UPDATE ON LOUISIANA’S MANAGED CARE AND LONG-TERM SUPPORTS
AND SERVICES INITIATIVE IN LOUISIANA
December 17, 2013
This update summarizes what occurred at the Medicaid Managed Care and Long-Term Supports and Services (MLTSS) Advisory Group meeting held on December 12, 2013. This document was prepared by Karen Scallan, member of the MLTSS Advisory Group representing parents of children and youth with developmental disabilities and complex needs. Questions regarding this information should be directed to Kcscallan@gmail.com.
HOW TO COMMENT ON MLTSS IN LOUISIANA
YOUR VOICE IS IMPORTANT. THESE CHANGES WILL CHANGE HOW YOU OR YOUR LOVED ONE RECEIVES WAIVER SERVICES. See the note at the end of this update regarding future meetings and public forums. In the meantime, learn more and send your comments by visiting the following links:
Find out More, Visit: http://new.dhh.louisiana.gov/index.cfm/page/1684/n/379
Send Comments to: dhh.louisiana.gov/index.cfm/page 1684/n/379.
OPTIONAL OPT IN FOR WAIVER RECIPIENTS TO BAYOU HEALTH
After the MLTSS Advisory Group meeting, a smaller group discussed allowing individuals receiving waiver services to OPT IN to the Bayou Health program. There are areas of our state where access to care is limited because physicians won’t take Medicaid Fee-For-Service agreements, but who are participating in the Bayou Health plans. An OPTIONAL OPT IN for these individuals to choose Bayou Health is a good thing for choice. This is significantly different than the full scale mandatory Bayou Health participation that was attempted previously. The caveat is though that anyone opting in for Bayou Health now will have to change plans as we move to MLTSS and health care is included in that. In addition to this OPT IN, they can OPT OUT if it does not work for them as long as they’re still in Bayou Health.
Comments included that families and individuals need to have education on the MLTSS change and they may or may not be mandatorily moved into MLTSS, depending what is decided and the RFP outcomes. The group felt that choice was always important for individuals and were generally happy with the state’s proposal on this.
MEETING SET UP
The meeting was not as well attended as the first one. Opening remarks and a presentation summary of the current LTSS services under the Office of Aging and Adult Services (OAAS) and the Office for Citizens with Developmental Disabilities (OCDD) was provided.
After the summaries, the Advisory Group broke into 4 subgroups to address questions in their respective concept paper and to answer questions proposed in the Request for Proposal concept paper. These concept papers can be found by visiting http://new.dhh.louisiana.gov/index.cfm/page/1684/n/379 . The four work groups were:
- Stakeholder Engagement and Communications
- Consumer Protections
- Measuring Quality
- Accountability
After the subgroups met to discuss and answer the proposed questions, they returned to the larger group to present to the whole body and audience. This format will continue with upcoming meetings. I attended the Consumer Protections workgroup.
The following is a summary of what each workgroup presented to the whole body and what we discussed in the Consumer Protections group. I will be preparing in the next week a commentary on the questions presented and additional suggestions which will go to DHH. I will publish that when it is complete.
ACCOUNTABILITY SUB GROUP
Questions for the Accountability Group included: What measures did they think were most critical to include in a contract for MLTSS and for DHH accountability? Were there any less critical measures? Why? And any other recommendations for inclusion on accountability in the contract?
The group responded that
●There should be clear performance indicators and reporting data set.
●MCO should be held accountable for outcomes
●When outcomes trend in the wrong direction, or the MCO doesn’t meet their goals or not enough progress is made, this should trigger and audit or accountability review and recommendations for changes made.
●Specific trigger points should be delineated in the contract
●Financial penalties should be included
Examples were given that some states only pay billing to the MCO at 95% during the fiscal year and preserve 5% to be paid at the end of the year only if outcomes are met
●Accountability should have teeth
●Requirements for credentialing services should not be dumbed down
●MCO must be forced to invest in non-billable quality monitoring, in other words, hire separate staff for internal monitoring who are not also responsible for billable services
●There were no “less-critical” decisions to consider
●There should be a requirement for electronically verifiable services.
