Updates and Other Things

May 30, 2019

Transactional vs Transformational

We had a conversation yesterday about the impact that DBHDS instructions, guidance, requirements on CSBs (especially those that directly impact the work of the Case Managers) have on the provider community.  We already know that the impact of high turnover among the CMs is having an impact on the individuals we support, their families and certainly on the provider staff with the responsibility of being the liaison to the Case Manager; a recent pilot by DBHDS has allowed seven CBSs to fund some additional staff (or rearrange duties among existing staff) to perform some of the “transactional services” as described below in a 2018 memo from the Interim Commissioner: “Fundamentally, case managers assess, plan, link, coordinate, and monitor the provision of services and supports. Within these core functions are a variety of tasks that can be considered transactional and others that can be considered transformational.
  • Transactional activities must be done to satisfy a regulation or requirement, but have little or no impact on the person’s quality of life; can often be done by someone other than the case manager; are system-oriented, and; routinized.
  • By contrast, transformational activities are fundamental to the role of the case manager; lead to discovering what people care about; ensure desired changes are pursued, and; supports a person having a voice in his or her life.
Making the distinction between transactional and transformational activities may suggest opportunities to do the work differently within an agency and allow CMs to focus on those tasks only they can do.” Of course, a great deal of all of our daily lives is devoted to “transactional” duties!

Progress on the QMHP Final Regulations

We spent this morning at the Board of Counseling’s Regulatory Review Committee Meeting to monitor the discussion of proposed changes to the final QMHP Registration Regulations – the Summary of the Public Comments informed the committee’s discussion.  There will be a few technical changes, and a partial acceptance of the language change proposed by the OT’s.  Final adoption is expected by the Board tomorrow and then they will again go through the process and be out for a short comment period on last time. Criminal Background Checks We have verified with the experts at the Virginia State Police that federal rules prohibit the transmission of the Federal Criminal Background report to a private entity.  We have been asked to explore that possibility as part of the discussion about the concerns about Fieldprint.  That does not eliminate the potential for Fieldprint to utilize one of your office locations as a site – something that could only be negotiated directly with Fieldprint – but the results would still be processed by DBHDS.

Behavioral Health Redesign Stakeholder Work Groups

Per Dr. Alyssa Ward, DMAS  – “We appreciate all of your nominations for the stakeholder work groups. Per my last update to this group, we have been working on organizing those nominations into a repository and establishing the structure and composition of the groups. Information coming soon, as promised. Please stay tuned.” She also reports the following on rate setting – “We are happy to report that funding has been identified for the rate and fiscal impact study for the Phase 1 Services of redesign, and we are working intensively with the identified actuary to confirm the scope of work and execute a contract in the next few weeks so that they can begin their work. We appreciate your patience as we have focused on this multi-step process. It is important to remember that the services of focus in phase 1 were chosen intentionally to support amelioration of the state psychiatric hospital bed crisis and support existing services in expanding, and are largely evidence-based (MST, FFT) or standard services (PHP/IOP) with nationally recognized standards that define their practice (e.g. PACT). As we have discussed, we plan to launch those service-specific groups as soon as possible so that stakeholders can be actively involved as we bring these services online. Also note, no existing services are proposed to “go away” in this phase, though crisis services will represent a new array (e.g. mobile, residential, observation, details TBD in workgroup). We also know that the Finance/Business Model Planning group is of central importance and we will prioritize that workgroup’s initiation. When the workgroups are up and running we will facilitate communication to the actuary about considerations in the study process.” Our concerns continue to be:
  • This is a huge undertaking, which will be complex and costly on many levels, and they are attempting to accomplish it on too short a timeline, and
  • The proposal, description, cost/funding source and all the details in between for all of the services projected through Phase 4 will need to be part of the proposal to the General Assembly for approval in the 2020 Session as they will all be part of the FY20-22 Biennial Budget.  The Budget Language from the 2019 Session is fairly clear:
Item #303

YYY.1. The Department of Medical Assistance Services shall work with the Department of Behavioral Health and Developmental Services and stakeholders to develop the continuum of evidence-based, trauma-informed, and cost-effective mental health services recommended by the University of Colorado Farley Center for Health Policy that will result in the best outcomes for Medicaid and FAMIS members. This continuum shall include community mental health rehabilitation services (including early intervention services) and integrated behavioral health in primary care and school settings.

2. The department shall develop the necessary waiver(s) and the State Plan amendments under Titles XIX and XXI of the Social Security Act to fulfill this item, including but not limited to, changes to the medical necessity criteria, services covered, provider qualifications, and reimbursement methodologies and rates for Community Mental Health and Rehabilitation Services. The department shall work with its contractors, the Department of Behavioral Health and Developmental Services, and appropriate stakeholders to develop service definitions, utilization review criteria, provider qualifications, and rates and reimbursement methodologies. The department shall also work with its actuary to model the fiscal impact of the proposed continuum.

3. Prior to the submission of any state plan amendment or waivers to implement these changes, the Department of Medical Assistance Services and Department of Behavioral Health and Developmental Services shall submit a plan detailing the changes in provider rates, new services added and any other programmatic or cost changes to the Chairmen of the House Appropriations and Senate Finance Committees. The departments shall submit this report no later than December 1, 2019.

4. Upon approval of the 2020 General Assembly and the federal Centers for Medicare and Medicaid Services, the department shall have authority to implement these changes.