A CALL TO ACTIONPROVIDERS
KEEP INDEPENDENT LICENSED BEHAVIORAL HEALTH
IN OUR COMMUNITIES!
The careful, planned development of the independent licensed behavioral
health provider status in our state was an evolution of the System of Care
that we have made available to children, individuals and families. It
promotes choice, regard for preferences related to proximity and culture,
supports small businesses and local communities, elevates recognized
leaders in this health care field and gives them an opportunity to stand on
their own capabilities. Individuals and families needing behavioral health
services for a child with troubling mental health issues resoundingly support
access to independent behavioral health providers of their choice. Primary
care physicians, psychiatrists, psychologists and health clinics often have
independent licensed behavioral health providers working collaboratively with
them in their practices.
The proposed change, which was introduced to the OHCA Behavioral Health
Advisory Committee on 1-12 or 1-13 (it was a closed meeting), the Medical
Advisory Committee on 1-21 (which was met with a 10-10 split on approval),
and that will be presented on February 11th at OHCA Board Meeting, if
approved, will go into effect soon after approval by the governor, anticipated
to be that day. This proposal is not about saving money. It may save some
money in the first few months by restricting access to services. It will instead
drive dollars to agencies and likely hospitalization for many of the children
whose support will be severed as a result of the rule. The importance of the
relationship between therapist and child will be disregarded, as if an
insignificant aspect of treatment. More dollars will go to the children with
higher needs, some children will be hospitalized, and the less distressed will
be unserved and become more distressed until they reach a level of need to
justify services. The move by ODMHSAS is a short-sighted opportunistic one
designed to eliminate choices in order to secure the continued utilization of
CMHCs as the default providers throughout the state. Collaterally, it is also
likely to move hundreds of children into private outpatient agencies as well.
A few concerns regarding the conflict of interest that exists with ODMHSAS
overseeing these changes are as follows:
1. The primary function of ODMHSAS has been, since the early 1980's, to
oversee the operations of it's community mental health centers. Only in the
last ten years has it's reach included the Prior Authorization for services for all
clients, including all outpatient services funded by OHCA (Medicaid). Even
more recently, ODMHAS took over the state match for Medicaid and now
oversees the budget for all Medicaid dollars spent on mental health. More
recently still, ODMHSAS began being the accrediting body for providers of
mental health services. The organizational culture of the agency has stayed
the same with the interests of it's community mental health centers
continuing to be given blatant preference over private providers and other
public agencies funded through Medicaid.
2. Last year, a large federal grant was issued to ODMHSAS in which Medicaid
dollars were matched with state dollars at a very small initial match ratio,
though this will shift over the next few years to a significant state
contribution. Virtually all community mental health centers worked for years
to prepare for this shift in services, and received state dollars to support their
efforts. All are now Health Home providers, along with a few other agencies
that have adopted the model. The grant is now in full swing, with major
Medicaid dollars going to support the "Health Home" model. In this a child
with serious emotional disturbance "chooses" a mental health agency to be
their HEALTH HOME! What it also means is that every child determined to be
seriously emotionally disturbed is part of a group that is funded on a
substantial per person per month payment, NOT TO PROVIDE ANY THERAPY,
BUT TO PROVIDE EXTENSIVE CASE MANAGEMENT SUPPORTS (I believe it is
approximately 8 hours per month). The thousands of children considered
seriously emotionally disturbed, who will be displaced when their therapists
are no longer able to provide services for them, will be notified of the
"Health Home" providers available to continue providing services for them.
The state will then begin paying these providers a per member per month
payment and the therapy services provided will be a cost in addition to this
payment. This is not an insignificant "slight of hand". It is an obvious
increase in costs rather than a savings for these children and it is a total
disregard for client choice in the matter.
3. Additionally, a few years ago ODMHSAS arranged a very beneficial matching
grant with the Centers for Medicaid/Medicare which provided again matching
dollars for the demonstration of improved services in the community mental
health centers. Millions of "bonus" dollars are distributed each year to the
community mental health centers by Medicaid, based upon the numbers of
Medicaid clients served. This rule change to “save money” will unquestionably
drive hundreds, or thousands of children from private providers into
community mental health centers, again increasing the funding for them,
while the stated intent is to save money.
None of the above concerns regarding the "reach" of ODMHSAS is necessarily
critical of the actions of ODMHSAS in taking these steps, if the result is a more
responsive system of care for persons served. This action has been taken,
though, without transparency and forces attention to the Conflicts of
Interests that have become inherent in an agency that is both a provider and
overseer of a much broader system of services.
As the managing partner of an outpatient agency that stands to benefit from
this rule change, I could remain quiet and accept all of this as a positive in
terms of "reducing competition". Instead I consider the still unmet needs of so
many desperate individuals and families, the collapsing infrastructure of the
health, social and educational supports to economically distressed citizens and
have to appeal for continued expansion of access rather than restricting it.
Other measures, such as reducing the caps on levels of care and reducing
individual sessions to 1.0 hours and family sessions to 1.5 hours could likely
account for a major reduction in funding. Once again, though, providers will
bear the burden of the state's unwillingness to support it's healthcare system.
The focus must be on informing the legislature that their constituents pay
taxes not only to fix what is broken, but to establish an infrastructure to
support the future, which based upon increasing mental health disorders will
be further burdened by a population that does not complete high school, has
high health care costs (including substance abuse and mental health related
costs), lives with domestic violence, places inordinate numbers of children out
of their homes in child welfare custody and continues to have the highest
incarceration rate of any place in the world. Alicia Lieberman in her work
"From Cradle to Prison Pipeline" points out that addressing mental health
issues in children reduces dropout rates, incarceration, and many other
inter-related personal and social ills. What we do for children today is an
investment for future savings to the state. Without access to services, this
situation only worsens.
Richard DeSirey, MS, LPC
Managing Partner
A New Way Center