Transcript Document
HIV Care Under the Affordable Care Act Addressing the Needs of HIV Clinics and Clinicians in Florida May 2015 Julia Hidalgo, ScD, MSW, MPH Research Professor, George Washington University and CEO, Positive Outcomes, Inc. [email protected] Today We Will Address Key provisions of the Patient Protection and Affordable Care Act (ACA) Federal and State Medicaid policies Provider participation and covered benefit provisions Eligibility, service delivery, and payment systems Focus on challenges and opportunities for Florida HIV clinical, social support, and prevention providers Maximizing third party reimbursement for HIV prevention, care, and support services through collaborative strategies ACA Marketplace From: Hidalgo J and Edelbrock E. Commercial Health Insurance Basics for HIV Prevention Programs Webinar. ETR and University of Washington, Oct 2014. http://www.etr.org/CIS/webinars/webinar-3-commercial-health-insurance-basics-for-hiv-prevention-programs/ US Census: Majority of Americans 19-64 Years Are Enrolled in Commercial Insurance Private Public Uninsured 70% 60% 50% 40% 30% 20% 10% 0% 19-25 26-34 35-44 Age Group 45-64 ACA Requirements: Essential Health Benefits (EHBs) Ambulatory patient services Hospitalization Emergency services Pregnancy, maternity, newborn care, and pediatric services (oral and vision care) Mental health and substance abuse disorder services (i.e., behavioral health treatment) Prescription drugs Rehab and habilitative services and devices Laboratory services Preventive and wellness services and chronic disease management ACA Requirements: Essential Community Providers (ECPs) ECP Category ECP Provider Type Federally Qualified Health Centers (FQHCs) FQHCs and other community health centers, and healthcare facilities operated by Indian tribes and other Indian organizations RWHAP Provider Ryan White HIV/AIDS Program-funded providers Family Planning Provider Title X family planning clinics and look alike family planning clinics Indian Health Provider Indian Health Service (HIS) providers, Indian tribes organizations, and urban organizations Hospital Disproportionate share hospitals (DSH) and eligible hospitals, children’s hospitals, sole community hospitals, and other similar facilities Other ECP Providers STD clinics, TB clinics, and other entities that serve predominantly low-income, medically underserved individuals ACA Requirements: ECPs CMS issued a letter to Federally-Facilitated Marketplaces in December 2014 QHPs must contract with at least 30% of ECPs in each QHP’s service area Offer contracts in good faith to all available Indian health providers in the service area Offer contracts in good faith to at least one ECP in each ECP category in each county in the service area Where an ECP in that category is available and provides medical or dental services that are covered by the issuer plan type (i.e., Individual or SHOP) To be in “good faith,” a contract should offer terms that a willing, similarlysituated, non-ECP provider would accept or has accepted Issuers must be able to provide verification of such offers if CMS chooses to review the offers for compliance ACA Requirements: Preventive Services DHHS US Preventive Services Task Force (USPSTF) recommends “A” grade for HIV infection screening Adolescents and adults ages 15 - 65 years Younger adolescents and older adults at increased risk All pregnant women, including those presenting in labor who are untested and whose HIV status is unknown “A” grade for syphilis for all pregnant women and other persons at increased risk for infection “B” grade for chlamydia screening for sexually active women age 24 or younger and in older women at increased risk for infection “B” grade for STD counseling for sexually active adolescents and for adults at increased risk for STDs ACA Marketplace Lessons Learned in 2014 Lack of health insurance “literacy” is a significant issue, with the need to educate clients about Share of cost: Co-pays, co-insurance, deductibles, premiums Newly insured individuals may be unaware of providers’ collection policies, resulting in high debt for unpaid medical bills Selection of primary providers, specialty referral requirements, prior authorization, and medical necessity Network adequacy: primary care physicians, specialists Health plan care management strategies present serious barriers to care for HIV+ individuals Florida Marketplace Individual Plans On-Exchange Off-Exchange Only Small Group Plans On-Exchange Off-Exchange Only Carriers