This is the first of a two-part blog covering the June 28, 2018 meeting of the Joint Medicaid Oversight Committee. The second part addresses the committee’s discussion on pharmacy benefit managers (PBMs), and can be found here.

On July 1, behavioral health providers began submitting claims for services to Ohio’s five Medicaid managed care plans (MCPs), marking the final phase of the Kasich Administration’s seven-year transformation of the community behavioral health system, or Behavioral Health “Redesign.” This weighty undertaking has required continuous collaboration between the Ohio Departments of Medicaid (ODM) and Mental Health and Addition Services (ODMHAS), as well as MCPs, providers, county behavioral health boards, advocates and other stakeholders. ODM and ODMHAS have routinely described Redesign as a project consisting of four major reforms. These reforms are:

• Elevation (2011) – Governor Kasich’s first budget “elevated” the responsibility of providing the matching funds needed to draw down federal Medicaid dollars from the local behavioral health authorities to the state.
• Expansion (2014) – The Kasich Administration expanded Medicaid to cover more low-income Ohioans, including approximately 630,000 with behavioral health needs who previously relied on county-funded services or went untreated.
• Modernization (January 2018) – ODM and ODMHAS have designed a more comprehensive behavioral health benefit package and aligned the new services with national coding standards, replacing the old 17 codes with 120 codes providers can bill for services. For the first six months of 2018, providers have been able to bill these codes to be reimbursed directly by ODM on a fee-for-service basis.
• Integration (July 2018) – Beginning on July 1, all Medicaid behavioral health services were moved into Medicaid managed care, requiring behavioral health providers to contract with at least one of the state’s five Medicaid MCPs to submit claims to, as opposed to fee-for-service.

The directors identified several safeguards that have been put in place to smooth the transition from fee-for-service to managed care.

Since its inception in 2014, the Joint Medicaid Oversight Committee (JMOC) has played an active role in monitoring the progress of Redesign. In JMOC’s June 28 meeting, the committee heard testimony from ODM Director Barbara Sears and ODMHAS Director Tracy Plouck, outlining the administration’s expectations for behavioral health integration into managed care.

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The directors identified several safeguards that have been put in place to smooth the transition from fee-for-service to managed care, including:

• A four-month contingency payment plan agreed to by the MCPs in which the plans provide a cash advance equal to 55 percent of a provider’s CY2016 monthly payment. Providers participating in the contingency plan will simultaneously submit claims for services to MCPs, who will recover advanced payments by offsetting claims over a one-year period.
• MCPs must honor all prior authorizations approved by Medicaid fee-for-service before July 1, 2018 until that prior authorization expires.
• MCPs must maintain Medicaid fee-for-service rates as a minimum for claims payment until June 30, 2019.
• A post-implementation task force made up of ODM, ODMHAS, MCPs, providers, county behavioral health boards and others will work to immediately address provider and patient concerns that arise as a result of implementation.

“The time is right for integration.”

The state’s five Medicaid MCPs – CareSource, Buckeye Community Health Plan, Molina Healthcare, Paramount and UnitedHealthCare – have each signed an agreement to honor these safeguards, and have completed a “readiness reviews” with ODM in advance of July 1 to ensure each plan’s IT systems will reliably reimburse all of the different code sets. Emily Higgins, Chair of the Ohio Association of Health Plans’ Behavioral Health Subcommittee, testified on behalf of the five MCPs, saying “the time is right for integration,” and that each plan has rapid response teams working daily to address issues encountered by providers and anticipate provider needs that may evolve through the integration process.

JMOC members had several questions for the directors regarding the safeguards extended through the MCPs, as well as the MCPs’ capacity to remain responsive to challenges encountered by providers. Senator Lou Terhar asked whether the four-month duration of the contingency payment plan was intended to be set as a minimum, and what metrics may warrant an extension of the cash advances beyond four months. Sears explained that some MCPs were in fact contemplating extending contingency payments beyond four months, but it will be necessary to first review claim denials and the reasons for denials before determining whether extending the contingency plan is necessary. Director Plouck noted that it will take several months before claims data will be robust enough to properly evaluate the status of the transition to managed care.

Senator Vernon Sykes made a request to both Director Sears and JMOC Chair, Senator David Burke, that the committee hear testimony directly from behavioral health providers at future meetings.

Representative Mark Romanchuk inquired about the quality of service provided by the MCP’s rapid response teams, both in terms of how quickly they respond to provider calls, as well as the level of expertise available to provide technical assistance. Medicaid officials assured the committee that while the first line of people answering technical assistance calls may not always have the niche expertise a provider needs, the MCPs have all shared contact information for higher level staff experts to engage if necessary. ODM Director of Managed Care, Patrick Stephan, pledged that if an issue requires experts from both ODM and the MCP to get on a call with a provider, the department will make sure that happens.

Senator Vernon Sykes made a request to both Director Sears and JMOC Chair, Senator David Burke, that the committee hear testimony directly from behavioral health providers at future meetings, in order to learn how they are impacted by the managed care integration process.

Importantly, Director Sears pointed out that the transition of behavioral health to Medicaid Managed Care marks the state’s compliance with federal mental health parity law, after the federal government granted Ohio a delay in complying while Redesign was being implemented.

The summer JMOC schedule remains uncertain, according to Senator Burke, but the Center for Community Solutions will remain engaged with the implementation of this final phase of Redesign over the next several months.