HCPF Proposed Policy

The law (SB23-174)

Tue, May 17, 2022, 3:37 PM

Thanks for reaching out. The statewide Medicaid eConsult platform will not include behavioral health as part of its specialty services, however we are hopeful that we will be able to explore and potentially provide this service at a later date.

Please continue to send us your feedback and any questions that come up overtime.

Thanks and have a great afternoon,

eConsult Development Team

from the eConsult system, which allows PHI (protected health information) to be communicated between primary care physicians and specialists.  CMS stated that care coordination between medical providers and mental health providers increases quality of care and decreases overall health care spending. 

COMBINE alerted HCPF to this Parity concern in 2022.

Since 2019, COMBINE has advocated for more oversight of the Medicaid mental health care managers, the "RAEs", who are actually Anthem, United Healthcare, and Access Management (Colorado Access)

The Legislative Audit Committee controls the work of the Office of State Auditors, who are empowered to audit state departments and agencies. For the OSA to audit RAEs, they need additional power.  

This letter is signed by dozens of clinic operators. 

Kimberly M. Muhlebruch, Clinical & Executive Supervisor, SOBT Therapy, LLC; Centennial discusses necessity for supervision of early career therapists in diverse workplaces. 

"I am worried, no terrified, that they will decide to implement this new rule and that small businesses like my veteran owned counseling practice will be shut down."

"The report:

●  Meets neither the letter nor the spirit of the law, which was, to contract with an independent auditor to both review and remedy the inequitable payment models existing currently,

●  ignores the impact these inequitable rates impose on the workforce at Centers,

●  maintains a vague and incomplete narrative about the rate setting process,

●  obfuscates the corporate capture of the state’s $1 billion Medicaid mental healthcare system,

●  minimizes the work of the IPN and ignores the cost of that work,

●  does not discuss MHPAEA Parity concepts relating to rates,

●  minimizes the rate differences,

●  does not provide context for important statistics,

●  does not offer adequate recommendations to remedy the enormous payment variation,

●  offers “value based payments” as the remedy to rate differences, and

●  confuses the workforce, the public, and the legislators.

This "BEHAVIORAL HEALTH PROVIDER RATE COMPARISON REPORT" was mandated by legislation, with the purpose of explaining why independent providers are paid 1/5 of the rate that Community Mental Health Centers are paid for the same 55 minute outpatient psychotherapy sessions.  The report was produced by "independent auditors, CBIZ Optumas (DBA Optumas; formerly Schramm Health Partners LLC) and Myers and Stauffer." 

COMBINE forms a 501c4 Trade Association (COMBINE Action), increases dues, and reports over 150 members. 

Board Chair Yakitta Renfroe

Board Members: Carlos Villafan, Faith Halverson Ramos, Lexi Ellis, Andy Rose

claimed to be “woke” or in need of being a “white savior” or misunderstanding the trauma related to police brutality and the fear of being a population that no one cared about. It is microaggressions such as those statements that either pushed the BIPOC population away from therapy or encouraged them to have a louder voice to advocate for someone that knew them on a level that they did not have to explain."

Response to HCPF's answers to the Joint Budget Committee where we see the pattern of obscuring the RAEs and their policies.

COMBINE engaged with Colorado Access because they were prohibiting pre-licensure work by supervised candidates and university interns, contrary to the other RAE's policies. Colorado Access was only allowing supervised service where there's a facility license, which was a substantial barrier to entry.