MEDICAID Funding Strategies & Issues
[More To Come]
​

Hospitalization, IMD Exclusionary Rule, State Technical Assistance Needs with the Homeless/Incarceration Crisis
  • Hospitalization is a Mandatory Service (link) -- we think failure of Medicaid to cover long term mental health hospitalization violates Parity IF the State has a Comprehensive & Rational Continuum of Mental Health Care with FULL MEDICAID NETWORK ADEQUACY.
  • CMS has to decide what it wants to do with regard to the IMD Exclusionary Rule & Medicaid Network Adequacy. RIGHT NOW, people are falling through CMS' huge cracks of LACK OF ENFORCEMENT into HOMELESSNESS & INCARCERATION -- that is worse than a FACILITY with more than 16 beds of mental health patients.
  • Further, it is pretty obvious to us that STATES need A LOT OF HELP with this.  We'd like to see the establishment of relevant FEDERAL TECHNICAL ASSISTANCE CENTER(S) on:
    • addressing HOMELESSNESS & INCARCERATION among people with COGNITIVE DISABILITIES
    • as well as complying with relevant current FEDERAL LAWS & REGULATIONS 
  • We've got to STOP the Homelessness & Incarceration problem among people with mental illness and other cognitive disabilities and that needs to be in a REASONABLE TIME FRAME as required by OLMSTEAD.
 
General Medicaid Long Term Care
More Medicaid MENTAL HEALTH Issues
  • Colorado Medicaid's General Behavioral Health Benefit:  This has the potential to be FANTASTIC if the STATE:
    • ​Gets accurate numbers of those with mental illness [& other cognitive disabilities] in the Criminal Justice System
    • Builds out their Integrated Physical & Behavioral Healthcare System to address the needs of THOUSANDS of COLORADANS who have FALLEN THROUGH SOME PRETTY BIG CRACKS.
    • Starts funding ESSENTIAL SERVICES such as 
      • ​Residential Services
      • Assertive Community Treatment, &
      • Intensive Case Management
​                          as entitlements where "reasonably medically necessary"

  • "Alternative Medicaid Services" under the Behavioral Health Managed Care Program [Uses Savings from the Managed Care Program to fund Additional Services] --This is a perfectly legitimate strategy for funding "extras."
    • It is NOT good policy making to fund VITAL, ESSENTIAL SERVICES for some of the MOST NEEDY & VULNERABLE COLORADANS with Mental Illness.  We realize we don't live in a perfect world -- but whatever waivers, exceptions, innovative funding strategies we need employed to fund VITAL, INTENSIVE MENTAL HEALTH SERVICES -- we need to do NOW.
    • Such ESSENTIAL SERVICES Colorado has deemed as ALTERNATIVE SERVICES include Mental Health Residential Services, Assertive Community Treatment & Intensive Case Management.  We are NOT going to get good results with an inadequate program like that.  Of course, the proof is in the pudding -- we're NOT getting good results.
​
CMHS Waiver
  • The Community Mental Health Supports (CMHS) Waiver got pretty screwed up during the last Administration -- trying to limit it to people with Mental Illness who need help with activities of daily living.
    • It is NOT clear the last Administration actually implemented that change.
    • We need to have a FRANK conversation about what the CMHS waiver is and what it should be.  The last Administration was afraid to have that conversation.
    • It may be that Residential Services, Assertive Community Treatment & Intensive Case Management should be put on the array of services for the CMHS Waiver.
    • AND, of course, we have to get rid of that discriminatory targeting criteria requiring assistance with activities of daily living.
A HUGE part of the problem is that the COSTS of the Homeless/Incarceration Cycle are often borne by COUNTIES & Municipalities, & its the STATES that have the clear LEGAL DUTIES to rectify these situations.

BUT it will INCREASE COSTS for the STATE to do so, even while it reduces COSTS for COUNTIES & MUNICIPALITIES.  Not shockingly, STATES have been SLOW to RISE to the CHALLENGE & to FULFILL their LEGAL RESPONSIBILITIES.

We don't think we can listen to any more POLITE & CORDIAL [or rude] HYPOCRISY from the STATE of COLORADO  on this.


CMS Nov. 13, 2018 Dear Medicaid Director Letter
OpPORTUNITIES TO dESIGN iNNOVATIVE sERVICE dELIVERY sYSTEMS FOR
*aDULTS WITH A sERIOUS mENTAL iLLNESS OR
*cHILDREN WITH A sERIOUS eMOTIONAL dISTURBANCE

​