Posted by Behavioral Health Billing Solutions, LLC.
Today, additional Managed Care Carve in proposals were announced. The Ohio Council of Behavioral Health and Family Service Providers has put together an extensive proposal intended to be an alternative option to an amendment drafted by Senator Hotting to delay the MCO Carve in from July 1st, 2018 to January 31st, 2019. They were requested to provide an alternative to a delay by Senate members. See below for information sent out over the holiday weekend.
Your outreach and engagement with Senators and House Representatives continues to keep the concerns with system readiness and client access to behavioral health treatment services in the front of legislators. Additionally, The Columbus Dispatch also ran an article on BH Redesign on Memorial Day. The Senate is planning to reconsider the BH Redesign and managed care carve-in next week.
While our primary advocacy remains focused on a delay so that providers, plans, and the state can work through the claims/billing, contracting and credentialing, and other system issues, the Senate also asked us for a recommendation to support “timely payment” should the will of the legislature be to move forward with the July 1, 2018 BH carve-in.
As such, the Ohio Council sent the a Timely Payment Requirement document to Senator Burke and Terhar this week outlining a proposal that would preserve the administration’s July 1st carve-in timeline, allow the MCPs to obtain the resources and responsibilities for utilization management, and care coordination, and providers would be able to continue to send all Medicaid claims through MITS with the MCPs making payments within 15 days. We feel this response allows all parties to achieve their primary objective.
BHBS received the information below from an impacted agency director and wanted to share so other agency’s can view the options available and reach out to their legislator’s to impact change.
Urgent Action is needed to stop further damage to the community mental health and addictions systems and to delay a premature managed care carve in on July 1, 2018. There was an amendment drafted to delay carve in till January 31, 2019. That amendment has been tabled temporarily while the Senate is attempting to reach a compromise and the Ohio Council, with input from other advocates, has made the following proposal.
If you feel that this proposal or a delay to carve- in till January 31, 2019 is necessary, please contact your State Senator and Representative and the Senate and House leadership as listed below.
Time is of the essence. Ongoing conversations are taking place now. Please make these contacts ASAP.
The Ohio Council’s Proposal:
Requirements to Move Forward with Managed Care Carve-In on July 1, 2018and Ensure Timely Payment for Continued Service Capacity and Patient Access
Ohio can successfully move forward with managed care integration on July 1, 2018 only with the following practices in place to ensure continued service access and capacity:
1. Effective July 1, 2018 to achieve timely payment, providers shall submit all current fee-for-service claims that will become the responsibility of managed care via MITS to the Ohio Department of Medicaid (ODM) for adjudication, and ODM shall transmit data to the managed care plans (MCPs) on claims adjudication. The MCPs shall be responsible for paying the claims to providers within 15 days of claims submission to MITS, the same timeline within which the state is currently paying. Providers shall receive remittance advice from MCPs and shall continue correcting and resubmitting denied claims to MITS for adjudication as they do now. This arrangement will remain in place until at least June 30, 2019.
(This recommendation is based on Indiana’s Medicaid Managed care structure were claims are submitted by providers to the state for adjudication and then data is transmitted to plans for payment, care coordination, and utilization management. Indiana uses the same software vendor as Ohio, DXC, for the processing of Medicaid claims.)
Requirement A shall be implemented in conjunction with the strategies already agreed upon by ODM with implementation details further articulated here:
1. All MCPs will make “Contingency Payment(s)” which shall be defined as required payments by ODM in the amount 54.6% of each provider’s Medicaid revenue (inclusive of MyCare claims) in 2016 for up to four consecutive months beginning July 1, 2018. Contingency Payments shall be made on the first of the month for the upcoming month. For example, the Contingency Payment for July shall be made on July 1, 2018.
a. The reconciliation period for Contingency Payments shall be July 1, 2018 to June 30, 2019. After July 1, 2019, the reconciliation process will occur to determine the net effect of over-payment and underpayment for each provider electing to accept the cash advance Contingency Payments. Each provider electing to accept the Contingency Payment and each MCP providing the Contingency Payment shall have 12 months (July 1, 2019 to June 30, 2020) to settle the reconciliation amount. ODM shall ensure that under no circumstances will funds be withheld from providers before the end of the reconciliation period of June 30, 2020 unless agreed upon by the MCP and provider.
b. Providers will be permitted to accept Contingency Payments while also submitting claims and receiving payment through MITS to the MCPs.
2. ODM shall maintain all transition of care requirements with the MCPs and follow all fee-for-service standards for payment and prior authorization through June 30, 2019.
3. ODM and MCPs shall allow covered Ohioans to use any behavioral health provider until at least December 31, 2018 and shall be required to reimburse the behavioral health provider for providing service regardless of contract status between the MCP and the provider.
4. ODM shall form an implementation task force to monitor implementation of this plan, MyCare implementation, and claims testing between MCPs and providers. ODM should also be required to conduct an independent evaluation to assess the impact of Redesign on system capacity and the ability of Ohioans to access services.
