U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Public Health Service
Substance Abuse and Mental Health Services Administration
Center for
Substance Abuse Treatment
This publication was prepared under contract number 270-93-0004 from the
Substance Abuse and Mental Health Services Administration (SAMHSA). Gayle J.
Saunders, of CSAT, served as the Government project officer.
Appendix C of this publication was written by James B. Bixler, M.S., under
contract 270-91-0007 from CSAT. Sandra M. Clunies, M.S., of CST, served as the
Government project officer.
The opinions expressed herein are the views of the authors and do not
necessarily reflect the official position of CSAT or any other part of the U.S.
Department of Health and Human Services.
Today, the U.S. health care system is undergoing a period of rapid change
that will profoundly affect how alcohol and other drug (AOD) treatment is funded
and delivered. Our AOD treatment systems are changing fast, as substance abuse
treatment is increasingly being provided through managed care arrangements.
More than 30 States are actively involved in health care reform plans, many of
which include efforts to treat publicly funded AOD clients through managed care
initiatives. This move to managed care creates tremendous challenges for both
State substance abuse agencies and for local treatment providers, who all need
to be ready to function well in this new, more competitive environment.
Managed care promises many positive benefits, from cost savings to increased
focus on outcomes and on providing appropriate treatment that is targeted to
each individual's need. But the change to managed care also carries very
significant risks for our clients in the publicly funded systempeople who
are often poor, have little political clout, and have serious needs and problems
not typically covered in private managed care plans.
Managed care is essentially a system for providing acute care, while
substance abuse is a complex, chronic, and recurring condition. The length and
intensity of treatment are both important for successful recovery of those with
AOD problems. Many managed care organizations have little experience with AOD
treatment among populations like ours, with their challenging and comprehensive
long-term needs.
Another serious risk is that managed care plans could exclude current AOD
treatment providers, who are experienced with these difficult populations but
may lack the infrastructure and the resources required by managed care
organizations (MCOs). These providers, who have worked long and hard to provide
services to poor and uninsured clients with multiple needs, deserve the
opportunity to continue their services in this competitive new environment.
Nothing is more important at this particular time than the specific contract
stipulations that will be made between the States and MCOs regarding AOD
services. Personnel in State agencies will need to work through a wide range of
issues as they prepare to purchase, manage, monitor, evaluate, and develop MCO
standards for providing managed care services to those with AOD problems.
Managed care initiatives need to be well designed, carefully developed, closely
monitored, and strongly enforced.
States can do much to establish workable, positive contracts with managed
care providers that will be comprehensive and equitable for all. Carefully
developed contracts can benefit AOD clients now being served in the publicly
funded system, as well as supporting our existing AOD treatment providers as
they move into the new system. Such contracts can also provide for our
particular concerns regarding these clients, including their need for ready
access to care, for outreach, for adequate, long-term benefits, and for the
special services needed by pregnant women, parolees and probationers,
adolescents, and ethnic or cultural groups.
This document is intended to provide guidance to those in State AOD and
Medicaid agencies who will be undertaking essential roles as planners and
managers of managed care contracts. To address critical issues in this emerging
area, the Center for Substance Abuse Treatment (CSAT) sought the advice and
direction of a publication development panel made up of experts from States that
are already well advanced in developing State managed care plans for AOD
clients. The guidelines and recommendations presented in this document are the
result of their efforts.
On behalf of CSAT, I wish to express my grateful appreciation to the
publication development panel and its chair, Jeffrey N. Kushner, and to Stephen
Moss, Ph.D., the consultant and writer. I also wish to extend special thanks to
the many dedicated individuals who reviewed this document and provided their
comments and expert advice.
The expertise of all of us working together will be neede das we learn to operate successfully in this new managed care environment and seek to preserve the right of publicly funded AOD clients to receive adequate, appropriate, and effective treatment. Within this context, CSAT is pleased to publish this document as part of our mission, in partnership with State and local governments and community-based programs, to imporve the access and effectiveness of addiction treatment and recovery services on a nationwide scale.
We hope this manual will encourage and guide State agencies and treatment providers as they take an active and influential role in shaping and managing our evolving health care system.
State alcohol and other drug (AOD) authorities find themselves in the midst
of revolutionary changes now occurring in the health care and AOD treatment
fields. Regardless of the eventual outcome of national health care reform
efforts, States are continuing to enact legislation that is rapidly transforming
the service delivery landscape. More than 30 States are in the process of
legislating some form of health care reform, and most of these reform efforts
include the delivery of AOD treatment services with some form of managed care at
their core.
Because many managed care organizations (MCOs) have little experience with
AOD treatment among noncommercial populations, the State AOD directors must
assume a primary role during this turbulent time. State directors must advocate
aggressively for the needs of uninsured and publicly insured populations.
Directors can best achieve this role by maintaining their access to the
expertise of today's publicly funded treatment providers. These treatment
providers, after years of providing services to these challenging and
disempowered populations, have developed a wealth of knowledge and experience
about how to reach out to and treat these groups.
Managed care consists of a set of health care management tools that have the
capacity
both to increase the overall quality of a treatment system
dramatically and to wreak havoc. Managed care initiatives must be
well-conceptualized, carefully developed, closely monitored, and strongly
enforced. A strong managed care contract must be developed to deal with a set of
particular components. Such a contract must:
Public AOD treatment systems have been largely exempt from the impact of the
managed care movement that has swept through the rest of the health care
industry. This exemption is quickly evaporating. In this new environment, the
AOD field must seize the opportunity to frame the debate. State AOD authorities
and others involved in the field need to ensure that they play an active and
knowledgeable role as new AOD treatment paradigms are being created.
| Goal | |
| The goal of this document is to help prepare State AOD
directors and others (e.g., Medicaid authorities, MCOs, AOD treatment providers,
AOD policy makers, and purchasers of managed care services) to: |
- Provide some model contract language for State agencies to use and build
upon with MCOs
|
- Actively participate in the development and management of managed AOD
treatment systems in the context of State health care reform initiatives
|
- Describe potential strengths and weaknesses of managed care system and
identify strategies for using managed care to achieve specified goals
|
- Provide guidance to contract effectively with, manage, monitor, evaluate,
and/or develop standards for an MCO
|
- Describe state-of-the-art managed care practices for AOD treatment
|
- Increase conceptual and pragmatic understanding of how effectively to
develop and manage a contract with an MCO that will best achieve system goals
|
- Provide an overview of financing, contracting, and network management
issues
|
| Objectives |
- Identify data needed to monitor access, quality, cost, problems, and
outcomes of a managed care system
|
- Provide an overview of current managed care systems as they relate to
public AOD treatment systems
|
- Identify critical issues to focus upon when working with MCOs
|
|
- Describe necessary and effective mechanisms for appeal, grievance, and
consumer protections
|
Chapter 1Managed Care Overview
Substantial confusion about the meaning of the term "managed care"
exists among both the general public and alcohol and other drug (AOD) treatment
professionals. For purposes of this document, managed care can be described as "an
organized system of care which attempts to balance access, quality, and cost
effectively by using utilization management, intensive case management, provider
selection, and cost-containment methodologies." Tension naturally exists
between the fiscal objective of conserving funds and the clinical goal of
providing appropriate, quality services in a timely manner to all those who need
them.
Since its inception, the managed care industry has movedand is movingthrough
several "generations." A basic understanding of the generations of
managed care can be helpful in understanding managed care behavior and the
maturity of systems (Center for Substance Abuse Treatment 1994; Waxman 1994).
- The first generation of managed care focused on reducing costs by
restricting access to services through such means as overly rigid
utilization review, limited benefits, and large copayments.
- The second-generation managed care organizations (MCOs)
manage benefits. They focus on the development of provider networks,
selective contracting, increased treatment planning, and a less rigid
utilization review process.
- Third-generation MCOs focus on managing the care of enrollees by
emphasizing treatment planning and carrying out more active management of
clients through the course of their treatment(s). This involves enhancing the
breadth and "seamlessness" of the continuum of care and actively using
the least restrictive treatment settings that are clinically appropriate. The
MCO may provide highly individualized clinical management for individuals who
are at high risk for multiple readmissions or who are particularly challenging
to treat.
- A fourth generationnow being aspired tois for MCOs to manage by
outcomes. This model seeks to focus primarily on the outcomes of treatment and
allows great provider autonomy regarding how these outcomes are achieved. To the
extent that the field moves toward this "outcomes management" model,
research and clinical findings will be fed back to treatment programs, which
will in turn provide new data for further analysis. This will create a self-correcting
treatment system.
Numerous variations of managed care are rapidly evolving across the country.
However, States are most likely to consider only the handful of managed care
models that best meet their needs at this time. The most probable models of
managed care include health maintenance organizations (HMOs), the managed
behavioral healthcare organizations (MBHCOs), and regional integrated service
networks (RISNs). Since most State development will be built upon these models,
or variations of these models, State AOD directors need a basic understanding of
their strengths and weaknesses.
Health Maintenance Organizations
Health maintenance organizations are healthcare organizations that provide
and/or ensure the delivery of an agreed-upon set of health maintenance and
treatment services to a group of persons for a prepaid amount of money.
The most common form of an HMO is a staff model in which treatment
professionals are salaried employees. Other models include:
- A "group model" (contracts for services of treatment
professionals in a group practice)
- A "group network" (treatment professionals in a group
practice who also accept other patients)
- An "individual practice association" (in an IPA, the
management organization administers the plan and contracts with independent
treatment professionals who are generally paid a fixed sum of money per person)
- A "preferred provider organization" (in a PPO, the payer
directly contracts with individual providers at reduced fees and a guaranteed
volume)
For AOD treatment, a theoretical advantage of the HMO model is that AOD
treatment is integrated with physical medicine and thus is more in the
mainstream of general health care. Many believe that this strengthens AOD
treatment services by increasing the understanding of how medical costs are
related to AOD-related problems, thus highlighting the high medical costs
associated with these problems. In reality, however, HMOs have often provided a
very narrow range of mental health and AOD services. The primary care physicianusually
the gatekeeperis often insufficiently trained in screening for, or
diagnosing, AOD disorders.