MEASURING QUALITY SUB GROUP
Questions for the Quality Measures Group included: Do they recommend the continuation of quality measures currently used? Should the state set a pre-Managed care measures baseline or should the MCO set it in the first year? What should the initial priorities for improvement be? What are the most critical domains to measure in assessing MLTSS outcomes?
The group responded that
●There are no nationally recognized MLTSS core measures
●We want to compare apples-to-apples
●Quality of Life should be considered
●We want to be able to make cross-state comparisons
●Specific tools that are used for other purposes could be used such as the Personal Experience Survey created by Centers for Medicaid and Medicare Services (CMS).
●An independent survey should be conducted by the state
●Current measures should be continued and built upon
●Consideration for other nationally-recognized measures are out there
●Consideration should be given for what MCO’s are currently using
●The state should consider pioneering state-specific measures
●They are unsure on what to measure since we don’t know what specifics we want to see in the end.
●We should be measuring what we hope to achieve and consider measurement on impact on access to care; providers; care coordination; re-hospitalization; over utilizations; level of care that is appropriate and impact on health of LTSS services.
STAKEHOLDER ENGAGEMENT/COMMUNICATION SUB GROUP
Questions for the Stakeholder Engagement/Communication Group included: What should the structure of the public forums be? What existing events are there they could attend? What existing communication methods could be used? What additional stakeholder engagement should be done? What considerations should be given to communication with families of and individuals in institutional care? In Home and Community Based Services (HCBS)? and waiting for services? What should be in a successful plan? What groups should be part of the communication/engagement plan? What other important considerations should be made?
The group responded that
●Businesses should be engaged in the process
●Focus groups should be held for message content
●Administrative simplicity should be included
●There should be online access
●All providers should be in all MCOs and plans to begin with
●Communication to families/individuals through meetings, provider conferences, existing networks, newsletters, FAQ sheets, speaker bureau, public service announcements, government access channels on cable and faith based groups.
CONSUMER PROTECTIONS SUB GROUP
Questions for the Consumer Protections Group included: What considerations should be made in implementing the CMS mandated consumer protections? What CMS voluntary options for consumer protections should be included? Should there be an Ombudsman Program? If so, what should it look like? Design? What characteristics should an Ombudsman Program have and what would be the ideal outcomes for success? What factors should warrant someone being allowed to change plans outside the enrollment period?
The group responded to each of the CMS Mandatory and Voluntary Protections Separately:
●Mandatory Requirements
●CIVIL RIGHTS
●MCO must demonstrate knowledge of civil rights issues, laws and regulations;
●MCO must provide ongoing training on same
●MCO must demonstrate how they will ensure accessibility of services
●MCO must contract for translation services in a wide variety of languages
●MCO must demonstrate an understanding of the additional rights and protections for traditionally underserved populations including individuals who are homeless, living in rural communities, receiving mental health services and substance abuse services.
●ENROLLMENT SUPPORT
●MCO must provide language support as described above
●Materials must be no higher than 6th grade educational level
●Significant information should be provided, NOT JUST MARKETING BROCHURES
●Individuals should be able to transfer plans for cause where cause is open as long as the person can truly show good and sufficient reason for transfer.
