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Integrated Behavioral Health Care - Funding Module 6 W. Patrick Sullivan, PhD Indiana University Learning Objectives 1. To describe key provisions in the PPACA and how they impact the effort to integrate care 2. Discuss how the PPACA hopes to expand health insurance and ensure access to care for all citizens 3. Discuss fiscal barriers to integrated care as well as fiscal mechanisms that encourage integration 4. Explore different reimbursement models that undergird health care and the implications for how services are delivered 5. Explore how these initiatives impact social work practice Disproportionate Cost Burden • • • Over half of all Medicaid beneficiaries with disabilities are diagnosed with mental illness For those with chronic conditions health care costs are as much as 75% higher for those with a mental illness – with the rates for those with a co-occurring substance use disorder resulting in a two to three fold cost increase Among those eligible for both Medicaid and Medicare 44% have 1 mental health diagnosis 20% have more than 1 mental health diagnosis1 (Integrated Care Resource Center, 2011, p. 1). Barriers to Reimbursement for Integrated Care2 1. 2. 3. 4. 5. 6. 7. State Medicaid limitations on payments for same-day billing for physical health and a mental health service visit/service Lack of reimbursement for collaborative care and case management related to mental health services Absence of reimbursement for services provided by non-physicians, alternative practitioners, and contract practitioners Medicaid disallowance of reimbursement when primary care practitioners submit bills listing only a mental health diagnosis and corresponding treatment Level of reimbursement rates in rural and urban areas (case mix issues, telemedicine, care coordination) Difficulties in getting reimbursements for mental health services in school-based health center settings Lack of reimbursement incentives for screening and providing preventative mental health services in primary setting PPACA: Expanding Coverage3 By 2014 all individuals under the age of 65 who have incomes below 133% federal poverty level will be eligible – of the projected newly eligible 17.5% are estimated to have a mental illness or substance use disorder Those who do not qualify for Medicaid will have access to insurance through the State Exchanges PPACA: Health Insurance Exchanges • Provides an opportunity for low to middle income persons and small businesses to purchase health insurance • Available to those up to 400% of Federal Poverty Level • Exchanges are designed to help consumers determine their eligibility for the exchange – screening process also informs those who are eligible for Medicaid, CHIP or other plans • Plans must offer the Essential Health Benefits • If States fail to establish exchanges on Jan 1 2014 the federal government will operate the exchange PPACA: Parity • • • Parity in the essential benefit package Prohibitions from capping annual and lifetime benefits for mental use and substance use disorders treatment at levels below physical health care Behavioral health benefits are essential services in state exchanges – mental disorders and substance use disorder services and are considered essential services in Medicaid “benchmark” expansions Health Insurance Exchange Plans Plans must offer the Essential Health Benefits • There are four levels with plans paying covered costs at Bronze (60%), Silver (70%), Gold (80%) and Platinum (90%) • The “premium assistance credit” is a refundable tax credit for those who purchase through the exchange - This is based on income -- IRS pays the pays the premium assistance credit amount directly to the insurance plan. • The benefit package and overall plans available will determine the degree to which this aspect of the ACA will forward the goals of Integrated care PPACA: Medicaid Expansion4 • If states opt into expansion – from 2014 to 2016 Federal government will finance 100% of those who become eligible due to expansion and by 2020 this drops to 90% • At present 49 of 66 million Medicaid beneficiaries are enrolled in some form of managed care • Estimates suggest that if health care reform is fully executed including expansion– by 2019 an additional 3.7 million people facing severe mental illness will gain coverage • Among those without serious disorders 27.6 will gain coverage Medicaid Participation5 • In a recent survey – Medicaid participation rates (the percentage of those who are eligible who enroll) was estimated at 62.6% • State variation ranging from 43% (Arkansas) to 82.8% (Massachusetts) • Participation higher among disabled adults (75.8%) and lowest among “childless” adults 38.3% - and “category of eligibility” is seen as the strongest predictor of take up rates Participation Factors • More generous benefits in state plans – including preventive dental care and other optional services • Increasing provider reimbursement • Increases in recipient cost sharing results in lower rates • As an interaction effect the above may increase the odds