This week’s newsletter NAMD released a statement on key statutory flexibilities for Medicaid; House drops AHCA proposal; CMS issue briefs containing early results of the Medicare-Medicaid Financial Alignment; and Opioids
NAMD Releases Statement on Key Statutory Flexibilities for Medicaid
On March 23, NAMD released a statement outlining key statutory flexibilities federal policymakers should consider as part of debates around reforming Medicaid’s financing structure. In the statement, NAMD highlights Medicaid’s recent successes, and notes that current reform proposals envision a limit on federal contributions to the program paired with regulatory flexibility provided by the Administration. While regulatory flexibility is welcome, ensuring the program’s success in a resource-constrained environment requires statutory changes to allow states to directly address fundamental cost-drivers impacting the overall health care system.
Last week, CMS released three evaluation issue briefs containing early results of the Medicare-Medicaid Financial Alignment Initiative in the areas of care coordination, beneficiary experience, and special populations:
Care Coordination: This evaluation brief provides an overview of care coordination activities and early findings on successes and challenges of providing care coordination services for nine capitated model demonstrations implemented between October 2013 and February 2015 (link).
Beneficiary Experience: The brief describes the experiences of beneficiaries who are users of long-term services and supports and/or behavioral health services. Based on focus groups conducted between May 2015 and April 2016, it includes information on common themes, including the experiences of racial, ethnic, and linguistic minorities (link).
Special Populations: Based on findings from surveys and focus groups conducted in Massachusetts and Washington from mid to late 2015 and early 2016, this brief describes the experiences of beneficiaries who are users of long-term services and supports and/or behavioral health services, with a focus on the experience of racial, ethnic, and linguistic minorities (link).
Reminder from CMS Data Systems Group
Last week, the CMS Data Systems Group issued a reminder that, accordance with 45 CFR 95.611, enhanced funding is available only upon prior written approval of an APD by CMS; moreover, CMS does not allow enhanced FFP claims for a project if an APD has not been previously approved.
The Group also clarified that states mustrequest funds before incurring expenditures in addition to their annual E&E APD. States must have an approved FFY18 E&E APD by October 1, 2017 or they will have a gap in enhanced funding for the new Federal fiscal year.
For this reason, CMS recommends that states submit their annual E&E APD now to avoid any delays in approving FFY18 funding by October 1, 2017. CMS is currently approving funding request for the next two fiscal years (FFY18 and FFY19). Any request for an increase to a retroactive year that is not within 60 days will be denied. CMS asks that states make sure that they are tracking their expenditures and managing their funding on a quarterly basis.
Children’s Oral Health Initiative Value-Based Payment Technical Support Opportunity for States; Expression of Interests due by April, 12, 2017
The Centers for Medicare & Medicaid Services’ (CMS) Medicaid Innovation Accelerator Program (IAP) is launching a new technical support opportunity for state Medicaid/CHIP agencies to select, design, and test value-based payment approaches that will sustain children’s oral health care delivery models that has demonstrated success in improving children’s oral health. IAP will select up to four state Medicaid/CHIP programs to participate in this two-year opportunity (open to states at all levels of expertise in Value-Based Payment approaches).
Additional information, including the Program Overview, Expression of Interest form, and Informational Session slides can be found on the IAP Value-Based Payment webpage here.
Interested states are asked to complete and email an Expression of Interest form to MedicaidIAP@cms.hhs.gov, subject line “Children’s Oral Health VBP,” by April 12, 2017, Midnight ET.
$22.6 Million in ‘Cures’-Authorized Funding Available to States for Behavioral Healthcare from SAMHSA; Applications due by May 17, 2017
The Substance Abuse and Mental Health Services Administration (SAMHSA) is soliciting applications for $22.6 million in FY 2017 cooperative agreements, authorized by the 21st Century Cures Act, aimed at Promoting Integration of Primary and Behavioral Health Care (PIPBHC). The agency expects to issue 11 awards of up to $2 million each; for detailed eligibility info, see here. Applications are due by May 17, 2017.
As part of this initiative, SAMHSA specifically seeks to:
Promote full integration and collaboration in clinical practice between primary and behavioral healthcare;
Support the improvement of integrated care models for primary care and behavioral healthcare to improve the overall wellness and physical health status of adults with a serious mental illness (SMI) or children with a serious emotional disturbance (SED); and
Promote and offer integrated care services related to screening, diagnosis, prevention, and treatment of mental and substance use disorders, and co-occurring physical health conditions and chronic diseases.
The agency has also identified several special populations to be served:
Adults with a mental illness who have co-occurring physical health conditions or chronic diseases;
Adults with a serious mental illness who have co-occurring physical health conditions or chronic diseases;
Children and adolescents with a serious emotional disturbance with co-occurring physical health conditions or chronic diseases; or
Earlier this month, the Centers for Medicare and Medicaid Services (CMS) published a Medicaid Drug Rebate Program (MDRP) notice providing a review of statutorily-required drug coverage limitations. Specifically, the notice reviews limitations on MDRP coverage of drugs used for cosmetic purposes or hair growth imposed by the 21st Century Cures Act, and limitations on drugs used to treat sexual dysfunction or erectile dysfunction imposed by legislation passed in 2005.
CMS Publishes Submitted PACE Innovation Act RFI Comments
Recently, the Centers for Medicare and Medicaid Services (CMS) made available the stakeholder comments submitted in response to its PACE Innovation Act Request for Information, which closed earlier this year.
