HCPF produced a document for JBC hearing January 2021. Several items of concern to COMBINE were addressed.
Overall HCPF continues to obscure the role of RAEs in managing behavioral healthcare. Anthem, Colorado Access, and United Healthcare are not mentioned a single time. No representative asks about RAE statistics, network adequacy, or other items related to behavioral healthcare workforce, including reimbursement. There is no discussion of the 20% cut to Anthem Medicaid providers a year ago and how that impacted the workforce.
Regarding public notice of benefits:
page 14 "3. For the FY 2020-21 hearing process, the Department was asked to respond to the following questions related to public awareness campaigns. Is the Department spending money on public awareness campaigns? If so, please describe these campaigns, the goal of the messaging, the cost of the campaign, and distinguish between paid media and earned media. Further, please describe any metrics regarding effectiveness and whether the Department is working with other state or federal departments to coordinate the campaign? Please provide an update to your response from last year, including any changes to existing campaigns and/or the addition or discontinuation of campaigns.
RESPONSE The Department was not appropriated money for public awareness campaigns last year. We have used existing staff resources thus far to communicate Medicaid benefits and covered services to members during the COVID-19 public health emergency and anticipate needs for significant communications in partnership with CDPHE next year to ensure public health messaging on vaccines reaches members and providers. The Department has leveraged channels other than paid media such as issuing public statements and working with stakeholders – providers, Connect for Health, advocates, counties, etc. - to message to Coloradans about (a) safety measures during the pandemic such as wearing masks, social distancing, washing hands, celebrating holidays safely with household members only; and, (b) to increase awareness of our program to help Coloradans stay covered during this economic downturn. Neither of these efforts generated additional costs for the state.
Regarding "the cliff". At the end of the Public Health Emergency (PHE) due to COVID, hundreds of thousands of Coloradans will lose Medicaid and need to purchase health insurance from the ACA marketplace. This is a continuity of care issue as our Medicaid clients will, in some cases, lose access to the providers they have been working with.
Response is on and near page 27.
"Reviewing 300,000 members or more is an enormous task, insurmountable for already over-taxed eligibility workers. Despite the fact that the Department has provided tips, shortcuts, and locked-in files by county to help streamline this work, Colorado counties do not have the capacity to handle this increase in workload without additional staff or overtime. In order to minimize the impact on members, as well as the counties who process eligibility, the Department is requesting supplemental funding to support the eligibility reviews of the locked-in population.
Regarding public "Buy-In" for Medicaid, page 92
Medicaid "buy-in", with an income based adjusted premium ($200/month maximum), is currently reserved for adults and children with disabilities and stands as a route toward greater access and greater coverage at affordable prices. "...the Department stands ready to respond to health care policy or operational directives from the General Assembly to further meet the access, affordability or coverage needs of Coloradans during this economic downturn or in the future, including Medicaid Buy-In or other evolving solutions.
On page 80 HCPF asserts their reduction of nursing home wage adjustment from 3% to 2% is supported with a mention of parity. COMBINE believes "parity" is used here in a manner inconsistent with MHPAEA. This continues HCPF's use of the word "parity" when it suits their purpose, and also shows HCPF understands that reimbursement is a parity issue. "The Department developed the R-16 request independent of the pandemic in order to achieve parity across provider reimbursement methodologies. The purpose of this component of R-16 is to rationalize provider payment methodologies. Section 25.5-6-202, C.R.S. outlines a comprehensive methodology for the Department to set nursing facility rates. This methodology requires the Department to annually adjust nursing facility rates based on changes in provider costs. As a result, the state’s reimbursement for nursing facilities historically increased by approximately 3.00% each year – i.e., by an amount generally equal to the statutory cap. Last session, the Joint Budget Committee introduced HB 20-1362, which limited the annual increase in the Department-paid per diem rates to nursing facilities to 2.00% for FY 2020-21 and FY 2021-22.
Additionally, HCPF misleads the JBC, stating that other providers' rate revisions are determined by the General Assembly, when, in fact, the RAEs have total control over rate setting. "No other long-term care provider in the Medicaid program receives automatic rate increases, and other than nursing facilities, no other providers in the Medicaid program receive automatic rate increases as a result of state law. Other providers that receive automatic increases, such as pharmacies, receive these increases because of requirements in federal law. Revisions to rates for other providers are subject to annual appropriation by the General Assembly.
Page 63, Rep. McCluskie asks about rate setting. What follows is a discourse on MPRRAC that is irrelevant to rate setting for behavioral healthcare, which is mostly managed by RAEs. Page 65 outlines a rate setting regime and implies that rates are set across the board using these ideas. However, there is no mention that RAEs may disregard this guidance and set rates however they see fit.
Page 42 discusses support for medical education. This is a parity issue. Education means more providers and therefor more access to treatment. If access to treatment ('treatment limitations') happen because of policy, that policy must be similar for behavioral health.
Colorado Newsline's Moe Clark reports on Colorado's Audit Committee's recommendations and how HCPF has outstanding items not addressed.
JBC (Joint Budget Committee) document includes review of audit items and are addressed on page 7 and elsewhere.
"In reference to the outstanding audit recommendations identified in the Office of the State Auditor’s “2020 Annual Report of Audit Recommendations Not Fully Implemented,” the Department has 14 recommendations that are considered high priority."