In HMO settings, mental health and AOD treatment services (i.e., behavioral
health services) are often overwhelmed by the physical medicine departments.
Behavioral health services are often also undervalued, because these disorders
are not well understood by health care administrators. Behavioral health
services account for only a small percentage (e.g., 3 percent) of the total HMO
expenditures, with AOD treatment services accounting for as little as 1 percent.
Since AOD treatment services represent such a small part of the total services,
they are often relegated to the background and sometimes are not even tracked.
As a result, more than half of all HMOs now contract with specialized firms to
enrich their behavioral health treatment services and to remain competitive
(Levin et al. 1984; Levin 1993; Frank and Salkever 1991).
Managed Behavioral Healthcare Organizations
This general shortcoming in the HMOs led to widespread criticism and to the
rise of MBHCOs. These firms provided all, or specified components of, AOD and
mental health care to an enrolled population for a prepaid capitated payment.
They offered a range of "products" dedicated to managing mental health
and AOD treatment needs. This MBHCO industry rapidly expanded from the last half
of the 1980s until about 1992. This dramatic growth created a highly competitive
environment that resulted in the active involvement of venture capitalists,
frequent acquisitions and mergers, and general instability in the industry.
During this growth period, financial concerns often took precedence over the
quality of care provided to individuals.
The early 1990s brought a period of consolidation that resulted in the
domination of about a dozen major MBHCOs. These organizations aggressively
establishedand continue to establishcontracts with corporations,
governments, and HMOs around the country. These companies now collectively cover
approximately 80 million lives (Oss 1993).
In an MBHCO, AOD and mental health treatment needs are not overshadowedas
can happen in an HMOby the dominance of medical needs. However, these
services are not naturally integrated with the medical care system. This lack of
a natural bridge for linking individuals with necessary medical services can
create incentives to shift costs to the medical sector (Christianson 1989). In
addition, AOD treatment can be overshadowed by the mental health sector.
Regional Integrated Service Networks
Regional integrated service networks (RISNs) are a group of mental health
and/or AOD providers who have formally organized into a functional entity to
provide, manage, and/or oversee the delivery of specified behavioral health care
to a defined population. The creation of these networks is a fairly recent
phenomenon, but is gaining momentum as increasing numbers of providers and
provider organizations attempt to respond to the growth of managed care.
These networksvariations of provider-based PPOscan vary
dramatically in terms of their comprehensiveness, sophistication, and
marketability. While RISNs may collectively include a full range of needed
services, they may lack the capital, technical expertise, and/or experience to
participate successfully in the competitive managed care industry. To compensate
for this, networks have the option of purchasing administrative services only
(ASO) from an appropriate partner to strengthen the network.
In developing the network, State AOD authorities and other policymakers need
to make a decision regarding whether or not to join with mental health providers
and form a comprehensive behavioral health network tailored to the unique needs
of the State. The advantage of doing so is that combined AOD and mental health
services are the norm in existing managed behavioral health companies. The
majority of the purchasing market is therefore looking for an integrated
product. A disadvantage for AOD treatment providers in such networks is that AOD
services are usually the smaller component both in terms of programs and in
management. The particular circumstances in a given State should dictate whether
an RISN should be formed and what its ideal composition should be.
Virtually all Federal and State health care reform initiatives envision the
integration of public and private behavioral healthcare systems. Public
behavioral healthcare funding streamsfrom Medicaid, Medicare, the
Department of Veterans Affairs, CHAMPUS, State organizations, and other public
payersare now being redirected to purchase privatized behavioral
healthcare services. MCOs are increasingly entering this new market niche.
These public-private integration efforts will most likely result in rapid growth
of privatized service capacity for publicly funded populations.
Until recently, public purchasers and private sector MCOs have been fairly
cautious in terms of forming any kind of working alliance. The MCOs were
generally focused on surviving in the highly competitive private sector. They
often believed that employed enrollees and their families are generally more
stable, more predictable, and easier to treat effectively as compared to public
program beneficiaries, who were seen as less stable, more difficult to treat,
and more expensive to cover (Christianson 1989). Public purchasers were not sure
that the models and expertise developed by those serving private-sector clients
would easily generalize to more vulnerable and impaired populations.
However, in examining the experience of MCOs in the private sector,
government policy-makers have become increasingly interested in experimenting
with alternative healthcare delivery systems. The hope is that these
alternatives will help contain costs and improve quality of care. As a result,
more than 30 States are now in various stages of developing health care reform
measures. These almost always incorporate managed care concepts or the direct
purchase of managed care services.
Despite this movement, community-based, public-sector providers are often
skeptical about the ability and incentives of private-sector MCOs to provide
appropriate services for vulnerable populations. They believe that most MCOs are
not highly experienced in treating publicly insured clients and lack
well-established links with key community-based agencies. Such MCOs would
therefore be less effective in successfully serving this difficult treatment
population.
Most MCOs, on the other hand, believe that their systems of care can be
adapted to meet the needs of these populations effectively. They anticipate the
integration of public and private health care systems. Eager to enter this
evolving market, they are showing dramatically increased interest in serving
publicly insured populations.
The strong interest of MCOs in providing services for public program
beneficiaries, combined with the strong interest of public payers in using MCOs
to help achieve cost-containment and system development goals, will soon result
in greater blending of the "private" and "public" systems of
care. The collective challenge to overall health care reform is:
- To integrate the best of what the community-based public sector
treatment systems and the managed care industry have to offer, and
- To build collaboratively the system of care that will take AOD treatment
into the next century.
Currently, State Medicaid agencies all over the country are developing
innovative managed care systems. The Medicaid system now has about 12 percent of
its 30 million benefi-ciaries currently covered in some form of managed care,
and these numbers are expanding rapidly. These systems are directly affecting,
or will be affecting, the delivery of AOD treatment services. State AOD agencies
are in a key position to engage actively with State Medicaid systems and become
collaborators in developments occurring now and in the foreseeable future.
Two Federal Government Medicaid waiversallowing States to experiment
with new models of carecontinue to create opportunities for States to
pilot innovative managed care models. The "1115" waiver, the most
comprehensive, is used to establish pilot or demonstration projects, usually
through a Request for Proposal (RFP) process. The "1915(b)" waiver
allows the State to "lock in" Medicaid beneficiaries to certain
provider classes and to create central intake systems.
The Medicaid projectsdesigned to provide more carefully managed,
clinically appropriate, and cost-effective care to lower income and more
clinically challenging populationsare at the cutting edge of the State
healthcare reform movement. The manner by which the government and managed care
entities decide and implement the delivery, management, payment, and measurement
of care for Medicaid populations is the crucial question. The answer will
broadly impact both the direction of healthcare reform and the publicly insured
clients themselves.
Massachusetts, Minnesota, Oregon, and Tennessee are some of the most
well-known examples of States that are implementing major managed care programs.
State programs are described below.
Massachusetts
Massachusetts has one of the most extensive managed care initiatives in the
country. In 1992, the State Medicaid agency contracted with a national MBHCO
that specializes in servicing the public sector. This MBHCO would manage mental
health and AOD treatment services for about 400,000 recipients in Massachusetts.
An active collaborative relationship has evolved between the MBHCO, Medicaid,
and the State AOD authority.
The project is widely viewed as being both fiscally and clinically
successful. Since its inception, the MBHCO has halved AOD treatment costslargely
through eliminating unnecessary hospitalizations, improving overall access,
developing useful profiles of program performance, adding new levels of care,
and expanding methadone treatment services. It has currently implemented
intensive office-based and community-based case management services for the most
challenging clientsthe addicted, dually diagnosed individuals and/or
pregnant women with AOD problems. An independent evaluation detailing the
strengths and weaknesses of this project, mandated by the Health Care Financing
Administration, is now available (Callahan et al. 1994).
Minnesota
Minnesota has the longest experience in handling the interface of managed
care with AOD treatment. Two initiativesthe Consolidated Fund
and the Chemical Dependency Treatment Accountability Planare now
up and running.
The Fund consolidates a variety of AOD treatment funds into a
single consolidated fund. The Plan collects data on patient
demographics, severity of illness, and treatment placement. It then looks at
outcomes by measuring abstinence, utilization of health care services,
encounters with the law, on-the-job productivity, and family impact. In an
attempt to optimize cost-efficiency and quality outcomes, it will provide better
parameters for improving client match to the appropriate setting, treatment
modality, and clinical intensity.
Tennessee
In January 1994, by Executive Order, Tennessee implemented a Medicaid waiver
that totally replaced its Medicaid system with Tenncare. Under this
system, the State minimized its healthcare management responsibility and reduced
its costs by contracting on a capitated basis with competing MCOs.
The cost savings have allowed the State to provide total health care with no
tax increase to all Medicaid-eligible individuals (about 800,000), plus another
350,000 people who were formerly uninsured or uninsurable.
To be eligible to contract with Tenncare and compete for
subscribers, each MCO had to establish a comprehensive healthcare provider
network, including AOD services. Some MCOs chose to manage AOD services
themselves, while others subcontracted behavioral health (mental health and AOD)
to an MBHCO that, in turn, established a provider network.
The minimum AOD benefit package which Tenncare requires MCOs to
provide includes two episodes of treatment per lifetime. This minimum has, in
reality, become a maximum for most MCOs. Discussions are ongoing about whether
to increase or remove this benefit limit, since many people have already
exhausted it.
This system will also examine the cost offsets of providing comprehensive
AOD coverage. Monitoring, evaluation, and data-reporting to the State by the
MCOs is just beginning and reliable data are not yet available. Anecdotal data
on AOD treatment show a shift occurring in primary treatment modalities
from inpatient hospital treatment under Medicaid to precertified outpatient
services under Tenncare.
