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“Reaching across Arizona to provide comprehensive quality health care for those in need” Access to AHCCCS October 29, 2012 30 Years of Medicaid Innovation Our first care is your health care Arizona Health Care Cost Containment System

Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

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Page 1: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Access to AHCCCS

October 29, 2012

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

Page 2: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Access to Care

Legal Aspects/Implications

Federal Efforts to Date

Arizona Access Efforts

Strategies for the future

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

2

Page 3: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Legal Requirements

Federal Statute 1902 (a)(30)(A)–

“A State plan for medical assistance

must…assure that payments are consistent with

efficiency, economy, and quality of care and are

sufficient to enlist enough providers so that care

and services are available under the plan at least

to the extent that such care and services are

available to the general population in the

geographic area.”

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

3

Page 4: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Legal Issues

Without clarifying regulations further interpretation left to the Courts

Ninth Circuit Court of Appeals – several California cases over proposed rate reductions

“We have several times held that the balance of hardships favors beneficiaries of public assistance who may be forced to do without needed medical services over a state concerned with conserving scarce resources”

Standing issue went to Supreme Court (Douglas v Independent Living Centers)

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

4

Page 5: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

9th Circuit Rulings Continued

“Finally, we have stated that even if § 30(A)

imposes a substantive requirement, a rate

reduction might still conflict with the statute if

at least some providers stop treating Medi-

Cal beneficiaries. Indep. Living II, 572 F.3d

at 656-57.”

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

5

Page 6: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Arizona Ruling on rate reduction case

Hospital lawsuit over rate reductions

March 23, 2012

Secretary relied on (Administrative Record)

Tribal Consultation

Historical hospital provider participation

Additional Measures tracked

Arizona’s “robust” monitoring tools

Court found in favor of the State

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

6

Page 7: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

CMS Proposed Regulations May 6, 2011

First attempt to provide regulatory guidance regarding access requirement

Framework – enrollee needs, availability of care and utilization

Purpose “Create standardized transparent process for states to follow as part of compliance with (access)”

States would have to review access by subset of services every year – all services at least once every 5 years

Information included

Beneficiary Input (hotline – surveys – ombudsman)

Data looking at costs charges – Medicare – other payers

Identify any access issues highlighted by the review

Review must be completed if imposing rate reductions

If state identifies issues – submit Corrective Action Plan

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

7

Page 8: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Arizona Response CMS proposed rule based on MACPAC framework looked at limited

services and did not offer comparison to general population in area

Recommended

CMS partner with states to determine framework

Relying on member satisfaction surveys is not an indication of

community standard

Comparison to billed charges and Medicare not necessarily

relevant

States should be provided with flexibility to determine the

elements most appropriate for review

The inclusion of Corrective Action Plans will increase litigation

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

8

Page 9: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

CMS Access Efforts

CMS working on analytical approach to

monitor access. Evaluating data sources that

can be used

1. Survey data (household and physician)

2. Medicaid Claims data

Work in progress

Held some discussions with States

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

9

Page 10: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

State Concerns

No Specific Medicaid data other then old

claims - currently no encounters (MCO)

Weakness in surveys – what services did they

get

May provide national picture but is it really

comparable?

Is it enough information to inform and take

action?

Page 11: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Significant Measurement Efforts

Numerous fragmented federal efforts around updating and

improving quality measures

What is goal? Actionable data that allows improvement in

health care system

CHIPRA Core

Comprehensive Well Child Core

Adult Core

Dual Eligible

Multiple Chronic Disease

Meaningful Use

CMS Access Measures

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

11

Page 12: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Arizona Access Principles

Create Strong Contractual Network Requirements

Robust real-time Monitoring with information from

plans – systems

Establish Quality expectations and measure

Focus on actionable information to improve system

Do not drown in data – generate information

Disciplined Review of Information

Accountability for plans to perform

Page 13: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Arizona Network Requirements Largely Managed Care

Establish strong network requirements

PCP/Pharmacy within 5 miles (urban areas – 80%+

of population)

Hospital, NF, Assisted Living facilities by region

Appointment standards –emergency/urgent/ routine

Require adequate network for specialists

MCOs must monitor and ensure appointment

availability

Page 14: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Arizona Robust Monitoring

Provider Analysis

Hospital Analysis – other providers

Participation – Financial status – Reimbursement levels

Quarterly MCO report on providers terminating contracts

(250 out of 55,000 in past 2+ years)

