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HomeMy WebLinkAboutMINUTES - 09141993 - 1.15 (2) 1 . 150 TO: BOARD OF SUPERVISORS Contra �r. FROM: Phil Batchelor, County Administrator Costa Count9 a 40 September 14 , 1993 rJs DATE: �q co�: SUBJECT: COMMENTS ON THE . STATE'S MAINSTREAM PLAN ENROLLMENT LEVELS DURING THE TRANSITION PERIOD UNDER THE MEDI-CAL MANAGED CARE EXPANSION PLAN SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION RECOMMENDATION: APPROVE and AUTHORIZE the Chairman to send a letter to the State Department of Health Services commenting on the State' s proposed mainstream maximum enrollment levels during the transition period under the Medi-Cal managed care expansion plan. BACKGROUND: The State Department of Health Services recently released its plan for expanding Medi-Cal managed care and described the Department' s intent to limit expansion of Medi-Cal managed care during the two- year period before the implementation of the two-plan model described in the State' s plan. This limited expansion was intended to protect safety net and traditional providers from accelerated enrollment of Medi-Cal beneficiaries into managed care plans during the planning and development period of the two-plan model in each designated region. On May 14 , 1993, the State Department of Health Services filed emergency regulations concerning prepaid health plan and primary care case management contracts in designated regions . One element of the regulations concerns the minimum beneficiary enrollment level for each plan operating under the two-plan model in each region and the maximum beneficiary enrollment level of the mainstream plan in each designated region. The regulations also CONTINUED ON ATTACHMENT: YES SIGNATURE: �i�J��l /Sf// RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE v APPROVE OTHER' SIGNATURE(S): (/�/ZJ�(�C�/I�+LF` /► C+/{� e`r` L�+�C ACTION OF BOARD ON September 14 , 1993 APPROVED AS RECOMMENDEDOTHER VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE UNANIMOUS(ABSENT ) AND CORRECT COPY OF AN ACTION TAKEN AYES:�� •�1 NOES: AND ENTERED ON THE MINUTES OF THE BOARD ABSENT: ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN. SEP 14 1993 ATTESTED Contact: PHIL BATCHELOR,CLERK OF THE BOARD OF M County Administrator SUPERVISORS AND COUNTY ADMINISTRATOR Health Services Director Executive Director, Contra Costa Health Plan BY DEPUTY -2- establish the requirement that the Department redetermine the maximum enrollment limits every two years and describe the process for local government input on the mainstream plan maximum enrollment levels . The regulations also describe how the maximum enrollment levels will affect existing prepaid health plan, like this County' s Contra Costa Health Plan, and primary care case management: plan contracts . Counties have: been given until September 15, 1993 to comment on proposed mainstream maximum enrollment levels during the transition period. The Health Services Director has prepared the attached comments, which are actually more in the nature of questions which the State needs to answer in order for County staff to better understand the impact of these proposed maximum enrollment levels on the Contra Costa Health Plan. It is, therefore recommended that the Board of Supervisors approve these comments and authorize the Chairman to forward them to the State Department of Health Services within the September 15, 1993 deadline. 0 The Board of SupervisorsContra Phil Batchelor Clerk of the Board and County Administration BuildingCOSta County Administrator 651 Pine St., Room 106' (510)646-2371 Martinez, California 94553 County Tom Powers,1st District Jeff Smith,2nd District E SE L Gayle Bishop,3rd District �•=" ....•4. Sunne Wright McPeak 4th District � Tom Todakson,5th District v. 4 ,om C,'• L . .pTA C011t1'r't . 7 September 14, 1993 Joseph Kelly, Chief Managed Care Programs Branch State Department of Health Services 714 P Street, Room 1400 Sacramento, CA 95814 Dear Mr. Kelly: The Contra Costa County Boarcl of Supervisors appreciates the opportunity to comment on the proposed mainstream plan enrollment levels as detailed in your letter of July 15, 1993 . In reviewing the document, the Board of Supervisors has several questions and concerns which we request the State to address : 1. During this transition period, will the Contra Costa Health Plan (CCHP) , our County's local initiative Knox- Keene licensed, federally qualified HMO, be allowed to expand its current PHP contract limit beyond the proposed maximum enrollment of 23,294 for existing PHP' s in Contra Costa County? In order to convert current fee-for-service Medi-Cal users of the County health care system to managed care, CCHP' s contract limit needs to be increased above the current contract level of 13,640 for AFDC-linked and MIC eligibles to at least 25,000. 2 . We are concerned about the possibility that the State is allowing new PHP's to be established in Contra Costa County during the transition period. It appears that the State has encouraged a potential Mainstream Plan to -2- develop a new PHP in our County. We understand that the contract limit for this new PHP will exceed its CAHMO agreement commitment. It is equally disturbing that this new PHP' s contract limit, when combined with the contract limit of an existing PHP (Kaiser) will exceed the State Plan' s maximum enrollment limit for Mainstream Plans . 