Oregon
In 1993, the Oregon legislature enacted a bill that includes AOD treatment
in the Oregon Health Plan, a plan designed to provide health care to the
uninsured and poor. Oregon's vision was to integrate AOD treatment services
fully into a comprehensive set of services that are managed and coordinated via
primary care and case management.
These comprehensive services would include medical, surgical, and AOD/mental
health services, so that the needs of the whole person can be met. The stated
goal was to include AOD treatment services in the plan to reduce the
inappropriate use and cost of medical and surgical services.
It was understood by all parties involved with this legislation that AOD
treatment services, if provided appropriately, would reduce the other health and
social costs that inevitably occur when AOD problems are left untreated. The
Oregon Department of Human Resources is the buyer and sets standards, capitation
rates, and other requirements for the management of the Plan. The Oregon Office
of Alcohol and Drug Abuse Programs (SSA) is charged with implementation of the
AOD budget, including development of contract standards, placement/discharge
criteria, and screening instruments.
MCOs, mostly HMOs, are the managers of the Oregon Health Plan operating
within defined geographic boundaries across the State. These MCOs determine the
procedures, amounts and methods of payments, and providers to be used in their
geographic area. The State has required that the MCOs must initially plan to
refer at least 50 percent of their plan members who need AOD treatment to
identified "essential community providers." This is intended to ensure
that public safety, welfare, and other public costs are protected during the
transition into and implementation of managed care. Essential community
providers are programs that previously received funds from the Single State
Agency (SSA).
Implementing a managed care system is extremely threatening to the status
quo. Concerns about managed care abound because of past performance and
perceived structural shortcomings. Many fear the potential of an MCO for causing
harm to the AOD treatment system and to the vulnerable populations that system
serves.
It is important to understand the breadth of concerns that have been raised
about managed care. These concerns serve as a collective example of what can
happen if a managed care initiative is poorly executed (see table 1). This
understanding can be critical to State AOD authorities as they attempt to
develop stipulations in their managed care contracts that will effectively guard
against such abuses.
In assessing the implementation of managed care, it is essential to
understand that MCOs are vendors of a service who have negotiated
service contracts with a government agency, private company, or other entity.
These service contracts are designed to achieve specified financial,
administrative, system development, and clinical goals. Consequently, both the
contracting agency and the MCO share the successes and failures of a particular
initiative.
Managed care, having demonstrated the capacity to contain costs in the
private sector, is increasingly being proposed as a possible solution to the
many challenges that face public sector purchasers of behavioral health care. It
is seen as having the capacity to:
- Develop incentives that increase accountability
- Build an integrated continuum of treatment services
- Introduce much-needed innovation
Managed care techniqueswhen properly appliedoffer many
new opportunities to State AOD systems. Managed care's powerful tools and
methodologies can be applied to develop new systems, reallocate finite
resources, expand access, improve quality of care, and/or to "jump-start"
a treatment system to help it keep pace with the rapidly evolving healthcare
system. Any enlightened, systemwide reform should proceed based on an
appreciation of how managed care strengths can be used to achieve reform goals
and to reform service delivery systems.
Each State and region differs in its specific financial, political, and
systems development reform needs. Nevertheless, quality AOD treatment has basic
components that cut across these individual circumstances. These components are
described below.
Table 1. Common Criticisms of Managed Care
- Emphasizes short-term cost-cutting at the expense of long-term outcomes and
savings
|
- Has fiscal incentives to delay, deny, or restrict care
|
- Is used as a means to diminish or eliminate AOD treatment services, or to
undertreat AOD clients
|
- Refuses to purchase longer-term residential care (e.g., recovery homes,
therapeutic communities)
|
- Overemphasizes cost containment and underemphasizes quality of care,
program content, staffing, and clinically oriented concerns
|
- Sets arbitrary limits on the duration, type, or access to treatment
|
- Utilizes gatekeepers who are poorly trained and/or inexperienced in AOD
treatment services
|
- Restricts methadone maintenance as a treatment option for opioid-addicted
individuals
|
- Is inexperienced in managing special popluations (e.g., ethnic/racial
minorities, criminal justice referrals, injection drug users)
|
- Relies excessively on outpatient treatment models
|
- Uses overly restrictive interpretations of "medical necessity"
that contradict or otherwise neglect basic tenets of AOD treatment
|
- Is based on the needs of the employed and not the unemployed/underemployed
|
- Makes referral decisions based on general policies and procedures rather
than on individual client needs
|
- Lacks national standards and is unregulated
|
- Has inadequate grievance procedures
| |
Many State AOD authorities need to decide which path to pursue regarding
their relationship with managed care. The AOD authority must first consider
carefully the current strengths and weaknesses of the AOD treatment network, the
current status of managed care for publicly funded beneficiaries within the
State, and the future desired design of the service delivery system. State
situations vary widely on many important dimensions. These include:
- Stage of managed care development
- Staff and financial resources
- Political support for AOD treatment services
- Relationship with the State Medicaid agency
- Extent of sparsely populated areas
- Affiliation with other State agencies
Conducting an Inventory of the Current System
To achieve maximum benefit, the AOD authority should perform a careful and
critical inventory of the current system. It should minimally include:
- An examination of the resources available to the State
- Unmet treatment needs
- Regional and statewide gaps in a full continuum of care
- Cultural and ethnic capacities
- Sufficiency of linkages to housing, social, educational, health care, and
other services
- Adequacy of fiscal oversight and accountability
- Effectiveness of outreach efforts
- The quality of screening, assessment, and placement processes
- Maturity and utilization of quality improvement methodologies
- Breadth and sophistication of the management information system
- Status of followup data on treatment outcomes
Establishing Priorities
Establishing priorities for system development is a key step when
considering a managed care initiative. Questions that can be asked include:
- Is there a preference for uniformity or diversity in services for a
specified modality of treatment?
- Is there a preference for a larger number of smaller programs which
are joined into a network of services, or for a smaller number of larger
programs that have multiple levels of care and services?
- What are the priorities for program expansion or reduction?
- Is rapid development or slower, more measured development more
appropriate?
- What services are currently provided at public cost? Which agencies
fund these services and is there a consensus in goals?
- Are there currently achievable savings in the AOD treatment system?
- Can medical/surgical costs be substantively reduced by increased
access to AOD treatment?
- To what degree are payers, legislators, and the citizens of the State
supportive of addiction treatment?
- Who are the key policymakers and what relationships exist? What
commitments will they make to AOD services?
The ramifications of the answers to these questions should be carefully
assessed to facilitate achievement of desired goals.
Choosing the Optimal Approach
The AOD authority must decide between two options. One is whether
to support the development of a comprehensive, "one-stop shopping"
approach to servicewhere a client can receive a variety of medical,
educational, and social services onsite along with AOD treatment.
The second option is to support the development of more free-standing,
specialty AOD treatment programswhere a client is referred to other
community resources for medical care and for educational, social, and other
services. The unique set of circumstances in each State should strongly guide
the decisionmaking about these options.
To the extent possible, the State should consider whether its long-term
goals for the treatment network are consistent with any proposed managed care
plan. If the managed care plan does not promote the treatment goals of the
State, the State should seek to modify the managed care plan instead of the
treatment goals.
Achieving Maximum Benefits
Managed care systems offer a set of specific clinical technologies that can,
in the right circumstances and with careful planning, reshape treatment systems
to achieve specified goals (see table 2). Managed care is a flexible and
powerful toolwith clear strengths and weaknesses that can be adapted
to a variety of circumstances and used to transform systems in desired
directions. Misused, poorly managed, or poorly implemented managed care programs
can cause great damage. State AOD authorities and other purchasers of AOD
treatment services will benefit from doing a thorough needs assessment and then
carefully considering the degree and manner in which managed care
would be the most appropriate vehicle to implement reform initiatives (H.
Bartlett, New York State Office of Mental Health and Substance Abuse Services,
personal communication, 1994).
Much of the current expansion of publicly funded AOD treatment across the
country results from the expansion of Medicaid AOD treatment services. However,
it is important to understand that managed care is only one of the tools
available to effect desired changes in the treatment network. There are many
ways to change the quantity, quality, and mix of treatment types available in
any State. This can be done through regulations, legislation, licensing,
oversight, monitoring, and a variety of direct funding and contract schemes. To
best achieve the prevention and treatment goals established by the State, it is
important to ensure that these efforts work in concert with a managed care plan.
Given the impact that managed care can have, it is imperative that, once a
decision is made to use managed care, a strong and well-thought-out contract be
carefully developed, closely monitored, and strongly enforced. The contract
must specifically address all key areas, clearly specify expectations,
outline valid and efficient means to monitor compliance, and have strategies to
enforce this compliance. The MCO should submit a written description of how it
intends to comply with contract specifications. A well-designed contract will
maximize the chance that a given managed care initiative will achieve its
desired goals.
For publicly funded treatment, Single State Agencies for AOD abuse treatment
are probably in the best position to monitor stipulations of the AOD abuse
contract. SSAs should approach State financing agencies and insist on developing
and monitoring AOD contract stipulations with MCOs. It is the SSAs'
responsibility to manage the MCO vendors effectively, so they ensure compliance
with both the letter and the spirit of the contract.
The managing team overseeing the contract must be strong, and any gaps in
their knowledge, experience, or skills must be filled through collaboration with
others or through consultation services, which are widely available. There
should be no confusion whatsoever about the fact that the MCO will be held
accountable for achieving specified goals.
The remainder of the MCO contract should focus on key issues relating to AOD
treatment and managed care. These include:
- Comprehensiveness of care
The following four chapters in this book discuss how these arenas should be
addressed by managed care providers. Three of these chapters contain sample
contract language.