HHS Launches Webpage Highlighting Administrative Actions to Empower Patients
Last week, the Health and Human Services (HHS) Department launched a new page on HHS.gov highlighting the regulatory and administrative actions the Department is taking to relieve the burden of the current healthcare law and support a patient-centered healthcare system. HHS Secretary Tom Price, M.D. has called the new website “the place to go for updates” on HHS efforts to “improve choices for patients, stabilize the individual and small-group insurance markets, and expand access to more affordable coverage.”
House Leadership Withdraws AHCA in Face of Insufficient Votes; Congress Shifts Priorities to Federal Budget and Tax Reform
After a week of clearing final House Committee hurdles and continued amendments to shore up vote counts, the House leadership withdrew the American Health Care Act (AHCA) from floor consideration on Friday after it became clear the legislation would not secure sufficient Republican votes to pass. Key House leaders indicate the bill as written will no longer be considered, representing a setback for President Trump’s legislative agenda and a defeat for Speaker of the House Paul Ryan (R-WI). In the end, additional amendments to draw in hardline conservatives from the Freedom Caucus, including Medicaid work requirements and a block grant option for states, were not enough, and moderates became increasingly concerned about the legislation’s impact on coverage. The Affordable Care Act remains in place, and modification of its implementation now rests with the Administration. There is a possibility that the Senate may work to develop a more bipartisan proposal, but the outlook for this remains uncertain.
With the withdrawal of AHCA signaling the end of health reform as a legislative priority in the near term, Congress and the Administration indicate they will turn their attention to tax reform and, in the more immediate term, continued funding of the federal government through the remainder of FY 2017. Current FY 2017 funding is set to expire on April 28. Congressional hearings on the President’s FY 2018 budget proposal are also set to begin in the coming weeks.
In the News
Reuters reports that few teens receive effective treatment for opioid addiction
Last week, Reuters reported on a recent Journal of Adolescent Health study, which finds that a diminutive fraction of adolescents with opioid addiction receive medications that can help them quit. In 2013, 26% of adult heroin addicts received medication-assisted treatment compared to just 2% of adolescents; meanwhile, 12% of adult opioid addicts received medication compared to less than 1% of adolescents. For the approximately half-million US adolescents who use prescription opiates every year, these findings raise difficult questions concerning the often-strict parameters surrounding Medicaid coverage of medication-assisted treatment. The medication methadone, for example, is only offered at specific substance abuse treatment centers, all of which require a waiver to treat anyone under 18. Furthermore, Medicaid rules stipulate that adolescents with opiate addiction must have failed treatment twice in order to be prescribed methadone. Reviewing these restrictions, the study authors conclude that “there’s more that needs to be done across the board to facilitate access to these treatments when they’re medically necessary.”
Americans use far more opioids than anyone else in the world, reports The Washington Post
New United Nations data evidence that the United States outpaces all nations in its consumption of prescribed opioids. Compared to citizens of several European nations, U.S. residents are prescribed about six times as many opioids per capita. Arguably the largest driver of this disparity is hydrocodone: Indeed, Americans consume more than 99% of the world’s supply of this opioid. Despite these troubling data, the number of U.S. opioid prescriptions has actually decreased in the past few years, after more than a decade of explosive growth. This reduction reflects new practice guidelines underscoring opioids’ generally poor effectiveness at reducing chronic pain, increased monitoring of prescribers by government and health-care organizations, and widespread concern over the epidemic of opioid-related deaths.
Two Kaiser Family Foundation Resources on Per Capita Caps
What if Per Enrollee Medicaid Spending Growth Had Been Limited to CPI-M from 2001-2011? A new analysis from the Kaiser Family Foundation finds that the majority of states would have gotten less in federal Medicaid funding from 2001 to 2011 if Medicaid financing had been based on a per capita cap. The analysis looked at what would have happened if spending growth per Medicaid enrollee had been limited to growth in the medical care component of the Consumer Price Index (CPI-M) during that period.
What Could a Medicaid Per Capita Cap Mean for Low-Income People on Medicare? This brief discusses the potential implications of Medicaid per capita cap or block grant proposals for low-income seniors and people with disabilities on Medicare. It finds that the shift to per capita caps would limit federal Medicaid contribution – a change that is likely to have fiscal implications for states and enrollees. The brief finds that, ultimately, the impact on any given state will depend on the number of factors, including the growth of state elderly populations.
American Academy of Actuaries Sends Letter to Congress on AHCA
On March 22, the American Academy of Actuaries’ Health Practice Council sent a letter to Speaker of the House Paul Ryan (R-WI) providing an actuarial perspective on the American Health Care Act (AHCA). The letter analyzes AHCA’s per-capita cap funding proposal for Medicaid, noting opportunities and challenges for states in that scenario. Specific areas assessed include:
AHCA’s approach to setting state caps;
Treatment of the Medicaid expansion population, with risk for adverse selection in this enrollment group leading to higher costs than those accounted for in a 2016 baseline;
The CPI-U medical growth rate methodology, with risk for states being unable to sustain or improve current programs if costs outpace this growth rate;
Program flexibility provide to states; and
Actuarial soundness of Medicaid managed care rates.
Montana Medicaid and Health Services Branch Manager Opening
This position is the Medicaid and Health Services Branch Manager. The position is responsible for medical, rehabilitative, and mental health service programs by overseeing the following Department Divisions: Developmental Services Division, Health Resources Division, Senior and Long Term Care Division, and Addictive and Mental Disorders Division. Included are six institutional treatment and long term care facilities: Montana Chemical Dependency Center, Montana Developmental Center, Montana Mental Health Nursing Care Center, Montana State Hospital, and two Montana Veterans’ Homes. The position also oversees the Medicaid Payment System support program. The position directly supervises four division administrators and two Medicaid managers, and indirectly supervises approximately 1400 FTE.