that an individual may interact with providers who will facilitate, rather than discourage, enrollment PPACA: Mechanisms to Integrate Care 1. Medical Homes - builds on primary care, the chronic care model, patient-centered care and health information technology • For those with serious behavioral health challenges – a Behavioral Health Organization can become the primary medical home 2. Accountable Care Organizations: In general for those enrolled in Medicare • • Groups of providers who form collaborative agreements to share responsibility, improve quality and control costs There is great potential for behavioral health to be key players in ACO’s depending on contractual details, risk-sharing obligations and opportunities, and reimbursement mechanisms. PPACA: Medicare6 • • • • • Goal to slow growth in Medicare costs through improvements in care An ACO “assumes responsibility for a clearly defined population of Medicare beneficiaries, attributed to it on the basis of their patterns of primary care” One key feature if ACO’s is shared savings – requiring the provision of high quality care and “reducing cost below what would have been expected” But similar to provisions in Medicare – recipients have the opportunity to opt out. The opportunity for shared savings will be a factor in an ACO’s willingness to assume risk ACO Structure • • • • • ACO’s must include primary care providers who cover at least 5000 Medicare beneficiaries Have a formal legal structure Possess a leadership and management structure that includes clinical and administrative systems Provide data on cost and quality and other items requested by CMS Accept principles of evidence-based medicine, “patient” engagement, and “patient centeredness” Shared Savings 1. 2. 3. 4. Stakeholders including providers and payers must work together to identify targets that reduce cost and reduce variations in order to ensure quality care Evaluate objectively and together if targets were met and measure savings All should share success (financial) that provides equitable rewards to stakeholders and avoids “perverse incentives” (i.e. rewarding volume over quality for example) Engage in the process of continued monitoring to ensure quality of care is improved Questions to Ponder How can the cost of providing care be reduced while still meeting quality standards? What role might social workers play in the effort to reduce costs while enhancing quality? What traditional social work roles fit well within an ACO framework? Could social work play a prominent role in an ACO framework? Why? Mechanisms to reduce cost and accrue savings 1. Successful prevention activities – including promoting healthy lifestyle choices, preventative care, screening and early detection 2. Reduction in the overall “quantity” of services used 3. Substitution of less intensive and less expensive services for intense expensive care – i.e. reduction in use of the emergency room for non-emergencies and inpatient hospitalization 4. Less reliance on specialty ancillary services and greater emphasis on natural community supports 5. Effective use of group modalities – including peer supports 6. Use of alternative delivery methods include telemedicine Social Work in a “shared savings” environment • Case and care management, traditional social work roles may be emphasized in accountable care and other “at risk” delivery models • Social work has great experience in working with those facing the greatest challenges including those with significant physical, mental, and developmental challenges that can be costly to serve in medical settings • Social work emphasis on tapping community resources and natural supports can lead to effective and less costly care PPACA: Increased Funding for Integrated Care Increased reimbursement for primary care: Regardless of a fee-for-service arrangement or within a managed care plan – reimbursement for primary care is slated to increase by half Co-location of services: Additional grants are available for co-location of primary and specialty care in behavioral health settings PPACA: Services for Co-Occurring Disorders Home and community-based services for those with cooccurring disorders. • Services can include: vocational support, case management, peer support • These services can be offered as a part of a regular state Medicaid program (to people with incomes up to 300% of maximum SSI payment and high need • Or through a waiver granted by HHS PPACA: Infrastructure Supports • • • Community-based Collaborative Care Network Program: The development of a collaborative consortium of providers to coordinate and integrate services Federal Coordinated Care Office: Designed to help those who are dually eligible for Medicaid and Medicare and will attempt to reduce fragmentation and the navigation challenges people face trying to work in both systems. Workforce Development: The ACA sets aside funds to support training programs on medical homes, team management of chronic illness, and integration of physical health and behavioral health care Options for Integrating Care • Leverage existing delivery