Table 2. Possible Goals/Objectives for Managed Care
| Increase Access to Treatment | Improve Service Efficiency |
- Increase service capacity
|
- Maximize cost-efficiency of service delivery system
|
|
- Reduce inappropriately long stays in any level of care
|
- Build a more comprehensive and seamless continuum of care
|
- Improve utilization of the most appropriate levels of care
|
|
- Increase the "seamlessness" of service betweenlevels of care
|
|
- Reduce the delivery of AOD services in hospital settings
|
- Facilitate earlier identification of AOD problems
|
- Eliminate unnecessary paperwork and processes
|
- Increase access for cultural/linguistic minorities
| Improve Access to Wraparound Services |
| Improve Quality of Care |
- Improve all access to the full range of wraparound services that are
critical to the recovery process (e.g., employment, vocational, and child care
services)
|
- Implement state-of-the-art, continuous quality improvement technologies
|
- Improve efficiency of systems to triage and monitor client flow
|
- Increase the clinical focus on complex clinical cases
|
- Influence wraparound services to create greater access for individuals with
AOD problems
|
- Increase the accountability for client outcomes
| Improve Outcomes Measurement |
- Expand the capacity to track and monitor individual case progress
|
|
- Improve the care practices of providers
|
- Measure injection drug use
|
| Improve
Medical Linkage |
- Measure overall health status
|
- Improve linkages betwen individuals with AOD problems and primary care
|
- Measure overall level of functioning
|
- Improve screening for AOD problems in medical settings
|
- Measure criminal activity
|
- Reduce health care costs by reducing frequency of untreated AOD problems
|
- Measure client satisfaction
|
- Improve screening for medical problems by AOD treatment providers
| |
| |
| |
| |
Chapter 2Access to Treatment
Maintaining and improving overall "access" to the treatment system
is arguably the most important issue to monitor when first implementing managed
care into public treatment systems. Access generally refers to the capacity of a
treatment system to facilitate entry into the appropriate treatment, as well as
the continuance of that treatment, for all individuals who need it.
The extent of access to appropriate treatment in a managed care system
depends on the amount of resources devoted to alcohol and other drug (AOD)
treatment services. To understand how much access can be implemented for AOD
clients, a key variable will be the resources that are made available.
Most treatment systems have access problems that influence whether or not an
individual can obtain and continue to utilize treatment services. Uninsured and
publicly insured individuals often lack the resources and the knowledge to
negotiate their way through overly bureaucratic systems. Every effort must be
made to facilitate their entry into the treatment system. Potential barriers to
treatment must be carefully analyzed and steps taken to lessen or eliminate
these barriers.
In a managed care environment, access to treatment can be hindered in a
variety of overt and covert ways. It is imperative that key measures of access
be closely monitored to ensure that access is not intentionally or inadvertently
restricted.
Access in AOD treatment refers to a variety of diverse factors. Some of the
most important factors include:
- Understanding of AOD problems by gatekeepers
- Structured outreach activities
- Timeliness of the first face-to-face meeting after an initial contact
- Geographic proximity to appropriate services
- User-friendliness of the intake and referral systems
- Absence of financial barriers
- Cultural, ethnic, and gender-sensitive treatment
- Adequacy of AOD treatment funding and resources
Understanding of AOD Problems by Gatekeepers
All too often, gatekeepers into treatment are not sufficiently trained or
experienced to assess needs effectively and to triage individuals into
appropriate AOD treatment. It is crucial that such gatekeepers (e.g.,
clinicians, primary care physicians) be well-trained, sensitive to the
bio-psychological aspects of addiction, and monitored regularly.
Structured Outreach Activities
Structured outreach activities maximize access to a treatment system by
providing systematic efforts to identify individuals in need of AOD treatment.
Such outreach activities might be directed to pregnant addicted women, homeless
AOD abusers, injection drug users, or others whose impact on society is high and
who are less likely to seek out treatment on their own.
Timeliness of Treatment
Immediate and convenient initial access to qualified providers is a hallmark
of any quality treatment system. A key component of high-quality treatment is
how efficiently a person in need can obtain appropriate AOD treatment. The
motivation to address AOD problems is often fleeting, and a delay in access can
easily result in a crucial missed opportunity to initiate treatment. Contracts
with managed care organizations (MCOs) should ensure rapid access to all levels
of treatment.
Detoxification should be understood as an emergency care service.
Individuals should have very easy access (i.e., same day or the next morning) to
detoxification evaluation and treatment services 7 days a week.
While screening can occur over the telephone, evaluations should be face to
face. Standards should assure 24-hour telephone intake, immediate referral
capacity, and rapid access to appropriate treatment. Noncrisis treatment should
generally be available in 1 to 3 days (Zwick and Berman 1992). It may be decided
that some subpopulations (e.g., pregnant women, injection drug users) should
receive higher priority or more immediate access within the system.
Geographic Proximity
Appropriate treatment services must be within reasonable distance for the
population served. The maximum distance in time or miles should be determined
for each level of care. Since most publicly insured recipients do not have
reliable transportation, services should be accessible via public transportation
whenever possible. Special plans may be required in rural areas, including the
use of volunteers or members of self-help groups to provide transportation. Any
outpatient services should be especially easy to access.
"User-Friendliness" of Systems
The "user-friendliness" of a system describes the overall ease
with which an individual can negotiate the various steps of a treatment system.
To assure access, when policies and procedures are being developed for an MCO
plan, it is essential that ease of use should assume the highest priority. Those
who utilize the services offered are in an excellent position to rate their
access to that service. For example, information regarding the time to first
appointment, ease of telephone access, ease of understanding how to use the
system, clarity of written materials, and staff attributes can easily be
incorporated into standardized client satisfaction surveys, program/MCO records,
and ongoing focus groups.
Absence of Financial Barriers
Uninsured and publicly insured individuals are overwhelmingly poor and
disenfranchised. Any financial barriers (e.g., copayments) can be a barrier to
access and should be avoided.
Cultural/Ethnic/Gender Sensitivities
Treatment that does not meet the cultural, ethnic, and gender needs of
clients is poor treatment and will result in poor outcomes. Such non-responsive
treatment restricts the access of those with cultural, ethnic, and gender needs.
Adequacy of AOD Treatment Funding and Resources
Quality AOD treatment requires a comprehensive continuum of treatment
services. Many State systems do not support such a continuum, because they lack
the resources, commitment, and/or understanding of the value of AOD treatment
within such a framework. Any managed care initiative should include an analysis
of the AOD treatment continuum and the costs associated with needed expansion.
Such information is vital to inform the planning process.
Numerous factors can influence both directly and indirectly
whether or not an individual obtains and continues to utilize necessary AOD
treatment services (see table 3). When poorly implemented, managed care can
dramatically reduce access to services. When well implemented, it can
substantially increase access to care.
Depending on the structure of the contract, MCOs may have strong financial
incentives to create obstacles or to otherwise restrict care. All too often,
MCOs receive set amounts of dollars which are insufficient to maintain the array
of services needed for supporting stability of the patient. When developing
contracts with MCOs, it is essential (1) to guard against incentives to
undertreat these vulnerable populations, and (2) to build strong incentives to
promote access (Frank 1994; Christianson 1989).
Implementing managed care programs in rural or frontier communities requires
careful planning. Such planning needs to address the unique clinical challenges
of rural America.
The Challenges
In rural America, mental health and AOD treatment services have been
rationed for decades because of poor accessibility and the lack of human and
fiscal resources. Access to quality treatment in rural communities and regions
is often limited by a range of challenges. These include:
- Concerns about confidentiality
- Lack of properly trained providers
- Inadequate support services
- A conservative values orientation
Often, the public mental health system is the only provider in rural
communities.
Several factors contribute to the difficulty of developing an effective
managed care system in rural and frontier States. Poverty and unemployment rates
are generally higher. Public transportation is lacking. A disproportionate
number of populations are at risk for behavioral health disorders.
Additionally, managed care initiatives have primarily happened in more urban
centers, which allow a certain economy of scale. The implications of managed
care for rural areas are less clear.
Guidelines for Developing Services
It is important to develop and analyze a baseline inventory of practitioners
who are providing AOD treatment services. If that inventory identifies
shortages, potential MCO providers can be asked to propose strategies to bring
in or recruit professionals in a Request for Proposal (RFP) process.
Managed competition models based upon competition among independent provider
groups may not be the most effective model for rural areas. It has been
suggested by some that a "managed cooperation model might more effectively
improve access and quality of care." This model would create a rural "Authority"
that would use subsidies and exclusive franchises to achieve goals. The approach
would be flexible, fostering cooperation where needed and competition in areas
where sufficient diversity exists. Initiatives involving cooperation would
facilitate the development of networks. The managed component would improve the
interface between urban and rural areas, coordinate access to tertiary care, and
assist in recruiting needed professionals.
When managed care is implemented in rural settings, it is likely that the
experience of the company and leadership is more urban than rural in its
perspective. It is essential that any implementation in rural areas actively
utilize local professional and client groups in adapting managed care principles
to rural and frontier settings.