Premium Increase 2014 2015 11 14 13.5% 6 7 0.0% Carriers Premium Increase 2014 2015 5 6 11.4% 15 13 5.7% Florida QHPs Sold On and Off the Federally-Facilitated Marketplace Carriers Aetna Health Inc. Aetna Life Insurance Company All Savers Insurance Company AvMed, Inc. Blue Cross Blue Shield of FL Cigna Health and Life Insurance Company Coventry Health and Life Insurance Company Coventry Health Care of FL, Inc. Coventry Health Plan of FL, Inc. FL Health Care Plan, Inc. Freedom Life Insurance Company of America Health First Health Plans, Inc. Health First Insurance, Inc. Health Options, Inc. Humana Health Insurance Company Humana Health Insurance Company of FL, Inc. Humana Medical Plan, Inc. John Alden Life Insurance Company Molina Healthcare of FL, Inc. Neighborhood Partnership, Inc. Preferred Medical Plan, Inc. Sunshine State Health Plan Time Insurance Company UnitedHealthCare Life Insurance Company UnitedHealthCare of FL, Inc. Individual On-Market Off-Market SHOP On-Market Off-Market Impact of the ACA on State Medicaid Programs From: Hidalgo J and Edelbrock E. Medicaid Basics for HIV Prevention Program. ETR and University of Washington, Oct 2014. http://www.etr.org/CIS/webinars/webinar-2-medicaid-basics-for-hiv-prevention-programs/ Medicaid Overview Federal and state entitlement program Medical assistance for people with limited income and resources Covers 60 million adults and children Enrollment in “traditional” Medicaid is commonly via TANF, Aged, Blind, Disabled or other Categorical Programs Supplements Medicare benefits for 9 million low income aged and/or disabled individuals Beginning in 2014, the ACA permitted states to expand Medicaid optionally to non-disabled individuals Disability continues to be a common pathway to Medicaid and Medicare for HIV+ adults Anyone who is poor (include < $16,104 or 138% of the FPL) 4.8 million Americans enrolled in expanded Medicaid In FL, Medicaid is operated by the FL Agency for Health Care Agency (ACHA) Until ACA Medicaid expansion implementation, FL HIV+ adults commonly enroll in Medicaid through enrollment in Social Security Administration (SSA) disability or TANF benefits. In FL, applications for SSA disability benefits are determined by the FL DOH Division of Disability Determinations. SSA Initial Allowance Rates in FL, By Month, October 2000 to March 2015 ACA-Related Medicaid Benefits NON-EXPANSION STATES Can voluntarily cover EHBs under their traditional Medicaid benefit packages Coverage of preventive services in traditional Medicaid benefit packages is optional Some groups, such as the disabled, dual eligible, and medically frail individuals, are exempt from enrollment in ABPs and may choose to obtain traditional Medicaid services New Opportunities for Medicaid Payment for Preventive Services CMS published a final rule effective in January 2014 Before the rule change: preventive services could only be provided by a physician or other licensed practitioner (OLPs) of the healing arts to be paid by Medicaid After the rule change: other practitioners, not just physicians and OLPs, can be paid to provide preventive services recommended by a physician or OLP Assigns authority to State Medicaid Programs to Define practitioner qualifications Ensure appropriate services are provided by qualified practitioners Define the preventive services to be provided Design the reimbursement methods Does not define the type of personnel to be covered FL Statewide Medicaid Managed Care (SMMC) Recipient Eligibility Assistance categories that enroll in a Managed Care Plan (MCP) Temporary Assistance to Needy Families (TANF) SSI (Aged, Blind, and Disabled) Hospice Institutional Care Medicaid (MEDS) - Sixth Omnibus Budget Reconciliation Act (SOBRA) for children born after September 30, 1983 (age 18 to 19) MEDS AD (SOBRA) for aged and disabled Protected Medicaid (aged and disabled) Full-Benefit Dual Eligibles (Medicare and Medicaid -FFS) Full-Benefit Dual Eligibles enrolled in Part C – Medicare Advantage Plans that are not fully liable for all Medicaid services FL Assertive Community Treatment Team (FACT Team) FL Statewide Medicaid Managed Care (SMMC) Recipient Eligibility Recipients who may ENROLL VOLUNTARILY include Recipients who have other creditable health care coverage, excluding Medicare Persons eligible for refugee assistance Residents of a developmental disability center Enrollees in the developmental disabilities home and community based services waiver or Medicaid recipients waiting for waiver services Children