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We do need more psych beds, and we are in desperate need of HOUSING as well as Residential Treatment Options, Assertive Community Treatment, & Intensive Case Management. |
CO Medicaid Behavioral Health Services
wE hAVE CONCERNS REGARDING COMPLIANCE WITH mEDICAID nETWORK aDEQUACY, pARITY & oLMSTEAD
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Required Services under Colorado Medicaid for Behavioral Health
2. Outpatient Services
3. Pharmacy Services 4. Targeted Case Management 5. School-based Behavioral Health Services 6. Drug Screening & Monitoring 7. Detoxification Services 8. Medication-Assisted [Drug] Treatment Alternative Services [not an entitlement] under Colorado Medicaid for Behavioral Health:
The idea is that the savings from the Medicaid Behavioral Health Plan will fund the alternative services above. The problem is that violates Parity and Medicaid Network Adequacy. All the services listed under "Alternative" are critical but:
We were told by the CO Department of Health Care Policy & Financing that they were making ACT available to all where "reasonably medically necessary." The regulations on the Secretary of State's website do NOT reflect that. We will be going back to the Department for clarification. Will flesh out more of our concerns in the coming days.
Our Mental Health care focus is initially limited to: 1. Hospital Psychiatric Care: A Mandatory Service under Medicaid. 2. Residential: An Optional Rehabilitation Service under Medicaid. However, Colorado has historically categorized Residential as an "Alternative Service" under its Managed Care program -- meaning the services are not available to all who qualify based on "reasonable medical necessity." Access is artificially capped based on money realized from the savings of the Managed Care Program. 3. Assertive Community Treatment: An Optional Rehabilitation Service under Medicaid. However, Colorado has historically categorized Residential as an "Alternative Service" under its Managed Care program -- meaning the services are not available to all who qualify based on "reasonable medical necessity." Access is artificially capped based on money realized from the savings of the Managed Care Program. 4. Intensive Case Management: An Optional Rehabilitation Service under Medicaid. However, Colorado has historically categorized Residential as an "Alternative Service" under its Managed Care program -- meaning the services are not available to all who qualify based on "reasonable medical necessity." Access is artificially capped based on money realized from the savings of the Managed Care Program. 5. CO's CMHS [Community Mental Health Supports Waiver]: In 2015, the CO Department of Health Care Policy & Financing changed targeting criteria, apparently without consulting stakeholders. The new targeting criteria makes clear that people need a mental health diagnosis and help with activities of daily living. Colorado has had a MI waiver largely in name only both for historical reasons and budgetary reasons. We just don't think the State can discriminate against people with mental illness who have long term supervision needs -- but don't need help with activities of daily living (ADLs) This is especially true with Colorado Medicaid that is also not making available Residential, Assertive Community Treatment, & Intensive Case Management where reasonably medically necessary. Nor to our knowledge do they know haw many people need those services. 6. Waitlists: The State has resisted waitlists in mental health for apparently political reasons -- we think they are afraid of what they will find -- which is a lot of need that isn't being sufficiently addressed as legally required. States pledge to CMS under their contracts that they will follow Federal Law. Well, Colorado & most states are "partially" complying with Federal Law, most have not fully complied. We're going to be focusing on "Facial" & "Obvious" or "Per Se" violations of Medicaid Network Adequacy, Parity, & Olmstead. For more complicated issues, a State Audit would probably be required. Waiting List of Institutionalized & Homeless Populations with Mental Illness that need Supportive Housing:
42 CFR 438.88(c) Development of Medicaid Network Adequacy Standards (c) Development of network adequacy standards. (1) States developing network adequacy standards consistent with paragraph (b)(1) of this section must consider, at a minimum, the following elements: (i) The anticipated Medicaid enrollment. (ii) The expected utilization of services. iii) The characteristics and health care needs of specific Medicaid populations covered in the MCO, PIHP, and PAHP contract. (iv) The numbers and types (in terms of training, experience, and specialization) of network providers required to furnish the contracted Medicaid services. (v) The numbers of network providers who are not accepting new Medicaid patients. (vi) The geographic location of network providers and Medicaid enrollees, considering distance, travel time, the means of transportation ordinarily used by Medicaid enrollees. (vii) The ability of network providers to communicate with limited English proficient enrollees in their preferred language. (viii) The ability of network providers to ensure physical access, reasonable accommodations, culturally competent communications, and accessible equipment for Medicaid enrollees with physical or mental disabilities. (ix) The availability of triage lines or screening systems, as well as the use of telemedicine, e-visits, and/or other evolving and innovative technological solutions. We are NOT @ this time considering Substance Use Issues. They are hugely important and there is an enormous overlap with mental health. |
8.212.4 BEHAVIORAL HEALTH SERVICES |