Table 3. Factors Influencing Access to
Treatment| Obstacles to Access |
| Factors Promoting Access |
| Not identifying individuals in need of treatment |  | Effective
screening, assessment, AOD training |
| Not reaching
clients in the locations in which they enter the "system" (i.e.,
courts, criminal justice system) |  | Satellite sites,
systematic linkage, training |
| Long waiting
periods for appropriate service |  | Services within
72 hours, depending on severity of clinical need |
| Multiple
steps, places, and people needed to access services |  | Widely available
and simplified intake processes |
| Arbitrary
service limits |  |
Individualized treatment plans |
| Automatic
"fail first" policies (e.g., the client must fail a less intense level
of treatment before a more intense level is made available) |  | Individualized
comprehensive assessment used to guide appropriate placement |
| Geographic inaccessibility |  | Geographically
well distributed sites located on transportation lines |
| Resource-intensie review and appeal procedures |  | Highly
effecient, publicly known utilization review processes |
| Excessive and clinically inappropriate exlusionary
criteria |  | Restricted ability to exclude specified types of hours/day of
operation |
| Cultural, gender, and/or ethnic
insensitivities |  | Priority placed
on cultural competence development |
| Restrictive
copayments |  | Elimination of copayments |
| Unknown, untimely, or non-objective appeals processes |  | Widely known, timely, objective appeals |
| Lack of transportation | | Transportation
available as needed |
| Patient placement criteria
that are nonstandardized, financially driven, and/or subjectively applied |  | Patient
placement criteria that are collaboratively developed, clinically driven,
objective, and standardized |
It is imperative that the managed care industry and the AOD treatment field
develop standard access measures, so that data and findings can be easily
compared. It is impossible to overstate the importance of consistent data and
standardized units of analysis for purchasing, monitoring, and improving care.
Accurately managing these data is critical to determining the success of any
managed care intervention.
The utilization patterns of various treatment services provide a range of
quantifiable measures of access within a managed care system. Also influenced by
the quality and outcomes of treatment, these utilization data are easily
obtained from medical claims encounter data. They allow systematic comparison of
different plans and the ongoing monitoring of overall access.
A review of the literature (Shadle and Christianson 1989; Levin 1993; Mercer
1990, pp. 1-13) suggests that certain measures represent the current state of
the art and should be standardized across the managed care spectrum. These
state-of-the-art measures include the following:
- Potential purchasers should be aware that AOD treatment often cannot
be separated from mental health treatment in MCOs.
- Contracts should ensure that AOD treatment can be analyzed as a
discrete entity or it will be impossible to accurately measure access,
utilization, quality, or other important variables.
- All levels of care should be separately analyzed, with aggregate
totals compiled as needed.
- The utilization rates of clinical subpopulations (e.g. pregnant women,
ethnic minorities) should be capable of being discretely analyzed as separate
entities.
Recommended annual utilization (unduplicated) profile measures (per level of
care) are shown in table 4. Exhibit 1 provides sample contract language
regarding actions MCOs should take to provide access to treatment.
Table 4. Utilization Rates
(Per Level of Care Per Year)
- Admissions per 1,000 covered lives (unduplicated)
- Total days or units per 1,000 covered lives
- Mean length of stay (LOS) or mean number of treatment units
| EXAMPLE | | | | | | | |
| | MCO #1 | | MCO #2 | | 1996 | |
| Admissions/1,000 |
| 25 | | 50 | | ? | |
| Total Days/1,000 | | 150 | | 150 | | ? | |
| Mean LOS | | 6 | | 3 | | ? | |
| Mean Cost/Episode | | $750 |
| $450 | | ? | |
Example: You are a State AOD director and you are comparing the
utilization rates of two MCOs that are competing for a contract. In this
example, MCO #1 historically has half the admission rate of MCO #2. However,
MCO #1 allows its clients to stay in treatment twice as long, resulting in both
MCOs averaging the same amount of treatment days per 1,000 clients. MCO #1 pays
an average of $125/day, while MCO #2 pays an average of $150/day. Using these
data as a starting point, you continue to request outcome data, readmission
rates, customer satisfaction results, and continuing care profiles to inform
your decisionmaking.
Exhibit 1. Sample Contract Language Pertaining to Treatment
Access
The MCO hall regularly report on specified utilization data for all
levels of care, including, but not limited to, the number of enrolled members,
unduplicated admissions per 1,000 covered lives, day/units per 1,000 covered
lives, mean length of stay/number of treatment units, and mean cost per case.
The MCO shall provide emergency, urgent, and nonurgent care within
specified, clinically responsive timeframes. Emergent care should be offered
immediately or within 4 to 6 hours, depending on the situation. Urgent care
should be available within 24 hours. Noncrisis treatment should generally be
available in 1 to 3 days (Zwick and Berman 1992).
The MCO shall develop an outreach plan with specified objectives and
regularly report on its success at reaching those goals.
The MCO shall make and report on systematic efforts to identify, or
encoruage the identification of, beneficiaries with AOD problems and refer them
for evaluation and treatment.
The MCO shall ensure systematic screening for AOD disorders in those
settings most likely to deal with individuals at high risk for AOD problems.
These may include standard screening tools as part of initial contact with the
system, during routine physical exams, at initial prenatal contact, when "trigger
conditions" suggest a high possibility of AOD problems, or when there is
evidence of serious overutilization of medical, surgical, trauma, or emergency
services.
Chapter 3Comprehensiveness of Treatment
Comprehensiveness in the context of alcohol and other drug (AOD) treatment
is a very broad umbrella term that may encompass numerous key aspects of service
delivery. For purposes of this discussion, "comprehensiveness" refers
to the capacity to:
- Provide a full continuum of AOD treatment services
- Base treatment on ongoing bio-psychosocial assessments
- Utilize standardized patient placement criteria (PPC)
- Facilitate appropriate linkages with medical, psychiatric, and/or
social support services
- Meet the cultural, gender, ethnic, and other specialized needs of
those served
- Utilize a network of providers experienced in serving the covered
population
The managed care organization (MCO) shall ensure that enrollees have accessdirectly
or through functional affiliationsto a full continuum of prevention,
treatment, and rehabilitation services. These services include:
- Screening, assessment, diagnosis, intervention, and referral
- Short- and long-term residential treatment services
- Opioid substitution therapies, such as methadone treatment
- Freestanding and outpatient detoxification
- Hospital-based detoxification
When such services do not exist in the community, the MCO shall create these
services.
The need for a full continuum of care is critical. However, continuing care
(often called aftercare) needs to be clearly distinguished from acute, or
initial, care. This distinction is important. Irrespective of the care received
in the initial recovery phases, the extent to which the individual gets periodic
services for the first 6 months to a year after treatment is strongly related to
the probability that the person will continue recovery.
Continuing care services should be widely available and strongly supported
by all MCO systems. Also, there may be value in trying to create a separate
entity of the benefit package, ideally 6 months of weekly outpatient visits,
that cannot be eroded by other services and are available for relapse prevention
on an "as needed" basis (Hoffmann 1993).
Assessment
Standardization of assessment processes is an essential developmental step
that is urgently needed in the AOD treatment field. Such standardization will:
- Improve the overall quality of assessments
- Allow less trained staff to perform adequate assessments
- Provide a consistent data base to compare the effectiveness of
different treatment protocols upon different types of people with AOD problems
Any transition to managed care should include consideration of more
standardized assessments.
The requirement for standardization must be balanced, however, with the
requirement for the flexibility to meet the needs of the particular population
being served. Assessment instruments may necessarily vary across different types
of treatment settings, clinical needs, and geographic situations. However, they
all should contain a core set of State and nationally standardized data
elements. The policies of the MCO should aggressively facilitate such
standardization. In addition, these assessment data should be retrievable for
review as agreed upon by the contract with the MCO.
There are difficult tradeoffs when determining the location, type, and
number of assessment sites. MCOs use a variety of models to assess and triage
individuals into and within the treatment continuum. These may include:
- Assessment and triage capacity at all treatment sites
- Walk-in and call-in access
- Local community-based assessment sites
- Employee assistance program (EAP) triage centers
All models have advantages and disadvantages. In many ways, implementation
is more important than the model. It is important to analyze local needs,
clients served, previous experience, and current patterns of service delivery.
Based on these factors, one can develop the assessment and entry systems that
are most likely to achieve desired goals for a given State, region, or system.
Screening
It has been estimated that 75 to 85 percent of individuals with AOD problems
never receive formal AOD treatment. To achieve middle-term savings
through early identification and intervention, state-of-the-art models of AOD
treatment must provide comprehensive screening for problems throughout the
health and human services system. Ideally, systematic screening for AOD problems
will be available or done in psychiatric settings, correctional settings,
medical settings, and in a broad range of social service settings.
Early intervention and referral to outpatient AOD services should be seen as
a hallmark of quality AOD treatment. Infrequent use of the simple, inexpensive
screening devices that are available for AOD problems leads to insufficient
early case identification. This failure to identify AOD problems early results
in missed treatment opportunities, increased AOD treatment costs at a later
stage, and increased overall medical costs.
Prevention
As the managed care field matures, increasing attention is being focused on
longer term outcomes, demand reduction, and cost savings. A number of
technologies are being increasingly used. These include:
- Other clinical technologies
Many expect that the focus of managed behavioral health care will
substantially move in this direction, especially among systems that are
financially "at risk." These systems will be motivated to become
proactive in reducing the likelihood that clients will subsequently need more
intensive and costly care.
Increasing the capacity of a system to screen for AOD problems is essential
in being able to offer targeted prevention efforts and to intervene earlier in
the course of an individual's substance use disorder.
The sources of referral for individuals with AOD problems is one key
component of any managed care system that needs to be understood. These
referral sources should be systematically monitored as closely as possible.
Common referral sources for the publicly insuredthe courts, child
protection agencies, welfare systemsmust be borne in mind when developing
and monitoring systems.
Although health maintenance organizations (HMOs) and other capitated systems
have economic incentives to promote wellness, the results are mixed. In
situations where managed care is provided through HMOs, physicians are the
source of referral about 40 percent of the time. This is despite the fact that
physicians are often ill trained to screen for and diagnose substance use
disorders. Therefore, physicians should be thoroughly trained in screening
technologies, in conducting brief interventions, and in the use of standard AOD
screening tools (Levin 1993).
As one component of continual improvement activities, the physicians should
also be systematically monitored for their rate of referrals to AOD caregivers
for evaluation and treatment. AOD providers should be monitored for their
response to the referrals in a timely, professional, and collaborative manner.