system or build new capacity • Have Managed Care Organizations or Behavioral Health Organizations take the lead in integration efforts • Develop a single integrated system or multiple, specialized systems of care for subsets of beneficiaries Components of Integrated Care • Aligned financial incentives across physical and behavioral health systems • Real-time information sharing across systems to ensure that relevant information is available to all members of a care team • Interprofessional care teams that are accountable for coordinating the full range of medical, behavioral, and long term support services as needed • Competent provider networks • Mechanisms for assessing and rewarding high quality care Managed Care Organizations7 In places where the normal plan has been to carve out behavioral health care, states must contract with entity prepared to offer integrated care – or the MCO can subcontract for behavioral health services However: agreements must be secured for onsite services - and same day billing for physical and behavioral health care must be allowed. MCO: Pros & Cons Pros: • Administrative systems are integrated and data needed for care management is accessible • Seamless system for beneficiaries • Clinical integration is possible Cons: • Subcontracts may thwart true integration • Clinical capacity to recognize and provide effective services for behavioral health issue may be lacking • Special MCO’s for those with serious and persistent mental illnesses may be needed Primary Care Case Management • Does not require the use of a MCO – the integration initiative can be achieved via: • • • • Offering enhanced fees to primary care entities to support care/case management Support development of community – based care teams to “extend the reach of primary care.”8 Support health information technology for information exchange, population management, performance measurement Develop other incentives to integrate care • Pros: Can build on existing systems – including fee-for-service models • Cons: Infrastructure may be difficult to build – implementation may be difficult Behavioral Health Organization • Here the organizations have expertise with those with significant behavioral health challenges - this moves toward the idea of a Patient-Centered Medical Home where a BHO is the designated home • Pros – all those we observed with standard MCO’s with the exception that these organizations have a greater capacity to serve this special population • Cons – little experience using this arrangement to date MCO/PCCM/BHO Partnership • Partnership facilitated by financial alignment • • • • • Develop shared saving models In capitated environment this can be accomplished in a prospective payment plan Fee for service requires that shared savings are calculated Performance incentives This can maintain current BHO carve-outs which may remain the most viable plan for the serving those facing serious mental illnesses Pros & Cons • Pros: Risk can be shared widely Shared administrative costs and functions Can facilitate shared record keeping and the development of a client registry • Cons: Separate systems remain Shared saving difficult to calculate Controlling costs may trump providing appropriate care Reimbursement Issues • • • • • Same day visit billing barriers • Under Medicaid law, states may charge for same-day medical and mental health visits, with matching dollars provided, however, states do not take advantage of this opportunity Historically many states have implemented primary care case management programs that limit a beneficiaries free choice of provider There is considerable confusion about billing for ICM services with no clear guidelines States will decide the qualified providers eligible to receive ICM payments States will decide if reimbursement is for a set of activities (what a provider “does”), practice characteristics (what a provider “is”) or improvements in practice behavior (how the provider performs) Aligning Fiscal Incentives • • • • • Create incentive payments for providers who demonstrate improved performance on quality and cost measures Reimbursing providers on a per-member-per-month based on care coordination Quality incentive programs calculated as a percentage of program savings which can be shared directly with providers or provider networks as “shared savings” States plans may need to seek approval or a “waiver” to test some of these new initiatives – particularly when choice is restricted and benefit plans are altered States can also set payments on a stratified basis distinguishing low to high case management needs Billing for Integrated Care • Proper use of Health and Behavioral Assessment Billing Codes and modification of same can be used to properly to advance integrated care • Ensure codes include assessment activities, education, and cognitive and behavioral, and services geared toward health and illness management, i.e.,diet, exercise, smoking cessation • Include codes for group interventions – and even educational and instruction (relaxation training, medication management) to family