JMOC: Behavioral Health Redesign Update

The Joint Medicaid Oversight Committee (JMOC) received testimony from two state directors who provided operational updates and policy changes for the state’s upcoming behavioral health redesign implementation on July 1, 2017. The directors touched on many of the changes the Department of Medicaid and the Department of Mental Health and Addiction Services have made since their last presentation before JMOC on behavioral health redesign in December.

From the Ohio Department of Medicaid, Director Sears provided an update on the process behind modernizing the Medicaid codes for behavioral health redesign. Sears expressed that a long-term goal of the department is to provide data that displays Ohio’s overall behavioral health spending. Having this data will allow the state to better understand the services and supports needed for both physical and mental health care. This will be accomplished by comparing the new codes and making that comparison more transparent to better understand what services are being used. This will assist the state when setting future behavioral health goals.

A short-term goal of the department is processing behavioral health redesign claims in a timely manner. Many on the committee had concerns stemming from the difficulties many providers faced with the MyCare demonstration waiver implementation. Director Sears said that the department stands behind their ability and commitment to go live with behavioral health redesign on July 1st, setting numerous safeguards in place such as a “redesign rapid response team” for providers. The rapid response team has extended hours and is open 6 days a week, further emphasizing the commitment of the Department by stating, “if that’s not enough we will figure out how to do 7 days a week”.

Regarding concerns that providers may be having on the rollout, Director Sears discussed the fact that redesign represents a major shift from the current system, stating that some organizations may have to adjust their business models. Throughout the transition, the Department of Medicaid and the Department of Mental Health and Addiction have been and will continue to provide training and support to stakeholders. In the Director’s own words, “(the administration has provided) a considerable amount of outreach, more outreach than for any other changes I have seen.”

Director Plouck, from the Ohio Department of Mental Health and Addiction Services, discussed the policy changes that have occurred both this week and through a March 6, 2017 newsletter issued by the department.

  • The rules will have documentation clarification allowing for checklists and drop down boxes from medical records to be used for clinical documentation,
  • The rules will allow emergency rooms to be designated as an allowable place for behavioral health services,
  • Clarified codes for registered nurses (RN) and licensed practical nurses (LPN) to include things specific to their scope of practice.
  • Rule language will be clarified related to staffing requirements for the American Society of Addiction Medicine (ASAM) residential levels.
  • Moving Therapeutic Behavior Services (TBS) and Psychiatric Services and Rehabilitation (PSR) to the recovery service tab, rather than the counseling tab.
  • Urine drug screening payment changed and increased by $3.
  • There will be the addition of the location “community” for place of service in a setting that does not meet traditional locations.
  • Additionally, the testing phase through Medicaid Information Technology System Trading Partner will be moved up to early May.

Additional policy updates that were made this week also included objectives articulated by the stakeholders. To address workforce concerns providers have, mental health specialists who work at or lead groups at mental health day treatment, with at least three years of experience without a bachelor’s degree or master’s degree, will have an increased rate from what was initially proposed. The changed rate will be based on education, the rate for those without a degree, and, with three years of experience, will be eighty percent of the bachelor’s rate. Additionally, there will be an increased rate for individuals with a master’s degree without license and a larger rate for those with a master’s degree and a license.

In working with stakeholders on the RN/LPN scope of practice, the two departments decided to change how nurses employed by the agency will bill codes from the selection. This was done in an effort to provide clarity and encourage nurses to bill using specific nursing codes. In addition, the departments removed limits to medically necessary nursing services, removing the twenty-four hour for a single year for a single person limit and removing the need for prior authorization if one exceeds the former limit.

Additional rate changes were made for TBS/PSR reimbursements in cases where life skills development is occurring and/or assistance with executing treatment plans are being done in the community. Previously, anything after the first ninety minutes was billed at fifty percent of the rate of the first ninety minutes. Moving forward, providers will receive one hundred percent of the reimbursement rate after first ninety minutes for services not done in a clinical setting.

In closing, both directors established next steps for the behavioral health redesign rule-making process. The department of Medicaid rules went to Common Sense Initiative (CSI) on March 17, 2017, and rules from the Department of Mental Health and Addiction Services are now with CSI.