The Joint Medicaid Oversight Committee (JMOC) convened on September 20 to once again discuss the Behavioral Health Redesign. JMOC saw Ohio Department of Medicaid (ODM) Director Barbara Sears testify alongside ODM staff and representatives from the Ohio Association of County Behavioral Health Authorities (OACBHA) and the Ohio Council of Behavioral Health and Family Services Providers (Ohio Council). While the conversation touched on a number of familiar themes, it may be worthwhile to focus on two areas: payment and access.
…the state is still grappling with the tension between subsidizing an industry to maintain access and ensuring costs are contained.
First, the issue of contingency payments was a major point of conversation. Contingency payments are meant to float cash to providers who may be experiencing difficulties in billing (i.e. turning their accounts receivable into accounts payable). What’s interesting is the fact that more than half of the total payments made so far are through these contingency payments: monies which will have to be paid back in some way. Several members of the committee noted that the timeline for the expiration of these funds may be inadequate and may cause problems down the line unless addressed through policy.
As of now, these dollars are financed directly by the plans and do not count against their capitation. This means these dollars are not associated with their rates. At some point, however, if these dollars were to expire, the plans may have to float cash from their capitated rates. This would mean that there would have to be some correction in the future due to rules of actuarial soundness. In other words, if this timeline extended too far, it may mean provider rates would have to be cut in the future. If that is the case, JMOC members would be wise to analyze the implications of this policy choice when they come back to set the JMOC target before the next budget cycle and engage the actuary to model this potential.
Another issue that came up was around provider capacity. On Monday, the Joint Committee on Agency Rule Review (JCARR) passed a rule that limited those individuals with criminal histories from serving as providers. In this context, there was particular concern this would affect the availability of peer support specialists for those with mental health or addiction issues, creating the dual effect of limiting employment options for the justice-involved as well as the availability of an effective intervention key to integration. While the state correctly pointed out that much of this limitation is tied to federal guidance, Ohio went beyond those standards and made them more restrictive. ODM did state, however, that JCARR will review this rule next year as opposed to in the standard five years, so this may be revisited by ODM or, if that is not quick enough, by the General Assembly.
…disruption may be a good thing, but it is unlikely that the General Assembly or JMOC will allow this change to continue without significant oversight and inspection.
In all, the state is still grappling with the tension between subsidizing an industry to maintain access and ensuring costs are contained. Testimony from OACBHA did indicate that access is currently not a problem, but providers claim challenges in maintaining viability as a business enterprise. As with anything, disruption may be a good thing, but it is unlikely that the General Assembly or JMOC will allow this change to continue without significant oversight and inspection.