receiving services in a prescribed pediatric extended care center Residents of a group home facility licensed under Chapter 393 FL Statewide Medicaid Managed Care (SMMC) Recipient Eligibility The following recipients INELIGIBLE to enroll Women who are eligible only for family planning services or through the breast and cervical cancer services program Persons who are eligible for emergency Medicaid for aliens Dual eligible recipients whose Medicaid benefits are limited (partial duals) Qualified Medicare Beneficiaries (QMBs), Specified Low-Income Medicare Beneficiaries (SLMBs), and Qualifying Individuals Medically needy recipients will not experience a change in benefits at the time that they meet their share of cost and will continue to receive services through Medicaid fee-for-service (FFS) Home and Community-Based Services (HCBS) Waiver programs are subject to a federal transition requirement, with the transition plan comment period recently closed Medicaid Managed Medical Assistance Specialty Plans Child Welfare Specialty Plan Children’s Medical Services Network Plan HIV/AIDS Special Plans Serious Mental Illness Specialty Plan Freedom Health Special Plans for Dual Eligible Recipients Recipients Eligible for More Than One Specialty Plan A ranking system determines specialty plan assignment The recipient is automatically assigned to the special plan highest in the ranking Ranking includes A recipient can still chose from any other MMA specialty plan if he/she is eligible for any other standard plan in their region Child welfare specialty plan Children’s Medical Services Network plan HIV/AIDS specialty plans SMI specialty plan Freedom Health specialty plans for dual eligibility recipients (i.e., individuals enrolled in Medicare and Medicaid) In applying this ranking system, HIV+ recipients with SMI are assigned to an HIV/AIDS specialty plan, but can alternatively select an SMI specialty plan FL SMMC Standard and Specialty MCPs STANDARD PLANS Amerigroup Better Health Coventry Humana Integral Molina Preferred Medical Prestige SFCCN (South FL Community Care Network) Simply Staywell Sunshine UnitedHealthCare SPECIALTY PLANS Children’s Medical Services (CMS)- Children With Chronic Conditions Clear Health Alliance- HIV/AIDS (Simply Healthcare Plans, Inc.) Freedom Health- Duals Chronic Conditions Magellan Complete Care- SMI Positive Health Care FL- HIV/AIDS (AIDS Healthcare Foundation) Sunshine Health Plan- Child Welfare 1 2 3 FL Region 4 5 6 7 8 9 10 11 1 2 3 4 5 6 7 8 9 10 11 FL SMMC HIV/AIDS Specialty Plan Requirements Specialized provider education, and HIV Specialist PCP criteria (including CME) Provider responsibility for HIV primary and secondary prevention activities and risk reduction education Provision of care in accordance with the most recent clinical practice guidelines for HIV/AIDS treatment Treatment adherence services available from the Specialty Plan Required use of approved assessment tools for behavioral health and substance abuse Specialist Case Management policies and procedures including provider’s role in the Specialty Plan’s MCM/care coordination services Referral to services, including services outside of the Specialty Plan’s covered services and services provided through interagency agreements Quality measurement standards for providers Exchange of data Extensive requirements regarding care management, including linkage with community HIV, other support services, RWHAP, and PAC Waiver Opportunities for HIV Core Medical, Support, and Prevention Providers in the ACA and Medicaid Reform Addressing Health Insurers’ Interests Via Services Offered by HIV Providers Health Insurers’ Interests Services That HIV Providers Might Offer Identify enrolled members that do not obtain preventive or other services Essential covered benefits Outreach, linkage, patient navigation RWHAP core medical providers Address members’ healthcare and health insurance literacy needs Prevent communicable diseases including HIV, STDs, TB, and HCV Non-MCM, patient navigation, health education nPEP and PrEP support, HIV/STD CTS, behavioral prevention, condom distribution and education, HERR Translation and health education Address members’ linguistic and numeracy needs to ensure that they can participate actively in health promotion, prevention, and care Culturally competent care coordination, disease Culturally competent workers with management, treatment education expertise in serving racial, ethnic, and sexual minority populations Addressing Health Insurers’ Interests Via Services Offered by HIV Providers Services That HIV Providers Might Offer Ensure access to physical, behavioral, MCM, navigation, behavioral and other outpatient services to promote health tx support, medical health, and prevent and treat disease transportation Ensure HIV+ clients receive and optimally MCM, navigation, tx education benefit from ARVs and other medications and adherence counseling, MCM Coordinate services provided by the care MCM team with the client, his/her family, and community resources Disease management MCM Discharge planning and readmission MCM prevention interventions for hospitalized patients Health Insurers’ Interests ACA Essential, RWHAP, and CDC-Covered Services ACA Essential Covered Benefits RWHAP Service Categories Ambulatory patient services Hospitalization Emergency services Pregnancy, maternity, newborn care Pediatric services Mental health (MH) services Substance abuse (SA) disorder services Prescription drugs OAMC, hospice care Rehab & habilitative services & devices Laboratory services Oral health services (peds)* Preventive & wellness services & chronic disease management Home health care, HCBHS CDC HIV High Impact Services OAMC visits for PrEP & PEP OAMC OAMC MH services, hospice care Outpt SA tx services, residential SA tx OAMC, ADAP, LAPA OAMC, EIS, lab tests Oral health services OAMC, MCM, EIS, HERR, tx adherence counseling HIV biomedical prevention: meds for PrEP & nPEP HIV & STD testing HIV test counseling, HIV behavioral prevention, HERR, PrEP and nPEP tx adherence, prevention case management Non-Essential ACA, RWHAP, and CDC-Covered Services RWHAP Service Categories ACA Non-essential Covered Benefits Medical nutrition therapy Medical transportation services Linguistic services Outreach services Rehabilitation services CDC HIV High Impact Services Outreach & linkage services Align With Your Organization Before Seeking New Opportunities Before moving forward, it is critical to Ensure your HIV program’s efforts are aligned with your organization’s overarching readiness efforts An important step for HIV practices in large integrated health systems, hospital-based or university-affiliated health systems, local health departments, large FQHCs Contracts may have been negotiated or are being negotiated QHP and Medicaid MCO contracts have probably been finalized for the current year Engage organizational leadership, including corporate board support Identify organizational resources that can be applied to your contracting and collaboration activities Medicaid Independent Contracting Model HospitalBased HIV Clinic MCO FQHCs CBOs Health Dept Collaborative Integration Strategies QHP or MCO Contract for services using “grant” type budget, FFS, sub-capitated arrangements Augment care management services provided by the insurer through contract Contract with provider networks to provide HIV and HIV services Hospital Provide subcontracted essential and other covered services Systems Coordinate and collaborate to serve HIV+ and non-HIV+ clients Subcontract with CBOs and handle their billing FQHCs & HIV Clinics CBOs Provide subcontracted essential and other covered services Coordinate and collaborate to serve HIV+ and non-HIV+ clients Subcontract with CBOs and handle their billing Provide subcontracted outreach, HIV and STD testing, linkage, home visits, MCM, preventive services On Our Own Virtual Integration Physical Integration Acquisitions & Mergers • Chart your own organizational course • Enhance your TPR capacity, join insurers’ FFS programs and networks • Crush the competition • Adopt a “trade association” model • Collaborate in information gathering, purchasing, and marketing • ASOs seek out and create formal relationships with HIV clinics, community health centers, or other core providers • Co-locate services but remain independent organizations • Share infrastructure costs • Identify agencies with services strengthening your capacity and “buy them” • Identify similar agencies but different service areas or populations and merge • Transfer clients to a fiscally solvent, culturally competent, and high quality agency close HIV program Integrated Healthcare Facilities and Community-Based Organization (CBOs) Contracting Model Medicaid FFS MCO Hospitals FQHCs Hospitals FQHCs CBOs CBOs CBOs CBOs QHP Integrated Public Health Department and CBO Contracting Model State and County HDs Public HealthFunded HIV/STD Surveillance CBOs How to Learn More About ACA and MedicaidRelated Health Insurers in My State