●Ombudsman should be included in the process as conflict-free support
●APPEALS/DUE PROCESS RIGHTS
●Sufficient PRIOR notice regarding events/actions requiring a respond
●Services should remain in place during appeals
●Letter of acknowledgement of requests and timeline for responses
●Clean and easy process for appeals/due process with timelines delineated
●CRITICAL INCIDENT MANAGEMENT
●THIS WAS NOT DISCUSSED DUE TO TIME CONSTRAINTS
●CONFLICT FREE EDUCATION
●Ombudsman Program should be involved
●Consumers should be able to acknowledge an authorized representative
(could be family or staff)
●Non-computer based options for education
●Voluntary Requirements
●CONTINUITY OF CARE (MANDATORY ENROLLMENT V. VOLUNTARY
●THIS WAS NOT DISCUSSED DUE TO TIME CONSTRAINTS
●COMPLAINTS AND GRIEVANCES
●Ombudsman Program should be involved in this
●Clear and standardized complaint form
●Include possible member-advocates or liaisons in the MCO to help with complaints, BUT NOT AS A SUBSTITUTE FOR INDEPENDENT OMBUDSMAN PROCESS
●MCO should be required to report both formal and informal complaints
●INDIVIDUAL CHOICE
●Self-Directed care coordination option*
●No more than 4-5 plans with five considered a lot
●There should be an option for individuals to assume risk for living in what may be considered an unsafe condition so that they can stay in their own home. Ex. The elderly individual who chooses to live at home with less safety than have to move to a strange nursing facility environment. This would include a written acknowledgement to the state/MCO removing them from liability.
●CONTINGENCY PLANS
●THIS WAS NOT DISCUSSED DUE TO TIME CONSTRAINTS
●OMBUDSMAN
●Ombudsman Program should definitely be included
●The program should be separate and independent
●It should be a significant contract
●The contract should include requirements for regular visits
●Ombudsman would be the only logical conflict free individuals to assist with changing plans.
SUB GROUP RESPONSES TO QUESTIONS POSED IN THE REQUEST FOR PROPOSALS CONCEPT PAPER
Questions regarding the Request for Proposals Included: Should the state issue 1 RFP for both populations (individuals who are elderly and those who have developmental disabilities)? What factors should be considered in how many MCO contracts should be awarded? What should the implementation set up be? Phased in or 100% all at once? Should one population be phase in before another? How can they achieve administrative simplicity?
The subgroups responded as follows:
ACCOUNTABILITY SUB GROUP
●Two separate RFPs for each population because a single RFP might eliminate an exceptional MCO for one population due to lack of experience in the other population.
●Economy of scale was secondary to specialization of service
●Maximum of 2-3 plans statewide
●A geographic phase in should be used but the process should go slower than Bayou Health’s geographic phase in.
●For simplicity: Use standardized billings, forms, processes, standards, clearly defined critical incident and mandatory reporting within a defined time frame.
MEASURING QUALITY SUB GROUP
●This was the only group to respond that one procurement should be provided
●This group felt that economy of scale was important for an MCO to be able to provide a healthy array of providers
●They believe a larger MCO can better serve both populations
STAKEHOLDER ENGAGEMENT/COMMUNICATION SUB GROUP
●Two separate RFPs for each population
CONSUMER PROTECTIONS SUB GROUP
●Two separate RFPs for each population
●No more than 4-5 plans with 5 really being almost too much.
●Factors that should be considered in the decision are:
●There are people with developmental disabilities receiving personal care services through Office of Aging and Adult services who would be moved with that group into that RFP process who might need services offered in the procurement for developmental disability services (ex. Employment)
●All procurements should provide equal services
●There is a lack of experience in MLTSS services to individuals with developmental disabilities by most MLTSS MCO companies
●Medicaid/Medicare dually-eligible individuals have to be considered
NEXT MEETINGS AND OPPORTUNITIES TO GIVE COMMENT
Next meeting
The next meeting is Thursday, January 9, 2014, 10:00 am. For the next meeting, there will be four work groups: (1) Enrollment, (2) Benefit Design, (3) Care Coordination, and (4) Populations.
Public Forums
Public forums will being in January. These will include regional stakeholder meetings arranged by the Department of Health and Hospitals (DHH), webinars, and additional events where Long Term Supports and Services transformation can be discussed. DHH is seeking information on other events where they can present.
Subsequent Meeting Dates
February 6, 2014 (Work groups will be: Focus on Rebalancing; Coordination with Medicare; Providers Choosing our Partners; Implementation)
Next meeting is June 2014 (NO MEETINGS DURING LEGISLATIVE SESSION)
RFP Release anticipated in Summer 2014
For questions regarding this update contact:
Karen Scallan
kcscallan@gmail.com
Parent Perspectives on MLTSS 