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DMC-ODS IMPLEMENTATION REQUIREMENTS MARCH 2019 PRESENTED BY – KAKOLI BANERJEE, PH.D

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Page 1: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

DMC-ODS IMPLEMENTATION REQUIREMENTS

MARCH 2019PRESENTED BY – KAKOLI BANERJEE, PH.D

Page 2: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Agenda

Update on 2018-19 Inter-governmental Agreement (IGA) (also the contract with DHCS), also STC (standard terms & conditions)

Page 3: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

SCC SUTS Contract with DHCS

By signing the contract -Inter-governmental Agreement (IGA) in 2017, SUTS became a PIHP (a Pre-paid Inpatient Health plan)-a Managed Care Plan (MCP)

(SUTS MCP is one of two MCPs operated by the SCC BHSD)

SUTS is contractually obligated to comply with IGA terms & implement all the components contained in the contract

When SUTS contracts out services, all service providers are also required to comply with IGA terms & conditions

Page 4: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

The Inter-governmental agreement -IGA

The IGA is composed of two main sections; a general section and a county-specific section

The general section covers provisions that apply to all waiver opt-in counties: IGA requirements also align with 42 CFR Part 438 provisions

(Final Rule), which regulate the operation of public managed care plans

This presentation covers changes/updates in the general section of the IGA

Page 5: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Required IGA provisions –(applicable to all opt-in counties) fall into 3 categories

Clinical services, medical necessity,

Access, Coordination of care

Quality management & performance measurement

Business operations (42 CFR 438)

includes claims & reimbursement

Page 6: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Mandatory ASAM Levels of Care- No change

MANDATORY Withdrawal management (at least one

level) Outpatient services (ASAM Level 1.0) Intensive Outpatient Services (ASAM

Level 2.1) Residential treatment (at least 1 level) Opioid (Narcotic) Treatment Programs Recovery services Case Management Perinatal Residential Tx Svcs Physician consultation

OPTIONAL Partial Hospitalization Residential levels 3.3 & 3.5

REFERRALS TO: Medically Monitored Intensive Inpatient

Services (ASAM 3.7) Medically Managed Intensive Inpatient

Services (ASAM 4.0)

Page 7: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Covered services & service requirements:Changes/clarifications

Page 8: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Covered services & service requirements:Changes/clarifications

The Contractor shall accept, and reimburse, a claim from any subcontracted OTP/NTP provider (Referring OTP/NTP) that pays another OTP/NTP for providing courtesy dosing (Dosing OTP/NTP) to a beneficiary.

The Contractor shall use the reimbursement rate established in the OTP/NTP provider’s subcontract.

Page 9: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Covered services & service requirements:Changes/clarifications

Page 10: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Covered services & service requirements:Changes/clarifications

Page 11: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Service requirements-Access:Changes/clarifications

Page 12: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Service requirements-Access:Changes/clarifications

Page 13: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Service requirements-Access:Changes/clarifications

Page 14: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Service requirements-Medical necessity:Changes/clarifications-Reminder

All beneficiaries shall meet the following medical necessity criteria: a diagnosis from the Diagnostic and Statistical Manual of Mental Disorders

(DSM) Fifth Edition for Substance-Related and Addictive Disorders with the exception of Tobacco-Related Disorders and Non-Substance- Related Disorders or be assessed to be at risk for developing substance use disorder (for youth)

the ASAM Criteria definition of medical necessity for services based on the ASAM Criteria

Page 15: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Service requirements-Medical necessity:Changes/clarifications

New language spells out the deadline for review The Medical Director or LPHA shall review each beneficiary’s personal, medical, and

substance use history if completed by a counselor within 30 calendar days of each beneficiary's admission to treatment date.

The Medical Director or LPHA shall document separately from the treatment plan the basis for the diagnosis in the beneficiary's record within 30 calendar days of each beneficiary's admission to treatment date.

Page 16: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Service requirements-Diagnosis:Changes/clarifications

Medical Director or LPHA shall: evaluate each beneficiary’s assessment and intake information if

completed by a counselor through a face-to-face review or telehealth with the counselor

to establish a beneficiary meets the medical necessity criteria. diagnosis shall be a narrative summary based on DSM-5 criteria,

demonstrating the Medical Director or LPHA evaluated each beneficiary’s assessment and intake information, including their personal, medical, and substance use history.

shall type or legibly print their name, and sign and date the diagnosis narrative documentation. The signature shall be adjacent to the typed or legibly printed name.

Page 17: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Service requirements-Physician signature on physical examination results:

Changes/clarifications

Physician signature requirements for the review of physical examination results are spelled out:

The physician shall type of legibly print their name, sign and date documentation to support they have reviewed the physical examination results.

The signature shall be adjacent to the typed or legibly printed name.

Page 18: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Service requirements-Clinical documentation:Changes/clarifications

Specific language from Title 22 was added to the following (section PP – 13 thru 18):

Treatment plan

Sign in sheet

Progress notes

Continuing services

Discharge

Reimbursement for documentation(see attachment)

Page 19: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

QM/QI : Grievance & appealChanges/clarifications

Interval for responding to a grievance is spelled out:

MCP process for handling beneficiary grievances and appeals of adverse benefit determinations-

Acknowledge grievance and appeal within 5 calendar days of receipt

No other change in the grievance & appeal process

Page 20: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Business operations: Alignment with Parity ActChanges/clarifications

Parity in Mental Health and Substance Use Disorder Benefits

General Parity Requirement MCP shall not impose Quantitative Treatment Limitations, or Non-

Quantitative Treatment Limitations on (inpatient, outpatient, emergency care, or prescription drugs) other limitations permitted and outlined in this Agreement.

Quantitative Limitations-cumulative financial requirement for substance use disorder services not applied to medical services

Non-Quantitative Limitations-

Page 21: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Non-quantitative limitations defined

Non-Quantitative Treatment Limitation (NQTL)” means a limit on the scope or duration of benefits that is not expressed numerically.

Non-quantitative treatment limitations cover reasons medical reasons, prescription drugs, charges, needing proof to authorize higher cost services, failure to complete a course of treatment.

(Definitions of both will be posted on the website).

Page 22: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Business operations:Changes/clarifications

Two additions:

Number for reporting Medi-Cal fraud

Suspected Medi-Cal fraud, waste, or abuse must be reported to:

DHCS Medi-Cal Fraud 800-822-6222 or [email protected]

MCP Record retention policy

MCP must require providers to ‘to keep and maintain records for each service rendered, to whom it was rendered, and the date of service, pursuant to WIC 14124.1 and 42 CFR 438.3(h) and 438.3(u)’.

Page 23: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Business operations:Changes/clarifications

Network adequacy requirements for MCP spelled out & MCP is expected to:

Provide supporting documentation to demonstrate network adequacy for timeliness and access standards

Show that the locations, number and mix of services in the network sufficient to meet needs of beneficiaries

Network adequacy must be demonstrated annually in a DHCS approved format

Failure to comply with documentation requests will incur monetary penalties for the MCP

Page 24: DMC-ODS IMPLEMENTATION REQUIREMENTS...dmc-ods implementation requirements march 2019 presented by – kakoli banerjee, ph.d. agenda

Comments & Questions

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