Requirement to notify immediately if substantive change in

network

Provider Affiliation Tape – electronic info on MCO providers

Conduct Operational and Financial reviews

Track Member and Provider Grievance and Appeals

Page 15: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Quality Measures

Quality of Care (QOC) process

Significant sentinel events

MCO tracks and trends to determine system issues

Resolve care needed today issues

Performance measures –

HEDIS like

well child visits – dental care

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

15

Page 16: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Actionable Data/Review/Accountability

Measures previously identified are more real time – no

significant lag –

Important because Goal is to take appropriate actions to

improve system

Staff from various division meet quarterly to review health

plan data

Also look at medical management data – IP/ED trends –

pharmacy lockdown etc…

Agency willing to impose monetary sanctions – even have

suspended enrollment

Page 17: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Potential Arizona Population Growth (FY 16) Population FPL Est. # State Cost Total

Children 6-18 100-133 44,000 $33 m $124 m

Eligible not enrolled 0-133 137,000 $225 m $656 m

Childless Adult

Restoration

0-100 154,000 $170 m $1.4 B

Childless Adult not

previously enrolled

0-100 33,600 $37 m $306 m

Optional Parent

Expansion

100-133 42,000 $0 $289 m

Optional Childless

Adult Expansion

100-133 18,000 $0 $165 m

17 30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

Page 18: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

Capacity/Access Strategies

Currently serves population 1.3 million

AZ looking at growth anywhere from 180,000 (14%) to 425,000

(33%) new members

How to expand network capacity?

Program has been increasing GME funding

Currently in procurement – may add plan capacity?

Lessen hassle factor – single credentialing process

Continue to have plans add value for providers – care coordination

data -

Integration efforts – behavioral health – duals

Payment Reform - Gainsharing

Page 19: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

“Reaching across Arizona to provide comprehensive quality

health care for those in need”

30 Years of Medicaid Innovation

Our first care is your health care

Arizona Health Care Cost Containment System

19

Page 20: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued
Page 21: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Access to Care: Balancing

Medicaid’s Goals and Capacity

Heather Foster, MPH

Deputy Director, Federal Affairs

The Community Health Center Perspective

NAMD Conference, Oct. 2012

Page 22: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

The NACHC Mission

To promote the provision of high quality,

comprehensive and affordable health care that is

coordinated, culturally and linguistically competent,

and community directed for all medically

underserved populations.

Page 23: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

What are Community Health Centers?

1,200 Community Health Center Organizations

• Over 8,500 delivery sites

20 million patients served

• Nearly 1 million migrant and seasonal farm workers

• Over 1 million homeless patients

• 48% rural patients

• 92.5% of patients are under 200% FPL

• 37% uninsured, 39% Medicaid

• 35% Hispanic; 25% African American; 4% API

Saving over $24 billion each year!

Page 24: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

What makes a CHC a CHC

• Must provide service to all regardless of patient’s ability to pay

• Community-driven: Health centers must have a patient-majority community board

• Located in or serving patients in a medically-underserved area

• Comprehensive primary care services (all ages)

Page 25: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Services Offered by Health Centers

• Primary Medical Care

• Preventive Health Care

• Prenatal, Perinatal, &

Newborn Care

• Gynecological Care

• HIV Care

• Hearing/Vision Screening

• Oral Health

• Mental Health

• Substance Abuse

• Pharmacy

• X-Rays and Lab

• Specialty Medical

Care

• Enabling Services

Page 26: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Enabling Services at CHCs

• Case Management

• Environmental Health

Risk Reduction

• Health Education

• Interpretation/Translation

Services

• Outreach

• Child Care (during visits)

• Housing Assistance

• Transportation

• Home Visiting

• Parenting Education

• Employment referral

& counseling

• Testing for Blood

Lead Levels

• Food bank/meal

delivery

Page 27: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Health Centers Have a

Unique Role as Primary Care

Providers…

Page 28: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Health Center Patients: Disproportionately Poor, Uninsured, and Publicly-Insured

38% 39%

72%

93%

16% 16%21%

40%

Uninsured Medicaid At or below 100% of

Poverty

Under 200% of

Poverty

Health Centers U.S.

