Tuesday, April 3, 2012

Michigan's Plan for Dual Eligibles: Comments on PIHPs and State-wide Assessments

PIHPs (Pre-Paid Inpatient Health Plans) 
PIHPs distribute Medicaid funds to local Community Mental Health agencies in the state and provide other administrative services and management. [The Washtenaw Community Health Organization (WCHO), serves as the PIHP for a four-county area of southeastern Michigan while also serving as the Community Mental Health (CMH) agency for Washtenaw County.]

The state has decided to preserve the PIHP structure for the management and financing of local CMHs, but the number of PIHPs will be greatly reduced with each one serving a much larger geographic area than it does now. The plan does not give much detail about what the PIHPs will look like or how accessible they will be to the people they serve. The decision to preserve the PIHP structure does not assure that there won’t be major changes in how PIHPs operate.

Screening and State-wide Standardized Assessments

According to the plan, (page 2) “Upon enrollment, all beneficiaries will be initially screened to determine basic needs, followed by a more in-depth standardized assessment to determine the possible array of services. The need for specialty services through the separately contracted PIHPs will also be determined at this time…”

Does this mean that a person with a developmental disability could be assigned to an Integrated Care Organization (ICO) (this would likely be something like a Medicaid managed health plan) rather than a PIHP, even though PIHPs under current law are responsible for managing and financing mental health services to people with DD? If a person with DD chooses to be in an ICO, would they still have access to all the mental health services they need?

Also according to the plan, (page 14) once a person is determined to fall under the PIHP part of the system, the PIHP “will conduct a more extensive person-centered assessment” The core assessment instrument can trigger the use of multiple sub-sections that “span the full ranges of needs and, individually, allow for gathering in-depth information in specific areas…” Over time other subs-sections “…may be triggered, leading to identification and linkage to new services”.

Under this plan, the state will develop a standardized assessment instrument covering physical and mental health care for 200,000 people that will determine the needs of individuals and presumably the services they will be eligible for, before the individuals themselves, their families, and others who know them well, have had a chance to participate in the Person-Centered Planning process where these decisions should be made.

Why bother having a Person-Centered Plan if a state assessment has already made the determination of needs and the identification of services? 

Is there an “instrument” that currently exists that can identify all the medical and social supports for 200,000 people with needs as diverse as the population of people who are eligible for both Medicaid and Medicare? If not, how much will it cost to devise such an “instrument” with its expanding multiple subsections and linkages?

Rather than assisting a PCP team (that includes the individual being served) in determining needs and services, the standardized state-wide assessment proposed by this plan, appears to have reduced the PCP to a rubber-stamp of the state’s determination of needs and services.

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