with and without identified client present Reimbursement Continuum Fee for Service Full Risk Capitation There a wide range if reimbursement models in health care. These models determine what services are reimbursable and those that are not, have implications for professional autonomy, and in many ways support or hinder the integration of care. In a simplified world – the continuum ranges from the traditional fee-for-service model on one end – and full risk capitation on the other. In Fee for Service • Each discrete reimbursable service is billed separately • There can be a built in incentive to provide more services – and the most expensive services • In contrast, services that the consumer need may be more costly that the rate of reimbursement – creating a disincentive for use Fee for Service cont…. • When specialty providers are used, the mechanism to integrate care from basic communication to shared information may be lacking due to a lack of a system or a designated gatekeeper • This model offers maximum autonomy to professionals within the fiscal parameters of the primary source of funding At the other end of the continuum…. Full Risk Capitation • Providers are paid a set rate per person prospectively (often per person per month) to provide the necessary services for a member • When the provider spends less than the prospective payment rate they profit – if they exceed the cap they lose (hence the term “at risk”) Full Risk Capitation cont….. • By remaining unfettered from a fee-for service framework that determines what services are reimbursable this model allows for flexibility in the range of services offered • Because fiscal risk is involved, care and case management become key services, preventative services are emphasized, and disease management and chronic care approaches can be useful Full Risk Capitation cont… • Because providers are at risk there may be an incentive to avoid high risk and expensive clients • There is an incentive to reduce the use of intensive and expensive services (i.e. hospitalization) even if such services are truly necessary • Because of the business model issues like prior authorization and concurrent review puts clinical decisions in the hands of non-clinicians – thus reducing professional autonomy Key Questions When considering the various models offered above and they key premises of each – what are some pros and cons of these service delivery mechanisms for the individual client, professional, and society? What ethical dilemmas may be posed in the effort to reduced costs while enhancing quality – and how does one balance the two concerns? Should efforts be made to extend care to every citizen? Is Reform Going to Happen? • Given the timeline, challenges, and political environment the final product can take many forms • Given that Medicaid is a federal-state program how states will respond to various expansion initiatives remains to be seen – based on Supreme Court Decision on Individual Mandate, States can opt of the expansion • Optional programs may be difficult to launch in current economic environment – and those most important to service integration may be in the greatest peril Key Challenges • • • • Demand for behavioral health care services will increase The number of available professionals may be inadequate Benchmark coverage under expansion only requires that coverage is comparable to private insurance therefore, some optional services that may be central to the care of people with chronic conditions may not be covered Exchange programs may not work to enroll people with chronic conditions References 1. 2. 3. 4. 5. 6. 7. 8. Integrated Care Resource Center (2011, October). State Options for Integrating Physical and Behavioral Health Care, p. 1-12. Mauch, D., Kautz, C., & Smith, S. (2008, Feb). Reimbursement of mental health services in primary care setting. Rockville, MD:SAMHSA Croft, B., & Parish, S. (2012, Feb.) Care integration in the Patient Protection and Affordable Care Act: Implications for Behavioral Health. Administration and Policy in Mental Health and Mental Health Services Research. Iglehart, J. (2011). Desperately seeking savings: States shift more Medicaid enrollees to managed care. Health Affarirs, 30(9), 1627-1629 Sommers, B., Tomasi, M., Swartz, K., & Epstein, A., (2012). Reasons for the wide variation in Medicaid participation rates among states hold lessons for coverage expansion in 2014. Health Affairs, 31(5), 909919. Berwick, D. (2011). Launching accountable care organizations – the proposed rule for Medicare shared saving program. The New England Journal of Medicine, 364(e32), 1-4. Hamblin, A., Verdier, J., & Au, M. (2011, October). State options for Integrating Physical and Behavioral Health Care. Integrated Care Resource Center. Technical Assistance Brief, 1-12. Hamblin, A, Somers, S., Neese-Todd, S., and Mahadevan, R. (2011, January). Medicaid and Criminal Justice: The Need for Cross-System Collaboration Post Health Care Reform. Exploring Health Reform and Criminal Justice: Rethinking the Connection between Jails and Community Health, Issue Paper.