Note: Health Center: Based on Bureau of Primary Health Care, HRSA, DHHS, 2010 Uniform Data System. U.S.: Kaiser Family Foundation, State Health Facts

Online, www.statehealthfacts.org. Based on U.S. Census Bureau 2009 and 2010 March Current Population Survey. U.S. Census Bureau,Table POV46. Poverty

Status by State, August 2010, Annual Social and Economic Supplement, 2010 Current Population Survey. www.census.gov.

Page 29: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Figure 1.5

Health Center Patient Mix Is Unique

Among Ambulatory Care Providers

Notes: Other public includes non-Medicaid SCHIP and other state-funded insurance programs.

Sources: Based on Bureau of Primary Health Care, HRSA, DHHS, 2010 Uniform Data System. Hing E, Uddin S. Visits to primary care delivery sites: United States, 2008. NCHS data brief, no 47. Hyattsville, MD: National Center for Health Statistics. 2010.

39%

13%

31%

38%

4%

9%

8%

17%

14%

14%

61%

37%

2.6 5% 9%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Health Centers Private Physicians Hospital Outpatient Depts.

Other/Unknown

Private Insurance

Medicare

Uninsured

Medicaid

Page 30: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Health Centers Save $$$

Source: Ku L et al, Using Primary Care to Bend the Curve: Estimating the Impact of a Health Center Expansion on

Health Care Costs, GWU Department of Health Policy, Policy Research Brief #14, September 2009

Page 31: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

What Does it Mean for Access:

Balancing Costs & Returns in

Medicaid

Page 32: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Questions?

[email protected]

(202) 296-1721

Page 33: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

For further information about NACHC and

America’s Health Centers

Visit us at www.nachc.org

Page 34: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Measuring Access to Care in Medicaid Managed Care

Joe Moser

Director of Government Affairs

October 29, 2012

Hurricane Sandy

Page 35: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

35

Medicaid Health Plans of America (MHPA)

111 Members 34 States + DC

Page 36: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Access to Care in Medicaid MCOs

• Balanced Budget Act of 1997: Medicaid managed care organizations must offer “an appropriate range of services and access to preventative and primary care for the population expected to be enrolled in such service area.”

• Federal Regulation 42 CFR §438.206: Requirement that each plan “maintain and monitor a network of appropriate providers that is…sufficient to provide adequate access to all services covered under the contract.”

Page 37: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Measuring Access

Page 38: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

How is Access to Care Measured in Medicaid Health Plans?

• Provider to population ratios

– Massachusetts and Maryland: PCPs 1/200

– Virginia: PCPs 1/1500

– South Carolina: PCPs 1/2500

• GeoAccess report and mapping

• Appointment timeliness standards

• Disenrollment reports

Page 39: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

How is Access to Care Measured in Medicaid Health Plans? (cont.)

• CAHPS access questions

• HEDIS access measures

• External Quality Review and other state auditing

• Complaints and grievance data

• Internal monitoring

Page 40: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

A Profile of Medicaid Managed Care Programs in 2010: Findings from a

50-State Survey

Kathleen Gifford

Vernon K. Smith

Dyke Snipes

Health Management Associates

Julia Paradise

Kaiser Family Foundation

Page 41: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Access

• Many but not all states reported that Medicaid MCO enrollees sometimes face access problems

• Improved access to care—both primary and specialty care—was cited most frequently as a perceived benefit of MCOs relative to FFS

• Access problems that exist are due to general problems encountered by all persons in those areas and not due to MCOs

• No assessment of access problems in FFS

Page 42: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Medicaid directors were asked:

“Can MCOs absorb Medicaid

enrollment growth under ACA?”

Page 43: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Medicaid Health Plans Prepare for Medicaid Expansion

• Building network capacity to meet demand

• Partnering to build a stronger healthcare workforce

• Reassessing role of mid-level practitioners

Page 44: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Community Health Centers

• Important source of primary and preventive care for MCO enrollees

• FQHCs recognized as MCO PCPs in 25 of 35 states responding to Kaiser survey

• 30 of 34 states encourage plans to contract with FQHCs in contract language

Page 45: Access to AHCCCS October 29, 2012 - Medicaid Directors · “Reaching across Arizona to provide comprehensive quality health care for those in need” 9th Circuit Rulings Continued

Questions?

45

Joe Moser

Director of Government Affairs

[email protected]

www.MHPA.org