MHAM Letter from Lansing – April

From Mental Health Association of Michigan: For More Info, Go Here…

Section 298 News
The state Department of Health and Human Services (MDHHS) has announced it will keep Medicaid beneficiaries who aren’t enrolled in Medicaid Health Plans (MHPs) with their existing PIHPs in the new section 298 pilot areas. About 24% of Medicaid beneficiaries in Michigan are not in MHPs. The state’s plan had been to bid out the opportunity among existing PIHPs to manage service for the non-MHP Medicaid population in the three 298 pilot regions. In an April 22 memorandum, the department wrote, “Due to various delays in our efforts to release the RFP and concerns about being able to stand up a successful bidder in timely manner (sic), MDHHS has made the decision to stop the RFP process and keep the unenrolled population with their current PIHP in the Pilot regions.” We were not a fan of the previous plan to bid this out, and are comfortable with the new direction described April 22.

As we await whether the 298 pilots will be ready to start this October, the Senate Appropriations Subcommittee on Community Health/Human Services has reported its budget bill for Fiscal Year-20. Its version of section 298 is problematic and needs revision. The language states in subdivision (1)(a), “The department shall define specific criteria relating to CMHSP ‘willingness’ and ‘capacity’ to provide the full array of services required by section 116 of the mental health code…These services shall include service accessibility, quality, and reasonable cost. Contracts between the department and the Medicaid health plans must require that the Medicaid health plans contract with CMHSPs, unless the CMHSP permits contracting outside the CMHSP network. If a CMHSP does not meet the willingness and capacity criteria, the department shall allow the Medicaid health plans to contract outside the CMHSP network for those services.” We have no problem with doing a readiness review of the pilot CMHSPs. But what about a readiness review of all the pilot MHPs, who have done a poor historical job with managing the so-called “mild-to-moderate” Medicaid mental health benefit, and have no experience managing specialty service for severe mental illness?

The Senate Subcommittee bill also says in subdivision (2) a report shall be prepared by January 31, 2021, indicating what measurement results, if met, would trigger a full statewide implementation of the section 298 concept beginning October 1, 2022. There are several problems with this. First, what about measurement results that would trigger an end to this concept? Second, the timetable laid out in the bill means U-M’s contracted evaluation of the pilots wouldn’t close till March, 2023, yet the Senate Subcommittte wants evaluation results for this monumental decision by January 2021, and is prepared to possibly have the whole state under 298 six months before the final evaluation by U-M is to be completed. Lastly – subdivision (3) – as has always been the case in 298, “savings” would go back into pilot site services, but “savings” isn’t defined. This opens up all sorts of possibilities (e.g., administrative raises) for MHPs to hold onto money they didn’t wind up spending.

We will be working with House members and the Governor’s office on this.

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