Rationale and Benefits of Recommendation A for Moving Forward with Managed Care Carve-In on July 1, 2018 for the Clients and Families that Need Behavioral Health Services:
Recommendation A allows claims to be submitted by providers to MCPs through MITS and ensures the following benefits:
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ODM rolls forward with the carve-in, assigning responsibility for claims payment, care coordination, and utilization management to MCPs on July 1, 2018.
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MCPs receive responsibility for the covered lives as of July 1, including resources for payment of services, care coordination, and data for utilization management and cost analysis.
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Providers continue with claims data submission through MITS, the automated process with which they are experienced and have a higher likelihood of claims adjudicating for payment that supports weekly cash flow. Providers will contract with MCPs by 12/31/2018.
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ODM already processes behavioral health claims and already transmits data to plans on a daily basis.
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MyCare claims adjudication and payment remain with MCPs and become the test ground for IT fixes and overall ability of providers and plans to collaboratively achieve clean claims for services delivered and timely payment of claims.
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Augments legislature’s and administration’s oversight and accountability of increasing the allocation of public resources to CareSource while they are actively on a remediation plan. Creates transparency by allowing time for CareSource to work through identified internal issues that resulted in violation of timely payment standards for multiple quarters, including moving away from manual claims processing, training hundreds of newly hired staff, and rectifying aged accounts receivable with all providers.
After a thorough review of the proposal, BHBS must state that although this covers many of the concerns our clients and contacts with agency’s across the state have relayed to us, there are still several areas that are remain.
Our initial concerns that remain if the MCO Carve in moves forward July 1st under these guidelines are below.
1. They don’t address the fact the provider enrollment of dependents and unlicensed provider’s are extremely lower than they should be. Current state, it would average between 8-10 providers per agency are enrolled and in most cases, 80% of an agency’s workforce are dependents and unlicensed.
2. Agency’s are still struggling with billing post Redesign. We have absolutely no solid numbers to verify how many files failed, how many claims overall denied and an overall reimbursement percentage. The numbers Medicaid has provided do not tie to numbers BHBS is experiencing with a variety of clients so I believe an independent review of sent files and claims is the only way to actually gauge how Redesign is going.
3. We believe the communication between changes Medicaid is making and Managed Care plans needs substantial improvement. And not all plans will be managing claims in the same manner. These difference’s in claim submission are extremely problematic for software vendors.
4. The following statement is unclear. Will prior authorization’s transfer from the MITS portal to the paper process required by the MCO’s?
ODM shall maintain all transition of care requirements with the MCPs and follow all fee-for-service standards for payment and prior authorization through June 30, 2019.
5. Current state, many agency’s don’t have a mechanism or functionality available to them to generate and submit a 270 batch eligibility file to Medicaid or their clearing house to determine clients MCO affiliation OR the unique id’s used by CareSource, Paramount and United Healthcare. For more information on a tool that can generate a 270 file without an EHR, contact EMS Healthcare Informatics here.
It’s important to reach out to the Leadership and Members of JMOC to provide your support or additional concerns. Contact information is listed below.
rep96@ohiohouse.gov; rep39@ohiohouse.gov; rep48@ohiohouse.gov; rep48@ohiohouse.gov; rep34@ohiohouse.gov; Rep80@ohiohouse.gov; rep71@ohiohouse.gov; rep02@ohiohouse.gov; Rep13@ohiohouse.gov; burke@ohiosenate.gov; coley@ohiosenate.gov; gardner@ohiosenate.gov; obhof@ohiosenate.gov; sykes@ohiosenate.gov; tavares@ohiosenate.gov; terhar@ohiosenate.gov; peterson@ohiosenate.gov; manning@ohiosenate.gov
The email addresses listed above belong to either house or senate leadership listed below.
House Leadership:
Presumed House Speaker Ryan Smith (R) (614) 466-3506
Kirk Schuring Speaker Pro Tempore (R) (614) 752-2438
House JMOC Members:
Rep. Stephen Huffman (R) (614) 466-8114
Rep. Nickie Antonio (D) (614) 466-5921
Rep. Mark Romanchuk (R) (614) 466-5802
Rep. Scott Ryan (R) (614) 466-1482
Rep. Emilia Sykes (D) (614) 466-3100
Senate Leadership:
Senate President Larry Obhof (R) (614) 466-7505
Randy Gardner (R) (614) 466-8060
Gayle Manning (R) (614) 644-7613
Bob Peterson (R) (614) 466-8156
Senate JMOC Membership:
Senator Charleta Tavares (D) (614) 466-5131
Senator Dave Burke (R) (614) 466-8049
Senator Bill Coley (R) (614) 466-8072
Senator Vernon Sykes (D) (614) 466-7041
Senator Lou Terhar (R) (614) 466-8068