HomeMy WebLinkAboutMINUTES - 09141993 - 1.15 (2) 1 . 150
TO: BOARD OF SUPERVISORS Contra
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FROM: Phil Batchelor, County Administrator
Costa
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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
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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
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Gayle Bishop,3rd District �•=" ....•4.
Sunne Wright McPeak 4th District �
Tom Todakson,5th District
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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
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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 .
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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
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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