Tuesday, April 3, 2012

Michigan's Plan for Dual Eligibles: General Comments

In drafting the final version of Michigan’s proposal for “Integrated Care for People who are Medicare-Medicaid Eligible,” it is clear that the state was listening to criticism of the original plan by people currently covered by the community mental health system, including people with developmental disabilities. The state’s response, however, was to use language more familiar and reassuring to the CMH population for parts of the plan affecting mental health services without removing the uncertainty of the original proposal or filling in the details in how the plan will be implemented and paid for. The revised plan still does not explain why the state chose such a radical approach to changing the current system of care for dual eligibles.

From my perspective, as the parent of two adult sons with severe developmental disabilities who need a high level of care to survive much less to thrive in a community setting, the uncertainty reflected in this document is alarming.

Budget reductions for FY 2013

It is likely that the 2013 budget for the Department of Community Health has already been approved by appropriations committees of the legislature with a $30 million reduction in spending for the Michigan Department of Community Health (MDCH) attributed to the Dual Eligible proposal (see page 28 of this presentation of the budget), even though the final draft of the proposal has not yet been submitted to the federal government for approval and won’t be fully implemented until June of 2014, according to the plan.

Where exactly are the spending reductions coming from?

State management of a federal program

Another baffling part of the proposal is that Michigan is voluntarily proposing to take on management of the Medicare system for the Medicare-Medicaid Eligible population, even though Medicare is a federally managed and paid-for program. Medicaid is already a state-federal partnership, funded by both the states and federal government, managed by the states, and regulated by the federal Centers for Medicare and Medicaid Services (CMS).

Of what benefit is it to the state and Medicare beneficiaries to take over management of a federal program?

State law v. the DE proposal

The Michigan Social Welfare Act (Section 400.109f) says that “…Medicaid-covered specialty services and supports shall be managed and delivered by specialty prepaid health plans [regional community mental health entities] chosen by the department of community health …The specialty services supports shall be carved out from the basic Medicaid health care benefits package…”

If Medicaid and Medicare funds are blended to pay for physical and mental health services of Dual Eligibles, then it appears that there is no Medicaid carve-out for mental health services for this population. Does the MDCH still maintain that the Integrated Care Plan can be implemented without changes to state law?

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