individuals must require assistance with three activities of daily living [ADL’s]. This rule applies to both in-home and facility based services, to achieve legally required comparability. Unfortunately, most individuals living in licensed group homes will no longer qualify.

This change could reduce a group home’s budget by up to 30%, creating significant budget shortfalls- yet another hardship for an already struggling community-based option.

Not only does this reduction affect the provider’s ability to provide basic support services, in many cases it could lead to an inability to meet the group home’s debt obligations. Many of these homes were financed using US Dept. of Housing & Urban Development (HUD) funding streams, and a significant number are tied together through HUD approved refinancing methods. If vacancy rates rise due to lack of support services, well over 250 properties could be at risk of failing.

Recommendations:

For most people living in these types of homes, PCS was not their most needed service. Individuals living in these settings most often need support services to allow them to live successfully in communities. For people with I/DD, they are most likely support services that are habilitative and for people with mental illness they would be recovery based support services.

For both populations there are Medicaid options that, if designed correctly, could support people in these settings and other community based options that should not increase the state funds needed to provide these supports. Unfortunately, it is impossible to get these new service definitions designed and approved by the Center for Medicaid Services by December 31- the end date of the current PCS definition.

With this in mind, we would recommend the following course of action.
  1. Extend the state funds available to people living in Adult Care Homes to licensed group homes. Thirty-nine million dollars is already set aside for adult care homes during this period of transition. This reserve should be extended to licensed group homes as well. People living in licensed group homes often have more significant disabilities than the individuals in adult care homes and deserve the same protection provided by the funds appropriated for adult care home residents.
  2. For people with IDD- Immediately begin the work of creating a specific 1915i option for services[s] that would support individuals living in community settings- both licensed and non-licensed. The 1915i option is a near perfect fit for this type of service. Not only can it provide funding to offset the loss of PCS, it could be designed to offset the state services dollars that are used in group homes and provide another meaningful Medicaid service for people living in other community settings. The match money for these services could come from already appropriated community base state funds. Preliminary estimates by The Arc indicate that a carefully crafted 1915i option could support individuals in these homes and make a significant dent in the waiting list without any additional appropriations from the State.
  3. For people with Mental Illness– It is possible that the same type of 1915i option services may make sense for people with Mental Illness. It may be more difficult to craft services definitions that assure cost neutrality, but this option should be explored immediately.
At the same time, the state should review the possibility of creating a recovery-based support service under Medicaid that could be used in non-licensed community settings as well as licensed settings. Since Mental Health services are recovery based, such a service could be created without the use of a 1915i. In both cases, 1915i or state plan service funds already used for community services for people with mental illness could be used for match.
These recommendations are straightforward solutions to what will become a significant crisis if we do not act. While there may be other options, we suggest the above actions because they have to potential to solve the problem short term and create a low cost solution for the long term that is consistent with best practice. If we are able to follow this path we not only stabilize the licensed community based options but create good options for individuals who choose to live in less restrictive settings.

13 September 2012

10,000 Blog Views! and Counting...

This week, the blog reached 10,000 page views! North Carolinians (and others across the country) are watching - and inquiring minds wanna know...

At the time of the June 16th posting, the blog had reached 5,683 since February of 2012, when first launched. Since that time, the hits have more than doubled from viewers in at least 63 counties across the State of North Carolina and beyond. 

Once more, I'd like to point out that regarding total hits, the number (10,143 as of this posting) reflected to the right of the page (previously located at the bottom) is the correct total of page views since the initial launch of this parent / public information blog back in February of 2012. StatCounter was installed in May, so the data you see compiled via the blog's StatCounter statistics only reflects activity from May onward, mostly because I just haven't bothered to change it. 

Viewers include loads of parents / family members as well as provider agencies and professionals, LME / MCOs, universities and research groups, risk management groups, PR firms, law firms, advocacy organizations, and both state and federal government offices (*although due to the ambiguity of government IP data, it's impossible for a novice like me to know which specific offices nor even agencies are viewing)...

