The money woes in Medicaid managed care states: providers facing rate cuts are employing several strategies.
Since the 1980s, states that adopted Medicaid mental health managed care waivers have operated under a financing model in which Medicaid payments were capped in exchange for a guaranteed funding level and significant flexibility in the types of services states could provide. To support this flexibility, many Medicaid mental health plans paid providers using case rates, subcapitation, and other alternatives to the fee-for-service model. These approaches supported innovations such as prevention and early intervention, as well as community-based and wraparound services that might not have been reimbursable or affordable under previous fee-for-service payment mechanisms. Plans also supported a recovery-based approach to care because they eliminated service-driven revenue incentives, as the focus shifted to service outcomes.
In August 2003, a new Medicaid managed care "rule book" issued by the Centers for Medicare and Medicaid Services went into effect with the implementation of the Balanced Budget Act of 1997. This has turned flexibility upside down and has moved the Medicaid program back to being a service-driven model in managed care states. Under the new rules, the guaranteed funding levels for states have been replaced with the requirement for states to set "actuarially sound capitation rates."
To set these capitation rates, states are required to hire actuarial firms such as Milliman and Mercer Government Human Services Consulting to count historical services, multiply them by a rate for each service, and add or subtract adjustments for inflation and expected changes in utilization. Only services listed in the state's approved Medicaid plan, provided to Medicaid-eligible persons, properly recorded by clinicians, and successfully transmitted to the Medicaid mental health plan are included in the calculation of future rates by the actuaries.
For those who work in fee-for-service states where Medicaid mental health plans never moved into managed care, these rules describe how business always has been done: They provide services to Medicaid enrollees, record and bill the services, and are paid. But in managed care states, a much more complicated process has been at work.
Over the past decade the alternative payment methods in managed care states created the unintended consequence of reducing the number of "countable" Medicaid claims. Providers expanded the care they provided beyond the state's approved Medicaid plan. They also became less rigorous about ensuring that service data and progress notes were submitted for every clinical activity. Because providers were not being paid based on a fee-for-service model, these operating changes had no effect on an agency's revenue stream but often resulted in a 15 to 25% drop in Medicaid claims.
In this environment, actuaries are producing studies suggesting that historical capitation rates are too high. Oregon has the distinction of being the first state where Medicaid mental health managed care capitation rates have been cut twice--by 16.5% in round one and by 12.1% in round two, the latter having gone into effect in January. Washington, another managed care state, implemented a 17% cut in July 2005 based on its actuarial study.
Unfortunately, many Medicaid mental health plans in managed care states have not retooled their systems to adapt to the new regulations and continue to pay providers using alternative payment methods, which is perpetuating the cycle of Medicaid capitation rate cuts. Unfortunately, many of the people who run state mental health authorities and local mental health plans have strong clinical backgrounds but weak financial backgrounds. Other factors contribute to this situation, as well, such as denial, the inability to effect change, political resistance, etc. The question is, how many Medicaid mental health managed care rate cuts will occur before states and regional Medicaid mental health plans are able to reverse the downward trend?
A number of community mental health centers (CMHCs) in managed care states are developing strategies to continue innovative care and protect their funding base. The four strategies described below should be considered by providers in all managed care states.
Fee for service. In several communities in Washington and Oregon, CMHCs have taken the counterintuitive step of encouraging their Medicaid mental health plans to implement modified fee-for-service payment systems that bring the local system into alignment with fiscal realities. In the North Central Washington Regional Support Network, a rural three-county Medicaid mental health plan in Eastern Washington, providers have been working with the plan to phase in a modified fee-for-service model over 12-months. They have helped to develop a fee schedule that supports the work they're doing including a 25% add-on for community-based services.
In Eugene, Oregon, LaneCare, a Medicaid mental health managed care plan operated by county government, has a long history of collaborating with the CMHCs in its network. It adopted a modified fee-for-service model at the start of its Medicaid mental health plan implementation and has consistently experienced some of the highest penetration and utilization rates in the state. While some might describe this as overserving clients, LaneCare's statistics are in alignment with recent prevalence and demand studies, and it has lived within its capitation rates. The most recent innovation has been paying a 15% premium for approved, evidence-based services.
Level-of-care systems. Several communities in the Pacific Northwest have adopted clinical level-of-care systems to ensure that the right services get to the right people at the right time. Two Medicaid health plans in the Portland, Oregon, area have implemented the LOCUS system developed by the American Association of Community Psychiatrists. They have mapped this tool to types and ranges of outpatient services to provide guidance to clinicians as they develop person-centered treatment plans with their consumers. This approach supports a self-managed system, eliminating the need for expensive preapproval processes. Clinicians are encouraged to provide adequate service levels of evidence-based service (up to 100 hours per year for the highest level of care), combined with fee-for-service reimbursement, to meet client needs and draw down available funds.
Electronic health records. Also in Oregon, three counties (Marion, Linn, and Yamhill) have been working together to implement Raintree Systems' integrated electronic health record for their health departments, which provide mental health, substance abuse, developmental disabilities, and public health services. Two of their goals are to achieve cost savings and generate additional revenue similar to projections from a study of a county-run mental health department in California that found:
* 3,000 to 10,000 hours of care were going undocumented, with an annual value between $360,000 and $1,000,000.
* 25,000 to 42,000 hours of clinician time were lost because of inefficiencies in the manual paperwork completion process, with an annual value between $2.2 and $3.7 million.
* 13,000 to 20,000 hours of support staff time were spent on unnecessary medical records work, with an annual value between $500,000 and $700,000.
Clinician reporting systems. In Washington State, a large community mental health provider, Spokane Mental Health, has pursued a strategy to implement a clinician reporting system from iCentrix Corporation. Although clinicians are the main revenue generators, they are often the last to get reports and information about their caseloads and billings. To correct this problem, Spokane Mental Health has implemented a nearly real-time reporting system that provides Web-based, summary, and drill-down details of clinician productivity and services provided, updated nightly from the organization's practice management system.
The challenges described in this article reinforce the need for clinicians to understand mental health financing and for financial staff to support the clinical needs of the population being served. While much good work can take place inside organizations to provide care and pay the bills, this is not enough. Mental health leaders and stakeholders must also work to ensure that local system designs stay abreast with changes in state and federal regulations and work with health plans and lawmakers to support adequate financing for good clinical work.
Dale Jarvis, CPA, is a Consultant with the National Council for Community Behavioral Healthcare, and Linda Rosenberg, MSW, is President and CEO of the National Council. To send comments to the authors and editors, e-mail firstname.lastname@example.org.
BY DALE JARVIS, CPA, AND LINDA ROSENBERG, MSW
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|Title Annotation:||FINANCIAL MANAGEMENT|
|Author:||Jarvis, Dale; Rosenberg, Linda|
|Date:||Jun 1, 2006|
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