1. SURVEY
Sent – June 6, 2019
Three questions plus comments
Comments were enlightening

2. COMMENTS
“There seems to be mixed information about who should attend the meetings. I was told the meetings are only for certain providers. Clarification would be helpful.”
“Meetings tend to be more on the formal side; doesn't create relaxed opportunity for natural interaction between community providers and county staff. Consider hosting some "learning circles" or "partner cafe" style convenings to create better connection and strengthen the relationship between community based partners and County staff. It will be nice to periodically have the Department Director and/or the Deputy Director also attend those meetings that showcase the value and commitment they have on strengthening existing community partnerships.”

3. “
Comments Cont.
At times, it doesn't feel there is enough time to have a conversation with the County representatives related to various processes or policies. Consider either extending the time a little bit and incorporate small group discussion as part of the agenda that is a mixed group (to include both contractors and County staff). This way, we'll get to know each other across the "isle". “
“In my past experience the meeting were in relation to treatment by big group providers not private practices.”
“Updates, changes, trends of what is not meeting the standards and discussing how best to meet them.”

4. Comments Cont.
“Many times, the contractors/vendors are in an awkward situation in which privacy is a concern. An example is when the contractor meeting is nearing an end and the county participants are coming into the room during our wrap up time which is a bit.” disconcerting!”

5. Overview Where we are now
Final Rule Update
Overview
Where we are now

6. MMC Final Rule Context
•The MMC Final Rule is the first major update to Medicaid managed care regulations since 2002
• Enrollment in managed care has increased
• Currently, nearly 2/3 of Medicaid beneficiaries are enrolled in managed care
•The Rule advances CMS efforts to achieve the Triple Aim of better care, smarter spending, and healthier people

7. Opioid treatment program – within3 business days of request
Appointment Time Standards
 Urgent care appointment for services that do not require prior authorization – within 48 hours of a request
 Urgent appointment for services that do require prior authorization – within 96 hours of a request
 Non-urgent appointment with a non-physician mental health care provider – within 10 business days of request
 Non-urgent appointment with a psychiatrist – within 15 business days of request
Opioid treatment program – within3 business days of request

8. • Geographic access maps • Accessibility and access summary chart
Network Adequacy Documentation Plans must submit the following:
• Network Adequacy Certification Tool (NACT) • An alternative access request, if applicable
• Geographic access maps • Accessibility and access summary chart
• Language line utilization chart

9. Network Adequacy Certification Tool (NACT)
 Exhibit A-1: Network Provider Data, Organizational/Legal Entity Level
 Exhibit A-2: Network Provider Data, Provider Site Detail
 Exhibit A-3:Network Provider Data, Rendering Provider Detail
 Exhibit B-1: Community Based Services
 Exhibit B-2: American Indian Health Facilities
 Exhibit C-1: Provider Counts
 Exhibit C-2: Expected Service Utilization13

10.  Network adequacy monitoring
Policies and Procedures
 Network adequacy monitoring
• Submit policies and procedures related to the Plan’s procedures for monitoring compliance with the network adequacy standards.
 Out of network access (MHPs Only)
• Submit policies and procedures related to the provision of medically necessary services delivered out-of-network.
 Timely access
• Submit policies and procedures addressing appointment time standards
 Service availability
• Submit policies and procedures addressing requirements for:
oAppointment scheduling
oRoutine specialty (i.e., psychiatry) referral
oAfter-hours calls

11.  24/7 Access line requirements
Physical accessibility
• Submit policies and procedures regarding access for beneficiaries with disabilities pursuant to the Americans with Disabilities Act of 1990.
 Telehealth services
• Submit policies and procedures regarding use of telehealth services to deliver covered services.
 24/7 Access line requirements
• Submit policies and procedures regarding requirements for the Plan’s 24/7 Access Line
 24/7 language assistance
• Submit policies and procedures for the provision of 24-hour interpreter services at all provider sites.
Policies and Procedures Cont.

12. After four submissions (and three re-submissions) of the NACT
Updates:
After four submissions (and three re-submissions) of the NACT
Fresno County’s corrective action plan was found to be out of compliance and at risk of a civil penalty of $ 751, dollars and potential sanctions of $2.18M per month until such time as we are deemed to be in compliance. Then funds would be released back to us.
Fresno County along with many other counties appealed the certification findings. While we have received notice that these particular penalties/sanctions were dropped, The Fresno County MHP still has the potential to be out of compliance for our current submission. We are still waiting for notification and we still don’t have the details of what it takes to be in compliance.

13. Identifying the most high-risk area for non-compliance: Timeliness -
Where We Are Now
Identifying the most high-risk area for non-compliance:
Timeliness -
Concurrent Review
Continuity of Care

14. Going Forward
MSO/PC, Provider Communication – Contracted and In-House
Recoupments
Additional Staffing, Additional Resources