3 . The statement in the description of Mainstream Plan Enrollment limits that "beneficiary choice under the two- plan model will determine the enrollment levels of the mainstream plan and the local initiative" is confusing as it relates to maximum enrollment which we previously understood to be an upper limit that could not be exceeded. We do not understand what will happen if the mainstream plan reaches its maximum enrollment. Will the mainstream plan be closed to new enrollees until turnover reduces its enrollment below the maximum levels? Will the mainstream plan always be "open" to new members (and how is this consistent with a maximum enrollment level? ) or is the State assuming a residual fee-for-service system? From an operations planning standpoint it is crucial for us to know what options will be available so we can implement the necessary support systems . 4 . If the mainstream plan is always open to the entire Medi- Cal managed care population, how does this two-plan model protect DSH payments? The State's Plan for Expanding Medi-Cal Managed Care states that a governing policy for managed care expansion is to "support the safety net/maintain disproportionate share hospital (DHS) funding. " Yet we do not understand exactly how the DHS funding will be protected if there is no upper limit on the mainstream plan maximum enrollment. How does the State plan to protect DHS payments if the mainstream plan' s enrollment reduces the safety net hospitals ' patient days? We would appreciate clarification of this very important point. 5 . If, as called for in your draft emergency regulations , mainstream plans are required to contract with DHS hospitals to protect the DHS payments, exactly how will the State guarantee that the mainstream plans make reasonable reimbursements to those safety net hospitals? Will the California Medical Assistance Commission continue to negotiate the State's Selective Provider Contracting Program? If so, will the DHS hospitals be reimbursed by the mainstream plan at these contract rates? Furthermore, we understand that reasonable and adequate reimbursement is guaranteed by CFR 447 . 250 (a) , the Federal regulations implementing the Boren Amendment . -3- Can you provide us with assurances as to how the State will define "reasonable and adequate"? 6 . We are concerned that the HMO industry has publicly opposed any requirement to contract with safety net providers. In testimony regarding the two-plan model regulations, the California Association of HMO's stated, 11CAHMO firmly and adamantly opposes any requirement that _health plans must utilize specific providers identified by the State. " Thus, the State and HMO industry appear not to be in total agreement on how best to protect safety net providers . And, as the major safety net provider in Contra Costa County, we don't understand how your maximum enrollment proposal implements your own stated policies to fully support safety net/DHS hospital funding. 7 . Prior to any implementation, we believe it would be most helpful to all parties to have a public discussion on these issues and will recommend that the proper legislative committees promptly hold special interim hearings on the State Plan's effect on DHS payments and safety net providers. We will be separately communicating this request to our State Legislative Delegation. 8. According to the State" s timetable, the County will be asked to sign a Local Initiative Development contract this fall. Since we need to have sufficient time to review the contract before we can go on to the next phases of our Local Initiative planning, we request that you give us a copy of the contract document before we send the letter of intent now scheduled for September 30, 1993 . 9 . Finally, we do have some concerns with the methodology you used to determine the mainstream plan maximum enrollment levels. We question whether the most current data was used in calculating DHS days. We also urge that you take well baby and administrative days into account when calculating enrollment levels . The Contra Costa County Board of Supervisors reiterates its intent to develop a local initiative and our staff is working with all interests in our community including beneficiaries and traditional providers to ensure that expanded Medi-Cal managed care is a reality in our County. But until we receive your written assurances on exactly how safety net providers such as our County -4- system of care will be protected and until we can review the development contract, we are reluctant to commit fully to the proposals put forth in the State Plan, emergency regulations, and the July 15, 1993 communication. Therefore, we request an extension of the September 30, 1993 deadline for submitting a letter of intent. Very truly yours, TOM TORLAKSON CHAIRMAN cc; The Honorable Daniel E. Boatwright Senator - 7th District Room 3086, State Capitol Sacramento, CA 95814 The Honorable Nicholas C. Petris Senator - 9th District Room 5080, State Capitol Sacramento, CA 95814 The Honorable Robert J. Campbell Assemblyman - 11th District Room 2163, State Capitol Sacramento, CA 95814 The Honorable Tom Bates Assemblyman - 14th District Room 446, State Capitol Sacramento, CA 95814 The Honorable Richard K. Rainey Assemblyman - 15th District Room 4015, State Capitol Sacramento, CA 95814 The Honorable Burt Margolin, Chair Assembly Health Committee Room 4112, State Capitol Sacramento, CA. 95814 The Honorable Diane E. Watson, Chair Senate Health & Welfare Committee Room 2191, State Capitol Sacramento, CA 95814 Theresa Parker, Undersecretary State Health & Welfare Agency 1600 9th Street Sacramento, CA 95814 Kimberly S. Belshe' State Health & Welfare Agency 1600 9th Street Sacramento, CA 95814 John Rodriguez Jose Fernandez