Contracts with MCOs should emphasize the importance of early identification
and screening of AOD problems, and purchasers of managed care should closely
monitor performance. Many standardized screening tools are available. Brief
intervention techniques (mild clinical interventions that can be provided at a
variety of settings by trained individuals) hold promise for the less severely
impaired. The Center for Substance Abuse Treatment (CSAT) has recently developed
a Treatment Improvement Protocol (TIP) on simple screening instruments for
alcohol and drug abuse and infectious diseases; this TIP is an excellent
resource for States to use when implementing screening systems (CSAT 1994).
Some believe that the short-term financial incentives to cut and/or contain
costs can create a powerful conflict of interest regarding quality care for the
purchasers of managed care. They would prefer to see the governmentpreferably
State alcohol and drug authoritiesestablish criteria on the environment,
intensity, and duration of services. Others believe that this approach would be
too restrictive, too intrusive, and would undermine the capabilities of the MCO
to innovate and improve systems of care. Most would agree that the best case
scenario would be that such criteriaand the implementation of these
criteriabe created and continually refined through an active collaboration
between the MCO, the State financing authority, consumer advocacy groups, and
the State alcohol and drug authority.
A standard set of written patient placement criteria for a State is a
reasonable goal. In this way, the placement process can be more understandable
and acceptable to providers and clients alike. Standardized criteria also help
create a level playing field in which competing MCOs will operate. In a
collaborative system, the standards can be openly discussed and amended as
understanding increases. All gatekeepers should be trained in the use of the PPC
adopted and used in the State.
There are many different routes to follow in implementing statewide patient
placement criteria. Insurance statutes can be used to govern how MCOs determine
AOD benefits. Regulations can be developed to govern eligibility for funds or
licenses. Contracts can be written between providers, MCOs, and/or the State.
The Patient Placement Criteria developed by the American Society of
Addiction Medicine (ASAM) have stimulated much discussion and action in the
field. Many States have adapted these criteria to fit individual State
circumstances. CSAT recently sponsored a Treatment Improvement Protocol (TIP) on
Patient Placement Criteria, which should be available in 1995. A review of these
publications would be helpful for State planners and AOD providers.
Wraparound services are services provided to individuals and families to
enhance, supplement, and support AOD treatment services. They are an essential
adjunct to treatment and are often a key to successful outcomes, although they
are not usually considered treatment services. They are usually notbut can
befunded under AOD treatment benefits. It is imperative that any MCO
managing the care of these beneficiaries ensure effective access to these
wraparound services. Successful linkages to primary care, mental health care,
and social services are essential to coordinated care and positive outcomes.
Most healthcare reform discussions separate social and public health
services from general healthcare services. At the same time, there is a
possibility that some of the dollars spent on treatment-related social services
will be mixed with healthcare dollars and that certain services, such as housing
and transportation, will fall into a financial vacuum. Thus, it may be
important to identify and publicly fund certain wraparound services as separate
from health care and as an MCO's responsibility.
One can divide wraparound services into (1) those that are essential to
access and (2) those that contribute to positive outcomes. At a minimum,
essential wraparound services include child care and transportation.
Wraparound services that contribute to positive outcomes include:
- Screening and referral for HIV disease, tuberculosis (TB), and other
infectious diseases
- Supportive living arrangements
- Domestic violence services
- Liaison services with Immigration and Naturalization services
Often, MCOs rooted in the private sector are not well linked to many of
these wraparound services. The contractor should identify the most salient
services for its population and determine the most effective way to ensure
access. The contractor should also contractually ensure that:
- The MCO provides and covers certain services that have not been
considered traditional healthcare services, such as transportation and child
care, or
- The MCO develops effective linkage mechanisms to these services
In the United States, $1 of every $7 spent on health care is related to
complications of AOD problems. More than 70 medical conditions and diseases are
attributable, in whole or in part, to alcohol abuse. These conditions and
diseases include cancer, cardiovascular disease, trauma, birth complications,
and acquired immunodeficiency syndrome (AIDS) (Merrill et al. 1993).
It is therefore crucial that medical care be closely integrated with AOD
treatment. In behavioral healthcare carveouts, there must be a clearly
established and functionally feasible linkage with primary care services (e.g.,
with adjoining primary care clinics and primary care physicians). In HMOs, there
must be close monitoring of the expertise of the gatekeepers and the
effectiveness of the internal referral systems. In all cases, the primary care
linkage to AOD treatment programs must be considered a priority and must be
systematically measured as well as possible.
In Minnesota, AOD system developers wanted to create financial incentives
for providing clients with efficacious levels of AOD treatment the first time
they enter treatment. The Minnesota system developers found it essential to
insert legislative language that directed decision makers and their
numbers-crunchers and/or actuaries to look at cost offsets in creating these
financial incentives. They incorporated the following language into law as a
factor to be considered when developing a universal standard benefit set:
In developing the universal standard benefits set, the
commissioner shall take into account factors including, but not limited to, cost
savings resulting from the inclusion of healthcare services that will decrease
the utilization of other health care services.
Assuming that this would not be fully understood by the actuaries, they
followed it up by inserting specific actuarial assumptions into the
commissioner's quasi-rulemaking directive to the actuary "for public and
private plans." In Oregon, the medical/surgical capitation rate was reduced
in anticipation of offsets resulting from AOD treatment.
In any given pool of enrollees, there are "special populations"
that require responsive treatment facilities, staff, outreach, and case
management. Such populations include, but are not limited to:
- Womenespecially pregnant women
- People exposed to human immunodeficiency virus
- Those with coexisting AOD and psychiatric disorders ("dually
diagnosed")
- Cultural and ethnic minorities
- People with multiple disabilities
Underserved populations require targeted outreach efforts to assist them in
getting into and staying in care. Contractual financial incentives often
discourage such outreach, and many MCOs are not sufficiently community-based to
provide this outreach effectively. This type of outreach may be best achieved by
a separate party (e.g., the AOD authority). A thoughtful decision must be made
regarding who is best positioned to reach out effectively to these populations.
Incorporating managed care into a publicly funded AOD treatment system will
have a dramatic impact on the providers in that system. Some will adapt quickly
to the new environment and prosper, some will fight to remain viable, and others
will not survive the transition. Mergers, new affiliations, and new system
developments will radically change the service-delivery landscape. The MCOs may
be inclusionary or exclusionary in how they implement systems development.
However, the MCOs should only be able to use licensed facilities.
It is therefore crucial that State AOD authorities do their best to support
the initial inclusion of these existing licensed programs and assist them in
adapting to the new environment. Extensive training may be required to assist
some providers. Information regarding managed care should be systematically
forwarded to them. Trainings and educational forums can be provided or strongly
encouraged. (Note: Appendix C, "Managed Healthcare Organizational Readiness
Guide and Checklist," which is a tool to help analyze a provider's capacity
to function successfully in a managed care environment, can be used by both
programs and State systems to identify their strengths and weaknesses.)
Needed consultative or technical assistance services can be arranged.
Strategic planning processesboth at the system and provider levelscan
be implemented. Within the limits of resource capabilities, State AOD
authorities should provide leadership in designing and implementing strategies
that will enable publicly funded AOD providers to participate successfully in
the managed care system.
"Any Willing Provider"
Many States are now adopting or considering "any willing provider"
legislation in an attempt to lessen the exclusionary power of MCOs. This type of
legislationmandating that all providers who are willing to meet specified
standards and accept a given rate will not be excluded from a managed care
networkis highly controversial. Fundamentally, the advantage of such
legislation is that it can prevent a provider or group of providers from being
formally excluded from a managed care network. The disadvantage is that it can
substantially restrict the capacity of an MCO to accomplish clinical goals and
that de facto exclusion could still probably occur. State AOD
authorities must examine the individual circumstances of their particular State
to decide whether or not to support such initiatives.
Essential Community Providers
The financial and societal consequences of undetected, untreated, or
inadequately treated AOD problems are enormous. During a transition to managed
care, it is essential to the public safety, welfare, and economy of a State that
the treatment offered to the uninsured or publicly insured populations not be
dramatically reduced or made less available. Measures must be implemented to
ease the inevitable problems of such a transition and to ensure that the
provider systems in place are not abandoned in a wholesale and reckless manner.
Many MCOs are not highly experienced in treating addictions among the type
of clientele that is characteristic of publicly funded programs. For this
reason, many believe that new systems should encourage the initial inclusion of
the local, publicly funded AOD treatment programs that have been serving this
population. Traditionally, these publicly funded programs have operated for
years with insufficient funding. They are at a distinct disadvantage relative to
providers who have been funded in the private sector for treating the commercial
population.
However, these publicly funded providers offer major strengths and
advantages. These providers have:
- Developed strong community linkages with key supportive services
- Demonstrated sensitivity and commitment to the needs of the publicly
insured individual
- Demonstrated that they are capable of being, by necessity, highly
cost-efficient in the delivery of clinical services
The loss or functional exclusion of such services in the name of reform
would represent a substantial step backwards in attempting to meet the needs of
the publicly insured population.
As healthcare delivery systems are transformed, planners need to be creative
in combining the community-based strengths of the publicly funded system with
the technical and managerial strengths of the managed care industry. One way to
facilitate a successful transition to managed carewhile still protecting
the public goodis to encourage contractually the inclusion of
community-based providers as "essential community providers" for a
designated transitional period.
Exhibit 2 provides sample contract language relating to the
comprehensiveness of treatment.
Exhibit 2. Sample Contract
Language Pertaining to Comprehensiveness of TreatmentIndividualized CareThe MCO shall
support the delivery of individualized care with a comprehensive continuum of
services that provide the most appropriate intensity of care in a cost-effective
manner.
Full Continuum of Services
The MCO shall ensure that enrollees have accessdirectly or through
functional affiliationsto a full continuum of prevention, treatment, and
rehabilitation services. These services include prevention; screening,
assessment, diagnosis, intervention and referral; outpatient counseling;
psychiatric services; structured day treatment; short- and long-term residential
treatment services; opioid substitution therapies, such as methadone treatment;
freestanding and outpatient detoxification; hospital-based detoxification; and
case management services. When such services do not exist in the community, the
MCO shall create these services.
