Wednesday, February 10, 2010

NC DHHS Medicaid Waiver Plan: Trojan Horse?---and what are its dimensions?

There's serious stuff cooking re: these Medicaid waivers as per the Jan, 2010 NC DHHS implementation memo: see here:

Which LME's will be chosen? Why will they be chosen? Will smaller providers be hounded out of business?

There is a legitimate place for small or solo providers. I see people in their homes in rural western NC and there is no public transportation outside of Asheville, NC.

Here is the kernel of the Medicaid wavier matter as per that implementation memo:

"Medicaid Waiver Amendment Submission

The North Carolina Department of Health and Human Services (DHHS) announced in the December Medicaid Bulletin and in Communication Bulletin #106 that DHHS is requesting approval from the Centers for Medicare and Medicaid Services
(CMS) for a mental health, developmental disabilities and substance abuse service waiver program.

The Waiver Technical Amendment was submitted to CMS on December 16, 2009. The model for this waiver amendment is based upon the current 1915 b/c waiver that has been operating in Cabarrus, Davidson, Rowan, Stanly, and Union counties since April 2005. The existing waiver is currently administered by the State through PBH (formerly known as
Piedmont Behavioral Healthcare), a local management entity for the delivery of publicly funded mh/dd/sa services. PBH has been working in partnership with DMH/DD/SAS and DMA in support of this waiver expansion request to CMS.

DHHS is asking to replicate PBH’s model with some additional amendments to the current 1915 b/c waiver application and make the waiver statewide with the ability to phase in new LME waiver entities. PBH as a waiver entity, starting as a pilot project, has demonstrated for the state the success of this model. Since 2005 DMA has contracted with Mercer to assist
both Divisions in providing annual monitoring. Based upon the success of this model, DHHS wishes to expand the use of the waiver program.

Based upon CMS approval of the waiver expansion PBH will become part of the State’s Waiver expansion. DMA and DMH/DD/SAS are currently contracting with Mercer to assist in the development of a Request for Applications (RFA) and selection criteria of local management entities who may be interested in becoming an LME waiver management entity.

DHHS plans to methodically select and add on additional LME wavier entities to operate in the same capacity as PBH as a prepaid health plan for the delivery of mh/dd/sa services. The tentative process and timeline for the Request for Application is as follows:
· Prepare and post RFA --- Target date: February 2010
· RFA applications due to DMA/DMH: April 2010
· Desk review and site review of RFA applicants: April - May 2010
· Announcement of selected LME waiver entity(ies): July 2010
· Waiver start date: July 2010 or dependent of several factors:
o Dependent upon CMS approval of submitted Waiver Application Amendment
o Approval of a New Technical Amendment to bring on the new geographical region of the LME waiver entity approved by CMS.
o Transitional timeline of the new LME waiver entity timeline to begin full waiver operation activities.

DHHS will select one or two LME waiver entities to begin operation during SFY 2010/2011 if approved by CMS. An official announcement will be made concerning sites selected to participate in the program. DHHS will issue additional RFAs in the future to establish more LME waiver entities across the state based on the success of waiver programs.

DHHS is planning specific ways for consumers, family members and the general public to participate in the development, implementation and oversight of this project. Additional information about this 1915 b/c waiver will be provided through designated DMA and DMH/DD/SAS waiver web pages, the joint Implementation Updates, DMA Medicaid Bulletins and a special series of waiver Fact Sheets over the course of implementing this project."


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