Wednesday, September 21, 2011

More on Michigan's plan for "dual eligibles"

Common Buckeye
If Michigan’s proposal to the federal government for “dual eligibles” were to be implemented, approximately one-third of mental health consumers would have both medical and specialized mental health services managed and financed by a medical health insurance plan. About half the funding for Community Mental Health services would leave the CMH system to pay for the new system of care. Such a plan would affect everyone receiving services under CMH, including people who are covered only by Medicaid.
Most people with DD and other disabilities and their families would have welcomed a discussion on how to improve CMH services. It is a flawed and chronically underfunded system, but at the very least, the principles upon which it is based and the combination of federal, state, and local policies that protect the rights of the people it serves, give most of those individuals a fighting chance for the services they need, not only for survival, but for a life that is fulfilling and meaningful. The state’s plan to reform the system is a radical approach with too many unanswered questions about how it could be implemented.

The Michigan Department of Community Health (MDCH) has now held 6 public forums to receive comments about Michigan’s proposal to integrate dual eligibles. After attending two of these forums, I found no indication that the MDCH was willing or able to answer the many questions that were asked when the plan first came up for public comment. Those questions (see here and here) remain unanswered.

A compilation of information and analysis of the dual eligible plan was distributed at a 9/14/11 meeting of the Community Mental Health Partnership of Southeast Michigan (CMHPSM), an affiliation of the mental health boards for the Counties of Lenawee, Livingston, Monroe, and Washtenaw. This document explains the plan better than anything else I have read. 

Here are some notable quotes from the dual eligible plan analysis mentioned above: 
  • “What are we to make of all the signs that portend expansion in the use of Health Plans for duals, moving benefits out of current managing structures [CMH and regional affiliations of CMH agencies]? One appraisal might be that the plan, while arguably audacious, is also ill conceived (perhaps to the point of recklessness), and designed – not to better coordinate care – but to achieve savings, to the detriment of dual eligible beneficiaries…”
  • What is puzzling about the MDCH proposal is that it – in effect – transfers crucial Medicaid state plan and … waiver services and supports to be managed by entities that have little or limited experience with the dual eligible population.” 
  • “The MDCH proposal also exhibits scant understanding of non-medical (e.g., housing, transportation, linkage with various social service programs, etc.) supports – accessed through other community agencies – that are critical to community inclusion and participation for seriously mentally ill and/or developmentally disabled dual eligibles.”
The 10-page initial proposal that landed Michigan a $1 million contract to develop a plan for dual eligibles can be found here.

The Kaiser Family Foundation summarizes all fifteen state plans that were awarded contracts by CMS in this document: “Proposed Models to Integrate Medicare and Medicaid Benefits for Dual Eligibles…” This policy brief can be downloaded here. Other states that had their plans accepted by CMS proposed more flexible arrangements with some offering different plans for different subpopulations of dual eligibles, a much better approach in my opinion.

These documents are not easy to understand unless you happen to be an expert on health care reform, insurance reform, mental health administration, etc., but they may help you to ask the right questions when you respond to the plans that the state has for you DD family member.

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