Posted by Behavioral Health Billing Solutions, LLC
On May 25th, we received the email below from Ohio Council urging us to go and show our strength as agencies in Ohio and speak out against specific rules that we feel will impact our ability to continue to provide Behavioral Health service and provide the kind of access to services that our communities deserve. The Ohio Council has been and continues to be an advocate for the agencies in Ohio.
May 25, 2017
Ohio Council Members:
WE NEED TO PACK THE HOUSE! Next Tuesday, May 30th at 1:30PM the JCARR Committee will be reviewing the ODM rules intended to implement the behavioral health redesign. We need people to attend the hearing to demonstrate the level of concern we have with the Medicaid rules and the proposed rates. The more people that attend and the more noise, the more likely we are to get some much needed changes made to the ODM rules. Bring anyone and everyone that’s willing to come. So, pack a car (or van) and plan to come to Columbus on Tuesday, May 30th!
JCARR Hearing Location: Statehouse Room 121 (William McKinley Hearing Room), Tuesday, May 30th at 1:30 PM.
JCARR Testimony: We also need several providers to offer brief testimony on the ODM rules and their impact. We must make the case that these rules (including the rates) are flawed. Testimony should be brief (3-4 minutes) and target the 1-2 biggest issues facing your organization with the rules. Below are some additional suggested talking points specific to the JCARR tests:
We are concerned the proposed Medicaid rules will reduce behavioral health service access and capacity and limit the use of our existing workforce, which is not the intent of the legislature.
Crisis services, group counseling, MH Day treatment and SUD residential services will be adversely impacted by the proposed rates. This will disproportionally harm children and adults with the most serious, chronic, and challenging addiction and mental health disorders.
The rules and the BH provider manual will reduce our ability to provide community based care. Medicaid will no longer cover individual or group counseling, MH day treatment, IOP, or SUD partial hospitalization when offered in a court building, church, child welfare office, community center or library. Not only does this make it harder for some people to access care, it also creates new barriers to engaging local community partners or the businesses in responding to the opiate and behavioral health crisis in our community.
The Mercer estimate that the rules will increase Medicaid expenditures by $53.4 million is based on a workforce that doesn’t exist. Using the existing workforce, actuarial consultants collectively estimate a $40 million reduction in Medicaid expenditures based on these rules.
The proposed rule changes create substantial impact on private businesses that serve Ohioans with behavioral health conditions. The cost of clinical practice change, re-deploying staff, staff training along with the business and IT changes are substantial and require investment of limited human and cash resources. The uncertainty of the final rules, BH provider manual, and finalized and tested IT specifications has and continues to add unnecessary administrative and business costs that could be avoided.
If you are willing to testify, please e-mail Gail Clendenin (email@example.com) by 5:00PM on Friday, May 26. We must provide JCARR with a list of speakers by Friday. Gail and I are available to review draft testimony and help you prepare. We will need final written brief testimony no later than 9:00AM on May 30th.
Going to be out of town? You can still participate! Written comments can also be sent to JCARR. If you are only able to send written comments, please use the guidance for testimony above. Be sure to indicate your comments are specifically related to the ODM proposed rules in OAC 5160-8-05 and OAC Chapter 5160-27 and that you are only submitting written comments. Written comments must be submitted by 5:00PM, May 26 to firstname.lastname@example.org and please copy Gail Clendenin (email@example.com).
Your advocacy is critical! We know there are many demands on your time and many competing advocacy requests. Sadly, the administration is exploiting the multiple public processes as a means of reducing our voice by spreading us too thin. The challenges are real. We must come together, stay motivated, harness our strength, and remain vigorously engaged through the next few weeks. Our goal remains achieving the remaining rule and rates changes necessary to successfully implement BH Redesign in a manner that sustains current behavioral health service access, capacity and the workforce.
Teresa Lampl, Associate Director
The Ohio Council of Behavioral Health & Family Services Providers
35 East Gay Street – Suite 401
Columbus, OH 43215-3138
And we came in force! Two full rooms of representatives from agencies across Ohio came to give testimony to the Joint Commission stating why the PENDING rules will cause a negative impact on our communities when rolled out July 1st, 2017. We were there, we were ready and a Medicaid Representative gave testimony postponing the discussion to the next meeting of JCARR on June 19th.
What does that mean?
It means that by postponing the discussion of the rules, they CANNOT be finalized and in place by July 1st, 2017, the deadline for the Redesign. Does that mean the Redesign is delayed?
Unfortunately, not necessarily. Medicaid could still ask for an emergency rule filing to keep the deadline in place. So for us as agencies and advocates for our communities need to continue reaching out to our Senate leaders to reinforce in any way possible that this timeline will be devastating to our communities, the communities we all serve. Be loud, be heard, it isn’t over yet….Stay tuned for more info as it happens.
ODM Proposed Rules
MHAS Proposed Rules