Some of the more interesting regular (and some once or twice) NC viewers include: Duke University, UNC Chapel Hill, UNC Charlotte, the Department of Veteran Affairs, the North Carolina Research and Education Network, Disability Rights NC, The Arc of NC (and various county chapters), NC Justice Center, NC Council of Community Programs, Crossroads Behavioral Healthcare (now Partners Behavioral Health Management), Daymark Recovery Services, Piedmont Behavioral Health, Sandhills Center, Saguaro Management and Accounting Services, Inc. (providing billing, human resources, program development and quality and risk management to human services companies), the Mental Health Association of Forsyth County, Raleigh's Campaign Connections PR firm, and numerous NC Government offices and agencies around the state.

And beyond North Carolina's borders: Kansas Health Institute, Virginia Commonweath University (VCU), Minnesota State Colleges and Universities, University of Georgia, Emory University, DC's American University, FHC Health Systems, Hospice of the Western Reserve in Ohio; Charleston, SC's New Hope Treatment Centers; HMS (a public government and managed-care contracting company); Deloitte, Marsh USA, and Alvarez & Marsal (each being US consulting / risk management firms with varying specialties); Nelson Mullins Riley & Scarborough LLP,  Drinker Biddle, and Hunton and Williams (each are national / multi-state law firms); and yes, even the US Centers for Medicare and Medicaid as well as a few hits from US Government offices in Washington, DC.

Yep, as election season launches into full swing (or sling as is oft the case), the world IS watching to see what North Carolina will do with it's special populations -- even if the usually less-than-enthusiastic main-stream media assignments and focus generally fall short in the real-life, human interest for "those people" and their families - because let's face it, nobody really wants to talk about what they don't understand, especially if it makes them sad... 

The 38th Vice-President of the United States, Hubert H. Humphrey, once said oh-so wisely, "The moral test of government is how it treats those who are in the dawn of life... the children; those who are in the twilight of life... the elderly; and those who are in the shadow of life...  the sick... the needy... and the disabled."

It's one of my favorite quotes and oh-so-fitting... and if you happen to be a quote-y kind of person like me and enjoy wise words, here's another for ya...

"Open your mouth for the mute, For the rights of all the unfortunate. Open your mouth, judge righteously, and defend the rights of the afflicted and needy." --Proverbs 31:8-9

So rest assured North Carolina, Inquiring Minds DO Wanna Know.


And to all the blog followers, the advocates, the exhausted parents, supportive family members; loyal and dedicated direct care staff, Case Managers, and various professionals (our personal community villages) who go above and beyond every day to make our lives possible...  and to all the people of conscious who listen, who care, who try and try again - and who never, ever give up because you know what is right and just and because it's just not in your soul's design to believe that one life is worth less than another... I'd like to take this opportunity to say Thank You!

Oh, I mentioned 63 counties; here they are... Clicking on the County links below will take you to the corresponding State representatives page on the North Carolina General Assembly's website.
  1. Alamance County 
  2. Beaufort County 
  3. Bertie County  
  4. Brunswick County 
  5. Buncombe County 
  6. Burke County 
  7. Cabarrus County 
  8. Caldwell County  
  9. Catawba County 
  10. Cherokee County 
  11. Cleveland County 
  12. Cumberland County 
  13. Dare County 
  14. Davidson County  
  15. Duplin County 
  16. Durham County  
  17. Edgecombe County 
  18. Forsyth County  
  19. Franklin County  
  20. Gaston County 
  21. Granville County  
  22. Guilford County  
  23. Halifax County  
  24. Harnett County 
  25. Haywood County  
  26. Henderson County  
  27. Hertford County  
  28. Hoke County  
  29. Iredell County  
  30. Jackson County  
  31. Johnston County  
  32. Jones County  
  33. Lee County  
  34. Lenoir County  
  35. Lincoln County  
  36. Macon County 
  37. McDowell County  
  38. Mecklenburg County 
  39. Monroe County *voter representation falls under Union County
  40. Moore County  
  41. New Hanover County  
  42. Onslow County  
  43. Orange County 
  44. Pasquotank County  
  45. Pender County  
  46. Pitt County  
  47. Polk County  
  48. Randolph County  
  49. Robeson County  
  50. Rockingham County  
  51. Rutherford County  
  52. Sampson County  
  53. Stanly County  
  54. Stokes County  
  55. Transylvania County  
  56. Union County  
  57. Wake County 
  58. Watauga County  
  59. Wayne County 
  60. Wilkes County  
  61. Wilson County  
  62. Union County  
  63. Yancey County  
To find out who your voting representatives are, visit the NC General Assembly search page.
For more on who's involved and how to advocate, see Speak Up!