More Comments on Michigan's Dual Eligibles Plan

Below are links to comments on the Michigan proposal for "Integrated Care for people who are Medicare-Medicaid Eligible." The people commenting all have family members who have been served by the Community Mental Health (CMH) system as well as professional or volunteer experiences that give them insights into the workings of the system that serves people with developmental disabilities and mental illness.

Rita Bird, a parent and Ottawa County CMH  Board member, gave testimony to the Michigan Senate Appropriations Subcommittee on the Department of Community Health in March 2012 on the  Dual Eligibles plan.

She raises questions about the cost of implementing the dual eligibles plan: "Good judgment demands that cost estimates be as accurate as possible in order to determine whether the Plan is financially sound and sustainable. "..

She is also concerned about "general confusion about the meaning of the plan and the state's intent in implementing it":

"What happens when the two systems [physical health care and mental health services] are in competition for the same dollars?"

"Who makes the final decisions on which services are covered, which services have priority, who delivers the services, who receives the services, and who has 'veto power over services that may be deemed just too expensive to provide to a particular population or to someone who is deemed too disabled, to sick, or too old for the expense?"

Rita's recommendations to the legislature are:

• Do not allow mental health funding allocations to be co-mingled with physical health care losing vital dedicated funding allocations for those with mental, cognitive, and physical disabilities. 
• Insist on the assurance that all current mental health services including enhanced Waiver services be continued and monitor waiver negotiations between DCH and CMS. 
• Delay approval of the Proposed DE Plan until it can be presented in its final form following CMS negotiations.
• Insist on a complete “Carve Out” of the existing mental health system structure until it can be accurately scrutinized for any cost savings and unnecessary bureaucratic weight. This has not been done.
• Have the mental health system continue to serve the DD population.
• Do not allow their services to be included in Long Term Care.

Marianne Huff, Executive Director of Allegan County Community Mental Health Services (ACCMHS) also comments on "the lack of sufficient detail to know whether or not there is a reason to be concerned."

She believes that " persons with disabilities have not been afforded an equal opportunity to learn about the Plan nor have persons with disabilities been given equal opportunity to participate in public discussions regarding the Plan."

She says, "...it is our contention that the stakeholder involvement process was limited and not truly accessible to those who comprise the greatest number of the almost 198,644 Dual Eligibles in the state of Michigan:  Qualified Persons with Disabilities."
 

Of further concern is "the lack of detail in the Plan as it applies to the current CMHSP system as a provider network and county-based system of specialty supports to persons with disabilities...It is difficult to speculate about the rationale for not including a more detailed explanation about the role of CMHSPs, but there is a sense that the Plan is designed to eventually eliminate the county-based community mental health system. "

Ed Diegel is from DD Advocates of Wayne County. In his comments, he emphasizes the importance of assuring that funding intended for people with DD is not used for non-DD programs, that inappropriate uses of these funds should be prohibited, and that the rights of the DD must be protected.

He also makes the point that in Wayne County, "when two of three Major Care Provider Networks (MCPN’s) unilaterally cut funding to programs for the Developmentally Disabled (with no corresponding reductions in State funding), the cuts resulted in service reductions and health and safety issues across the county. The conclusion is that there is no ‘administrative excess’ in the DD system for funding services for other populations."

On physical health care, Ed says that many people with DD who have complex medical needs may  exhibit symptoms different than the normal population or they may be presented in a different way.  He also notes that many people with DD  have doctors in more than one medical center.

He is also knowledgeable about  business operations of public agencies, service providers, and contractors. He emphasizes the need for planning for additional personnel that may be needed and re-defining industry practices to guard against the following:

• Excessive overhead assessments from contracting agencies at every level. i.e. Wayne County assessments for contracts that include kick backs and favoritism and excessive buy out provisions included in the over all overhead assessment
• Excessive reserves – recently the Michigan Attorney General sued the Federal Government to allow Blue Cross and 10 or 11 other Michigan Insurers to accumulate excessive reserves for its Michigan business (more than the 25% the Federal Govt allows).
• For-profit and non-profit company returns must be uniformly reported to assure against excessive profit taking. For instance, Health Net, a California Medicaid insurer shares are up over 64% since Oct 3, 2011 on news it will get a portion of the California dual eligible business!!

My comments on the plan are here .
 
Comments on the state plan to the Michigan Department of Community Health (MDCH) were due on April 4th, 2012, but comments can be submitted anytime to this email address: Integratedcare@michigan.gov 

This is the dual eligibles website for more background information on the plan.

If you have comments, be sure to let your legislators know. After the state submits its draft of the plan to CMS (Centers for Medicare and Medicaid Services), there will probably be negotiations with CMS that may result in changes. Fortunately, language was recently placed in an appropriations bill that requires the MDCH to submit the final draft of the dual eligibles plan to the legislature before the final version is submitted to the CMS.