Assessment
The MCO shall base treatment on a comprehensive biopsychosocial assessment.
The
MCO shall utilize a core of retrievable standard data elements in all
assessments. Assessment instruments shall be approved by the State AOD authority
and shall be consistent with specified patient placement criteria.
ScreeningThe
MCO shall ensure that effective screening is conducted for AOD problems and
shall facilitate the development of new community-based treatment settings in
areas with the highest rate of problems.
PreventionThe
MCO shall provide members with contractor-specified prevention and education
programs on AOD use; these programs shall have a special focus on risk factors
for AOD problems and on specified vulnerable populations.
Standardized
Patient Placement Criteria (PPC)The MCO shall use
standardized admission, continuing care, and discharge criteria that are
consistent with emerging national clinical norms to guide decisionmaking
regarding the appropriate intensity of care (e.g., ASAM/ASAM- modeled criteria).
The
MCO shall ensure that its policies, practices, and procedures encourage strong
linkages with appropriate specified supplementary and supportive services,
agencies, and organizations. Performance will be monitored systematically, using
contractor-specified performance measures.
The MCO shall
operate a structured case management program that includes a process to identify
complex cases at all levels of care. Specialized or dedicated case management
staff shall proactively coordinate care and follow client progress through the
continuum of care. Patient placement criteria shall be developed by the State
AOD authority and utilized by the MCO to assure consistency and openness
regarding placement decisions.
Outreach
The MCO shall ensure that the unique needs of specified populations are
identified and met in a clinically appropriate manner.
The
MCO shall provide, or contract for when necessary, specialty AOD care when
clinically appropriate and legitimately unavailable within the MCO's range of
services.
The MCO shall develop processes of outreach to
contractor-identified special populations at risk for AOD use disorders who may
have difficulty accessing care.
The MCO shall actively
collaborate with the courts to place appropriately those clients who are
diverted into treatment.
The MCO shall develop criteria to
ensure that chemically dependent individuals have access to cost-effective
treatment options that address their specific needs. These include, but are not
limited to, the need for: treatment that takes into account severity of illness
and comorbidities; provision of a continuum of care from primary inpatient to
outpatient care, aftercare, and long-term care; the safety of the individual's
domestic and community environment; gender-appropriate and culturally
appropriate programs; and access to appropriate social services.
Wraparound
Services
The MCO shall ensure that providers develop affiliation agreements and
policies that support smooth, clinically sound transitions of recipients from
one service environment to another.
The MCO shall ensure that
all clients are provided with documented access to a core set of
contractor-specified wraparound services which are then individualized according
to client need.
The MCO shall regularly report on (1) its
efforts to expand and refine systemic relationships with contractor-specified
wraparound services; and (2) measurable success in ensuring client entry into
specified wraparound services.
The MCO shall provide,
measure, and regularly demonstrate effective linkages for its enrolled
population among a broad range of contractor-specified primary care and public
health services. |
Chapter 4Financial Considerations
Fee-for-service reimbursement is a system in which payment is based on
actual services rendered. Until recent years, this system has been the mainstay
of most reimbursement for privately funded alcohol and other drug (AOD)
treatment services. However, fee-for-service reimbursement has inherent
incentivesboth financial and clinicalto overutilize services and to
overtreat clients. Because every additional unit of service generates additional
revenue, there is little incentive to monitor treatment more tightly or to lower
costs. The result can often be waste and inefficiency.
Most individuals who work in the AOD treatment field want to provide quality
care to those whom they treat. To the degree that financial incentives strongly
encourage both
high quality and cost-efficient treatment, most provider systems
will deliver treatment that is good for clients, for taxpayers, and for health
care in general. Effective reimbursement systems attempt to tap these good
intentions.
Capitation is a method of reimbursement in which a fixed sum of money is
paid per enrollee by the purchaser to the provider. This sum of money is
expected to cover specified services for every enrollee for a defined period of
time. Capitation agreements attempt to create a system in which those delivering
care are financially motivated to deliver the highest quality care and to
achieve the best outcomes in the most clinically and cost-efficient way
possible.
A shift in the financing of behavioral health care toward capitation models
is rapidly evolving. This represents a major policy shift from retrospective to
prospective reimbursement systems. Payment is gradually moving away from
fee-for-service and toward risk-based paymentseither per case fees or
capitation payments. Often, these risk-based payments are linked to performance
on specified measures (Oss 1992, 1993).
The essential components of a capitation contract include:
- Prepaid care to cover all clinical and administrative costs
- A contracted provider who is at full or partial risk
- Financial incentives to manage care wisely
- Payments tied to a specific risk pool
- Increased emphasis on outcomes rather than on amount or level of
treatment
Capitation creates clear financial incentives to minimize hospital use
through the development of a comprehensive continuum of treatment services. This
continuum of services has the advantage of facilitating the treating and
maintenance of enrollees within their community, where they will receive ongoing
support for recovery (Christianson 1989). Capitation requires establishing clear
performance criteria in such areas as accessibility, treatment appropriateness,
customer satisfaction, individual outcomes, and outcomes for the enrolled
population as a whole. Capitation thus focuses attention on the achievement of
specified results rather than on the mechanisms of process.
Capitation engenders strong emotions for those in the field. Christianson
(1989) summarized the polarization around the issue when he wrote, "Proponents
of capitated financing foresee cost savings and better integration of a
relatively fragmented service delivery system. Skeptics fear that capitated
arrangements will lead to access barriers, the channeling of patients to
inappropriate providers, and cost-shifting."
Most agree that capitated reimbursement models can, if implemented properly,
create increased clinical accountability for individual and aggregate outcomes.
This level of clinical accountability cannot easily be duplicated in a
fee-for-service environment. Fiscal and clinical incentives encourage the
capitated party to consider all available options for meeting client needs in
the most efficacious way. These fiscal and clinical incentives can foster
innovation by encouraging the use of treatment settings that are not
traditionally purchased in fee-for-service financing (Dangerfield and Beitt
1993).
However, depending on the nature of financial incentives built into the
contract, capitation can create strong short-term incentives to underprovide
care as a cost-cutting measure. Monitors of a capitated system must therefore
develop an expanded set of concerns, skills, and systems to maintain the
integrity of the treatment system and to ensure appropriate access to treatment
(Schaller et al. 1986). In many situations, the State AOD authority is well
positioned to be such a monitor.
Risk management refers to a health care organization's desire to minimize
the financial risk of delivering services in a capitated system. The financial
risk may be borne by the provider, by the managed care organization (MCO), or by
the entity that is purchasing the managed care service, or the risk may be
shared in agreed-upon ways. Adverse selectionhaving an unfair and
disproportionate number of expensive-to-treat enrolleesis avoided whenever
possible. Management of this risk is a key challenge in most managed care
systems.
In any pool of enrollees, there will be subgroups who utilize treatment
services differently. Some groups will be more expensive to manage and some will
be less expensive. It is essential to understand the clinical and treatment
characteristics of the populations served. For example, in the behavioral health
field, it has been estimated that 40 percent of all mental health/AOD
expenditures are made on behalf of just 2 percent of the population (Frank
1994). In most cases, this is related to individuals with severe mental health
problems who have AOD problems that exacerbate the condition.
When provider organizations compete to attract enrollees in capitated
systems of care, there are strong financial incentives to limit, discourage, or
disenroll those individuals who can be expected to incur higher costs. Providers
who attract a disproportionate share (i.e., adverse selection) of such persons
face serious financial risk unless they are protected by some form of adjustable
capitation payment, shared risk, or stop-loss mechanisms. Reinsurance or other "stop
loss" provisions are ways to protect against unforeseen costs. Providers
under such an arrangement are protected from financial loss beyond a certain
predetermined level (Mechanic 1993).
The benefit description (i.e., what treatment services must be available in
the plan) needs to be clearly defined. Any capitation payment must be
substantial enough to support delivery of these defined services. If there are
services that fall outside of the domain of the MCO, certain requirements will
be needed. These include:
- A mechanism must be provided for the client to receive these services.
- Some assurances are needed that there will be timely access to these
services.
- Assurances are needed that these services will be coordinated with
the MCO.
Capitated health care systems must incorporate effective checks and balances
to ensure that short-term incentives to undertreat do not overwhelm the longer
term incentives. For positive outcomes, checks and balances are critical because
they support longer term goalsto build quality services and improve
overall health status. To offset short-term incentives to undertreat, important
balances include (1) sufficient funding for the services required, (2) clear
performance indicators, and (3) longer contracts (e.g., 25 years) that
increase the incentive for MCOs to seek longer term positive outcomes.
Before the advent of managed care, financial exposure was limited by such
means as placing maximum individual limits on the amount, duration, and/or type
of treatment. Such limits are largely unnecessary in a managed care environment.
However, use of such limits still prevails, despite the fact that they can
result in denials of treatment that are clinically unsound and financially
counterproductive.
The contracting agency makes the final determination regarding the benefit
package that the MCO must implement. Depending on the situation, the MCO may or
may not be able to influence this decision significantly. Thus, service coverage
within a managed care system may include a number of benefit limitations that
need careful examination. These benefit limitations may include:
- Restrictions on the number of available hospital days or ambulatory
visits
- Copayments, deductibles, or other enrollee-paid fees
- Supplemental benefits available only for an additional monthly charge
- Mandatory periods of time (e.g., 90 days) between treatment episodes
- Limitation of sufficient resources (e.g., facilities and/or personnel)
- Annual or lifetime payment limitations
- Arbitrary "fail first" policies
In developing or evaluating the terms of a managed care contract, it is
imperative that the benefit package be closely examined. Attempts should be made
to minimize or eliminate any arbitrary limits of care that are not well grounded
in clinical practice.
