RFI Comments RFI comments received from 48 entities: Plans, Providers, Advocacy Groups, Local Governments, and other Stakeholders All comments logged and sorted into categories Possible change to RFQ; No change; Update guidance documents Common themes were identified across submissions
RFI Comments Some themes were universally supported across submitters Need coordination between PH and BH Providers; Clarification on Health Home and Plan roles; Plans need to understand NY and local BH and non-Medicaid systems of care On some issues there was no consensus between responders
Common RFI Themes Plan experience/ Staffing Flexibility Health Homes Integrating BH Services in Managed Care Information Technology Requirements Network Standards Utilization Management Performance Measurement Plan Reimbursement for Services
Plan Experience/ Staffing Flexibility Focus on the experience of Plan BH staff Sharing of staff between Mainstream and HARP How much sharing is allowed? Ensure coordination of BH expertise between Mainstream and HARP Staffing sufficiency How does the State evaluate adequate number of staff? Differentiate between smaller and larger Plan sizes by allowing flexibility in staffing ratios based on need
Health Homes Clarification needed on Plan/Health Home role and functions regarding care plan development and implementation Health Homes performance standards Health Home capacity Care Management 1915(i) Functional Assessments Standardized Plan/ Health Home contracts?
Integrating BH Services Common concerns: Availability of new 1915(i)-like services providers Capacity to perform 1915(i)-like functional assessments Pricing 1915(i)-like services Plan familiarity with NY service system including non-Medicaid services Challenge of linking Plans to crisis and emergency response services
IT Requirements Balancing need to exchange and integrate data (RHIOs) with fiscal cost and existing technical capability Mixed recommendations on requirements to join RHIOs Availability of IT resources – essential for Providers to be managed care IT ready Need for initial and ongoing Plan billing system support/training Multiple requests for Plan web-based billing capacity
Network Services Plans and providers expressed general support for: Facilitating co-located Article 28 services/BH services Ensuring adequate and coordinated mobile crisis across Plans Mandating contracting for after hour and weekend services General provider support and mixed Plan support on proposed RFQ network standards Contracting with providers serving 5 or more members
Utilization Management Utilization Management Comments Plans reported on current process – need to adjust UM for1915(i)-like services UM should reflect need for ongoing treatment and not just stabilization Need for the State to approve UM criteria and for Plans to inform Providers and the public of these criteria
Performance Management Common concerns from both Plans and Providers Need to know what Performance Measures are Don’t use measures for Pay for Performance in year 1- only establish baseline data
Regulatory Flexibility Overall comments supportive of regulatory flexibility Recommendation to develop Regulatory Workgroup in first year Support for integrated licensing Few specific changes recommended
Plan Reimbursement for Services Overall need to develop sound payment and rate structure on both Plan and Provider level Plans and Providers supported: Innovative Plan/ Provider network partnerships – including sub- contracting for Plan functions BH specific Medical Loss Ratio
State will conduct a survey to identify providers interested potential 1915i providers State is developing guidance for 1915(i)-like services Meeting with MRT BH Workgroup on 2/26/14 Revise RFQ based on feedback State will discuss relevant RFI issues with Plans and Health Home Post RFQ early March Preliminary Premium and Databook shortly after Implement Start-Up Activities (with funding in 2014-15 Executive Budget) Next Steps
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