Today’s Medicaid Council meeting was overwhelming – DSS has made a lot of very detailed decisions about how to structure and finance the Integrated Care Organization (ICO) proposal for dual eligibles and outlined them in 45 complex slides at the meeting which were not made available at the time. After the meeting, Comm. Bremby stated that nothing is set in stone and the department will be open to comment from stakeholders and the public in revising any of those decisions. Advocates will have an opportunity to comment beyond today’s meeting, by email/letter or in the ABD Committee meeting. DSS expects to have three to six ICOs (similar to Accountable Care Organizations) available for consumers to join voluntarily, however a decision has not been made about whether clients will be defaulted into the ICOs with an opportunity to opt-out, or will have to affirmatively sign up to join. ICOs are consortiums of providers across the care continuum that will be paid on a fee-for-service basis but may also share in any savings from expected costs for their patients. Initial concerns include very detailed expectations for these Medicaid ICOs that may not be compatible with ACO development in the rest of CT’s market. If Medicaid has very different standards and requirements than other payers in the state, it is not clear that there will be enough incentive for potential ICOs to create something new from scratch just for this population. Medicaid has not traditionally been an attractive business for providers or insurers in CT. Concerns were also raised by the description of how shared savings will be identified – it is critical that each ICO’s financial gains be tied to their own performance and not contingent on others in the state also saving money to access any federal savings. Continuing payment of Medicaid and Medicare through separate systems could be problematic and encourage cost shifting or fragmentation. Use of the Medicare Advantage SNP risk adjustment methodology to identify expected costs for each patient also raises concerns. We’ll have more details as we get them.
In very good news, the department has agreed to remove the unnecessary and intimidating Freedom of Information clause from PCCM provider contracts, removing a large barrier to participation in the program. DSS committed to creating an open, respectful public input process in the next few months to develop the new person-centered medical home/ASO program. They will also be developing a physician advisory process. They have received nine letters of intent to bid in response to the RFP. They received three hundred questions in response to the RFP, including some from this advocate, but responses to the questions have been delayed. DSS intends for DMHAS to take a lead role in developing health homes for consumers with behavioral health conditions.