After over two years of preparing to carve new behavioral health benefits into Medicaid managed care plans and recode all Medicaid behavioral health services to align with national coding standards, the Ohio Departments of Medicaid (ODM) and Mental Health and Addiction Services (ODMHAS) had announced they were ready to go live with the Behavioral Health Redesign starting on July 1, 2017. The agencies filed rules implementing the changes with the Joint Committee on Agency Rule Review (JCARR) earlier this spring after the Common Sense Initiative Office ruled the rules would not have an adverse impact on business. However, after hearing from numerous small providers that were unprepared to go forward with the new system on July 1, the Ohio House of Representatives inserted a provision in the budget bill (H.B. 49) that would prohibit the new system from going live until January 1, 2018, and further delay the carve-in of alcohol, drug addiction, and other mental health services into Medicaid managed care until July 1, 2018. Correspondingly, JCARR requested that the administration place its proposed rules in “To Be Refiled” status to allow for further review.
On Thursday, June 22, the Joint Medicaid Oversight Committee (JMOC) of the Ohio General Assembly heard testimony regarding the status of the Behavioral Health Redesign from ODM Director Barbara Sears, ODMHAS Director Tracy Plouck, and representatives from various behavioral health providers. Directors Sears and Plouck testified that the administration is respectful of the budget deliberation process and that the agencies will not refile rules affecting community mental health providers nor propose an effective date for the rules until the budget process has concluded. However, Director Sears affirmed that the hospitals are prepared to move forward with the coding changes and make the new services available as soon as possible. Therefore, ODM has refiled a rule to increase access to services for children and multi-system youth with an effective date of August 1, 2017. Director Sears noted that ODM is able to accommodate these new services sooner because the billing methodology for hospitals in the Medicaid claims system is separate from the coding changes relating to community providers.
Director Plouck provided an overview of numerous policy updates the departments made in response to stakeholder meetings held on April 19 and June 7. Rule changes highlighted by Director Plouck to JMOC include:
- A revised reimbursement policy allowing a provider to bill for a physician visit and a nurse visit on the same day;
- Removal of any language regarding staffing requirements in ODM’s Substance Use Disorder Rules;
- A revision of minimum supervision requirements for certain behavioral health personnel from “direct” supervision to “general” supervision (supervisor available by phone);
- “Community” will be an allowable Place of Service under certain Individual Psychotherapy CPT Codes;
- Medicaid rates for mental health day treatment performed by Qualified Mental Health Specialists with three or more years of experience will be increased to match the rate for practitioners with a bachelors’ degree;
- ODM will not require hospitals to convert their community behavioral health provider status to hospital outpatient by January 1, 2018.
For the complete list of policy updates made in response to feedback from the stakeholder meetings, refer to the directors’ June 22 JMOC presentation.
Director Sears provided an update of the work of the “Pre-Go Live Rapid Response Team,” which has been providing technical assistance to ensure a smooth transition to the new codes and benefit package, as well as beta testing efforts for claims made with the new codes under both Fee for Service and MyCare Ohio plans. The beta testing process received significant attention from the committee. Director Plouck assured committee members that the administration would be in communication with the General Assembly if beta testing results were to indicate the system is unprepared for the January 1, 2018, implementation date, however, Director Plouck said they are not at that point.
When asked by Senator Bill Coley what the criteria are for successful beta testing, the directors noted that around 20,000 claims have been tested by 71 trading partners, representing over 600 providers. Director Sears confirmed that although 20,000 claims is a relatively low number for testing, problems likely would have surfaced if they existed.
Following the directors’ testimony, a panel representing the Ohio Council of Behavioral Health and Family Service Providers, the Centers for Families and Children, the Zepf Center, and the Counseling Source provided the committee with their perspectives of the delayed implementation of the redesign.
Elizabeth Newman, CEO of the Centers for Families and Children, expressed that her organization had been prepared to move forward with the changes, and the delays are causing uncertainty in budgeting and operations. However, Hubert Wirtz of the Ohio Council testified that many providers are still not ready. Specifically, Wirtz said the software vendors that providers contract with to implement the coding changes are not ready to go live with the new system.
On Tuesday, June 27, the Conference Committee on H.B. 49 voted to include in the state budget the House language delaying redesign implementation until January 1, 2018, and July 1, 2018, for alcohol, drug addiction, and other mental health services. The committee also approved an amendment specifying that beta testing for the new codes and services will be considered successful if at least half of the participating providers are able to submit a clean claim that is properly adjudicated within 30 days. The budget bill was subsequently passed by both chambers and now awaits the Governor’s signature and line item vetoes.
As the state budget is finalized and the new fiscal year begins, The Center for Community Solutions will continue to monitor deliberations between JMOC, the administration, providers, and managed care organizations as they prepare for the long-awaited implementation of Behavioral Health Redesign in 2018.