HCCA Cascade Range Regional Conference February 14, 2014 Speakers Moderated by Gwen Dayton, JD General Counsel and Vice President, Health Policy Oregon Medical Association Panel members: Wendy Edwards, MPA:HA, CHC Director of Regulatory Affairs/ Compliance Officer Samaritan Health Plan Operations Intercommunity Health Network CCO Dick Sabath, Compliance Officer Trillium Community Health Plan CCO A new locally controlled way to provide Medicaid services in Oregon that includes: Integration of behavioral, physical, & oral health Non emergent medical transportation Reimbursement models that incentivize positive patient outcomes CCO accountability for the health of the population served Partnership among health care providers, health systems, community members and patients Remember: More Medicaid patients in 2014 1
New Compliance Challenges: HIPAA Implementing quality metrics Integration of services Mental health residential treatment transition Legislative activity 2013-2014 Information sharing for improved care (authorized by ORS 414.679) A CCO, its provider network and programs administered by DHS for adults and persons with disabilities must share member information for purposes of: Service and care delivery, coordination, service planning, transitional services and reimbursement, improving the safety and quality of care, lowering the cost of care, and improving the health and well-being of the CCO s members. Information may be shared within the CCO and the CCO provider network for the purpose of allowing the CCO to provide whole-person care. Information that may be shared without member authorizationincludes diagnosis of HIV, other physical health diagnoses and mental health diagnoses. Information about members may be shared between CCOs, OHA and DHS for the purpose of administering the laws of Oregon. 2
In network provider mandate for information sharing (authorized by SB 1580 (2012)) Except for psychotherapy notes, protected health information mustbe disclosed by health care providers participating in a CCO without member authorization: To other health care providers participating in the CCO for treatment purposes, To the CCO for health care operations and payment purposes, permitted by ORS 192.558; and To public health entities as required for health oversight purposes. But: CCOs and their providers must comply with HIPAA and 42 CFR Part 2 (authorization needed for disclosure of treatment records of substance abuse treatment providers). Mandated disclosures under state law do not override the federal protections for drug and alcohol records found in 42 CFR Part 2 or for educational records. Assist working partners, such as behavioral health and NEMT, understand HIPAA and the application of HIPAA within the CCO through training and agreements CCOs are required to provide based line data and show improvements in care through data as incentivized payment mechanism. Base line data that is accurate Understand how best to show improvement in care Make quality care accessible Eliminate health disparities 3
CCOs have integrated Non-Emergent Medical Transportation as service offering. NEMT brokerages vary across the state. Some face provider access issues in transportation philosophy. Specific compliance challenges: Notice of Action denial directly to hearing w/out appeal Volunteers making ride eligibility decisions Untrained call center personnel Medical reason for appointment Unmet transportation needs Conduct Risk Assessment Review contract provisions Offer assistance and share best practices Share and explain performance expectations Educate brokerage on practical HIPAA impacts 8 of the 15 CCOS have integrated multiple Dental Care Organizations (DCO) into their CCOs. CCO s can t delegate oversight and monitoring Quality Improvement activities. CCOs can t delegate adjudication of final appeals in Member grievance and appeal process. Work in collaborative, cooperative environment Work out processes for appeals and grievance reporting Assess compliance efforts Offer suggestions to improve or strengthen compliance efforts Anticipated transition of Mental Health Residential Treatment from Oregon Health Authority to CCOs Projected Transition Schedule: Meetings between May and August 2014 Active Transition to CCOs July 1, 2014 Solutions are currently being explored and include: http://www.oregon.gov/oha/amh/pages/residentialtransition.aspx Look at charters Read Mental Health Residential Treatment System Transition to CCOs (FAQ format) 4
There are many enrolled bills from the 2013 session that impact CCOs, including: Senate Bill 1580 Prohibits discrimination against types of providers by coordinated care organizations and specified managed care organizations. Senate Bill 1548 -Amends certain statutes that reference "physician" to include references to "physician assistant" and "nurse practitioner." Takes effect July 1, 2014. Senate Bill 1553 -Directs Governor to appoint Oregon Public Guardian and Conservator in office of Long Term Care Ombudsman to provide public guardian and conservator services for persons without relatives or friends willing or able to serve as guardians or conservators. There are many bills filed as we start the 2014 session that impact CCOs, including: Senate Bill 1580 -Prohibits methadone clinic from commencing operation at site within 1,000 feet of pediatric clinic or public park. House Bill 4013 -Authorizes practitioners to electronically transmit prescriptions for Schedule II controlled substances in nonemergency situations. House Bill 4074 -Authorizes Board of Medical Imaging to waive specified licensing requirements for individual who meets certain criteria. House Bill 4096 -Requires director and managers of Department of Consumer and Business Services, executive director and managers of Oregon Health Insurance Exchange Corporation, and statewide elected officials who elect to obtain health insurance provided by state, to select health benefit plan offered through health insurance exchange. House Bill 4108 -Requires Oregon Health Authority to contract with community-based organizations to operate pilot project to provide used durable medical equipment to medical assistance recipients. (Initially in Portland and Salem) 5
House Bill 4129 -Increases rate of taxation on cigarettes and tobacco products. (-$1.50 per pack increase on the Tobacco Tax--$430-460M to CCOs-15% directed at prevention, 85% to be used at CCO s discretion) House Bill 4122 -Requires state contracting agency or public corporation that procures goods or services with contract price that exceeds $1 million or meets other criteria to procure quality management services from qualified contractor. 6