July 30, 2018 from the CEO
At the Federal level on March 17, 2014, the Centers for Medicare and Medicaid Services (CMS) published a new set of rules for the delivery of Home and Community Based Services through Medicaid waiver programs. Through these new rules, the Centers for Medicare and Medicaid Services aim to improve the experience of individuals in these programs by enhancing access to the community, promoting the delivery of services in more integrated settings, and expanding the use of person-centered planning.
These rules will ensure individuals who have disabilities have the same access to the community as individuals who do not have disabilities. It allows individuals the opportunity to make decisions about the services they receive and who provide their services. The goal of the HCBS Final Rule is to make sure that the services individuals receive, give people the opportunity for independence in making life decisions, to fully participate in community life, and to ensure that individuals’ rights are respected.
CMS indicated that states were permitted to propose transition plans (i.e., Statewide Transition Plans) encompassing up to five years after the effective date of the regulations for settings to come into compliance with the regulation. This would require statewide compliance by March 17, 2019. However, in light of the difficult and complex nature of this task, CMS recently has extended the transition period for states.
Arkay will need to continue to emphasize community integration with supported employment and skill building services. Full participation in community life: All individuals are supported to take part in their community and have the same access as other individuals in the community. This requires full participation in community life. Our goal would focus on integrated and unsubsidized employment for our consumers.
The Michigan Section 298 Initiative is an effort to improve the coordination of publicly-funded physical and behavioral health services in the state. The initiative began with the Governor’s 2016 executive budget, which sparked a statewide discussion on the best approach for integrating physical and behavioral health services.
Section 298 was approved as part of Public Act 268 of 2016. Under this law, the Michigan Legislature directed the department to develop a set of recommendations regarding the most effective financing model and policies for behavioral health services for individuals with mental illnesses, intellectual and developmental disabilities and substance use disorders. The Michigan legislature recently passed an appropriations bill for Fiscal Year 2019. This bill contains new boilerplate language for the Section 298 Initiative.
On March 9, 2018, Michigan Department Health & Human Services (MDHHS) announced the pilot sites for the Section 298 Initiative:
A. Pilot #1: Muskegon County CMH (dba Health West) and West Michigan Community Mental Health
B. Pilot #2: Genesee Health System
C. Pilot #3: Saginaw County Community Mental Health Authority.
MDHHS is currently reviewing stakeholder input on the project. MDHHS has announced a new target date for pilot implementation of October 1, 2019. MDHHS will be engaging the members of the Leadership Group and other stakeholders in a discussion about the impact of the amended timeline on the pilots. The University of Michigan (UM) evaluation team has been working on identifying performance metrics for the evaluation of the pilots and demonstration project.
At the local level, Detroit Wayne Mental Health Authority (DWMHA) is responsible for providing specialty behavioral health supports & services for the citizens of Wayne County through it Pre-Paid Inpatient Health Plan (PIHP) under the MDHHS.DWMHA is both a PIHP and a Community Mental Health Service Program (CMHSP), but it is excluded from the MDHHS. In June 2018, DWMHA is exploring the possibility of initiating its own Section 298 pilot project with Medicaid Health Plans (MHP).
DWMHA has been working with nationally recognized experts in health care to identify various models. The DWMHA Board has approved to do their own integrated pilot project with a MHP in line with the State 298 initiative that can be implemented by October 1, 2019. This is the same implementation date of the MDHHS pilot projects.
Arkay will need to review the Wayne County model and see how the organization will “fit-in” to this model. Points to consider are if the model will increase the delivery of services or decrease services to the developmentally disabled population. Arkay could have a liaison staff for all DWMHA meetings.
The other news from DWMHA Board has approved a Systems Transformation Plan in June 13, 2018.which eliminates the MCPN structure. The DWMHA Board of Directors passed a resolution regarding the future of DWMHA and its System of Care. With input from the DWMHA Board of Director’s System Transformation Committee, healthcare delivery experts, MDHHS, and executive leadership resolved the elimination of the current MCPN structure and DWMHA assuming full management of all services and supports thereby taking over the responsibility for delegated services and responsibilities.
The DWMHA’s Systems Transformation Plan seeks to eliminate the roles of the MCPN and to begin to directly manage the services and responsibilities currently delegated to the MCPNs in accordance with a key target dates of October 1, 2018, January 1, 2019 and October 1, 2019. DWMHA will need to re-establish a direct relationship with our providers and the people we serve. Also, DWMHA needs to migrate delegated functions from all MCPNs.