Cost-shifting occurs when the care of a particular condition is "shifted"
inappropriately to another treatment facility, State agency, or other entity.
Cost-shifting is a common problem in any systems development. It is imperative
that developers aggressively consider how to minimize incentives for shifting
costs. What incentives will there be for the MCO to transfer care (and therefore
cost) to other State agencies? How will care and responsibility for individuals
be determined between the MCO and other agencies? What kind of interagency
agreements should be developed to guide these decisions? How will possible cost
shifts between the MCO and medical services be monitored?
With today's healthcare reform of publicly supported clients, many MCOs are
now placed in the position of becoming the provider of services to the indigent
(i.e., the provider of last resort). There are no other resources or providers
to whom MCOs can shift costs. State AOD agencies need to consider contract
benefits and responsibilities from this perspective.
In any capitated situation, it is essential to understand the case mix
(i.e., the clinical characteristics) of the pool of enrollees and to determine
the likely per-person cost of treating each group. Actuarial companies are
companies that specialize in analyzing past utilization data for specified
groups and then, using assumptions when necessary, estimating likely future
costs for treating each group.
There is considerable "art" in the science of actuarial
prediction. Good actuarial work needs to be thoroughly attuned to the real
world, so that any assumptions are grounded in logic and represent the field as
it is currently practiced. Actuarial analysis is only as good as its sources,
and therefore depends on the quality of the historic cost data, the accuracy of
the demographic data, and on the validity of its assumptions.
An actuarial analysis is the basic tool used by insurance firms to determine
how much to charge for a policy that would pay for a defined benefit package.
State agencies need to estimate how much the State should expect to pay for the
services it proposes to contract through a managed care firm. States employ
actuaries to prepare such analyses. The final analysis combines a variety of
estimates, calculations, and assumptions as the basis for computing the cost per
covered person per month, the "PMPM" (per member per month).
Whenever possible, actuarial analysts will base estimates on concrete data
and, when necessary, will make assumptions to compensate for missing,
incomplete, or inaccurate data. During negotiations, actuaries will usually tend
to estimate conservatively and err on the side of a high PMPM. In order to
stretch limited funds, it is usually in the interest of the State purchaser and
the State AOD authority to lower the PMPM to the lowest level that can still
support a quality care system.
In working with actuaries, it is thus very important to provide them with
appropriate assumptions. To the extent possible, one should try early in the
discussion to define what assumptions the actuaries are actually using. Model
building for PMPM should accompany or precede actuarial analysis. Such model
building will force explication of what the payer wants, in what volume, and for
what populations.
The importance of providing assumptions for the actuaries cannot be
emphasized enough. Experience in healthcare reform at the State level has shown
that battles about benefit packages ultimately end up in actuarial wars between
competing sets of numbers. These competing numbers are used by opponents as
reasons to reduce benefits for appropriate and cost-effective services.
It is important to understand the actuarial process and to question
aggressively the actuaries who establish the capitation rates. The critical
question is whether the rates being proposed are sufficient to guard against
undertreatment. If the capitation rate is insufficient, undertreatment of
substance abuse problems will result.
During the actuarial process, it is important for decision makers and
actuaries to be knowledgeable about the many cost offsets related to AOD
treatment. This knowledge can be a driving force for creating financial
incentives to provide efficacious levels of treatment.
Overall actuarial studies should be tailored to the options that the State
is considering for controlling costs (C. Hansen, Washington State Division of
Alcohol and Substance Abuse, personal communication, 1994).
Chapter 5Consumer Protections
The relatively recent emergence of behavioral healthcare companies has
resulted in this type of health care being largely unregulated by both States
and the Federal government. Although States and the Federal government regulate
health maintenance organizations (HMOs), health insurers, and alcohol and other
drug (AOD) treatment providers, few such regulations govern the activities of
managed care firms. While many firms act in good faith and provide quality
services to those served, some do not and thereby damage the overall reputation
of the industry.
In the absence of such regulation, several problems have occurred at
different times in the implementing of managed care programs. These include:
- Failure to have adequate staff with specific skills and training in
AOD diagnosis and referral
- Failure to use acknowledged AOD patient placement criteria
- The use of financial arrangements that create incentives to undertreat
- Inadequate grievance procedures
- Inadequate emergency procedures
- Incomplete coverage for approvals in the evenings and weekends
- Inappropriate shifting of costs to public funding sources
Without consumer protections in place, this combination of factors can
potentially lead to inadequate and sometimes dangerous care. In response to
this, the Model Managed Care Consumer Protection Act was established to provide
reasonable protections to consumers. It sets a standard that allows responsible
managed care firms to continue to carry out their functions, but creates
much-needed consumer protections for those firms whose policies or fiscal
incentives can lead to less than adequate care (President's Commission on Model
State Drug Laws 1993, pp. D75-D95; D. Gates, Pennsylvania Health Law Project,
personal communication, March 1994).
The following are some key consumer protection areas that should be
incorporated into a contract with a managed care entity. Exhibit 3 provides
sample contract language pertaining to consumer protection.
Openness of Systems
MCOs differ substantially regarding how available, specific, and/or valid
their patient placement criteria are to providers and enrollees. Public access
and input to these processes can lead to improved quality, accountability, and
provider/consumer relations.
Out-of-Plan Services
It is important that enrollees have reasonable access to appropriate
treatment services. Systems need to be set in place to ensure this access if
providers cannot, at a given time, offer these services within the formal
system.
Consumer-Friendly Materials
Written information from MCOs is sometimes difficult to obtain and
challenging to read. It is essential that all necessary materials be readily
available and be written in clear and simple language(s).
Disenrollment Protections
The extent to which services are covered and the amount of that coverage
vary greatly. Limits on coverage can include maximum number of days, number of
visits, or dollar amounts.
MCOs often have incentives to disenroll or to encourage disenrollment of
individuals perceived as expensive or difficult to treat. Additionally, in
highly competitive markets, MCOs sometimes use dubious procedures as they
compete for enrollment.
In general, contracts should make disenrollment by the provider or MCO very
difficult. This can be done by requiring that the provider or MCO take multiple
and monitored steps in disenrollment, while making disenrollment by the consumer
a relatively easy, single-step process (Boyer 1993; President's Commission on
Model State Drug Laws 1993). All disenrollments should be documented and
reviewed by the financing agency and/or the State AOD authority.
Appeals
Legitimate differences of opinion regarding the clinically appropriate
level, length, or intensity of care for a given problem are inevitable. Every
MCO must have a user-friendly vehicle for handling appeals and grievances.
The training, experience, qualifications, and overall sensitivity of "gatekeepers"
is crucial when addressing the needs of individuals with AOD problems.
Gatekeeping is a central component within the managed care environment. MCOs
should be required to provide ongoing training of gatekeepers.
The MCO should be able to demonstrate knowledge of all relevant
Federal/State laws and governing provisions regarding AOD treatment. Such
relevant laws and regulations include the Americans with Disabilities Act and
confidentiality regulations.
Exhibit 3. Sample Contract Language Pertaining to Consumer
Protection| Openness
of Systems | Appeals |
| The MCO shall
use and disclose the patient placement criteria (e.g., ASAM) used by clinicians,
make other contractor-specified information publicly available, an regularly
elicit formal comment from involved agencies and enrollees. | The MCO, the contractor, or both will establish an efficient
grievance procedure to handle complaints and grievances which cannot be resolved
in the internal process. The MCO shall ensure that internal appeal and
grievance processes are widely known, easy to use, timely, and not overly
demanding of provider and enrollee resources. A mechanism will be in place for
an AOD-credentialed, nonfinancially involved third party (e.g., State authority)
to hear grievances that cannot be resolved at the MCO level. Enrolled
individuals will have direct access to this third party as needed (e.g., an 800
line). |
| The
MCO shall systematically meet with other specified organizations (e.g., State
agencies, healthcare organizations, provider organizations, and consumer groups)
to maximize the integration of necessary care across organizational boundaries. |
The MCO shall develop a system to track and report on the
frequency and severity of client complaints and grievances by region, provider,
service type, and resolution of problem. |
| The MCO, or the
contractor of the MCO, shall establish a community advisory board composed of
carefully selected representatives (e.g., consumers, providers, relevant
agencies, people in recovery, public health and mental health providers, and
criminal justice representatives) who regularly meet with the MCO to monitor and
suggest policy evolution. | Staffing
and Gatekeeping |
| The
MCO shall clearly inform all enrollees of any functional limitation in benefits
or care. | The MCO shall ensure that
all reviewers, other staff, or subcontractors involved in the determination of
care shall be clearly qualifiedby virtue of specified training,
experience, and/or certificationto make informed decision regarding
clinically appropriate AOD treatment. |
| Out-of-Plan
Services | Utilization review decisions
will be clinically based on "best practice" and consistent with
emerging national patient placement standards (e.g., ASAM criteria). |
| The MCO will ensure that enrollees have reasonable
geographic access to all appropriate services in the benefit package. Services
may be delivered by a nonparticipating provider when not available in the
enrollee's area from a participating provider or when the enrollee is out of the
area. | Clinical decisionmaking will not be
subject to any arrangements which create direct financial incentives for an
individual staff person to deny or reduce care or create any conflict of
interest. |
| Consumer-Friendly
Materials | The MCO will ensure that
admission to different levels and types of service is individually determined
and based on teh clinical judgments of qualified AOD treatment professionals |
| The MCO will ensure that consumers are provided with
all necessary materials to utilize the system effectively and that these
materials are written in clear and simple language(s). | The
MCO shall work with the State authority and other MCOs to develop a common or
core set of patient placement criteria. |
| Disenrollement
Protections | |
| The
MCO shall not disenroll consumers based on previous claims, change class or
premium status based on claims, or use any incentives to d |