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States Are Increasing their Use of Medicaid Managed Care for Children and Youth with Special Health Care Needs
/in Medicaid Managed Care Care Coordination, Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, Chronic Disease Prevention and Management, Cost, Payment, and Delivery Reform, Eligibility and Enrollment, Maternal, Child, and Adolescent Health, Medicaid Managed Care, Population Health, Program Design, Special Populations and Services /by Olivia Randi and Kate HonsbergerA new, 50-state analysis of Medicaid managed care programs by the National Academy for State Health Policy (NASHP) shows that in the past three years, state Medicaid managed care (MMC) programs have:
- Enrolled more children and youth with special health care needs (CYSHCN);
- Provided more services to them through managed care; and
- Launched more specialized initiatives serving CYSHCN in managed care.
These trends deviate from past approaches as, historically CYSHCN have often been exempt from MMC due to the complexity of their needs. CYSHCN represent nearly 20 percent of children younger than age 19 and have chronic and/or complex care needs that require physical and behavioral health care services beyond what children normally require.[1] As states become more proficient in developing MMC programs, they are increasingly incorporating CYSHCN into their program designs in an effort to improve quality and reduce costs.
NASHP has updated a 50-state chart and map, originally published in 2017, highlighting new developments in states’ MMC programs that serve CYSHCN.[2] The 2017 analysis found that 47 states use some form of MMC (risk-based, primary care case management, and prepaid health plans) to serve CYSHCN, a figure that remains true in 2020, with the same number of states and Washington, DC continuing to use MMC to serve some or all CYSHCN.
NASHP’s new analysis found a downward trend in traditional fee-for-service (FFS) models and a shift toward innovative delivery systems. Given that 47 percent of CYSHCN are covered by Medicaid, this analysis provides important insight into how states are designing services to meet the unique needs of CYSHCN.[3]
The use of managed care delivery systems is widespread, with states contracting with managed care organizations (MCOs), which are paid on a per-member, per-month basis, to provide services for people enrolled in Medicaid. Thirty-eight states use a risk-based model to serve CYSHCN, in which the MCO assumes the financial risk. Ten states use a primary care case management (PCCM) model in which states contract directly with primary care providers and pay them a case management fee for each enrollee’s care coordination, and three states have a prepaid health plan (PHP) through which health plans are paid per-member, per-month for a limited set of services.
In this new analysis, NASHP identified several key trends among the 47 states and Washington, DC that use MMC to serve CYSHCN, such as the use of specialized MMC plans, MMC enrollment policies for CYSHCN, behavioral health service delivery systems, and quality assessment standards for CYSHCN.
MMC Contract Language for CYSHCN
Since 2017, six states have added a specific definition of CYSHCN to their managed care contracts – 29 states now clearly describe this population of children within their MMC program. Including a definition of CYSHCN in a managed care contract can support identification of CYSHCN and can be used to determine eligibility for specific services and supports. Some states align their definitions with the federal Maternal and Child Health Bureau, Health Resources and Services Administration definition, while others are based on specific health conditions or Medicaid enrollment categories (e.g., children enrolled in Medicaid through the aged, blind, and disabled eligibility category).[4]
More states are also evaluating the quality of care that MCOs provide to CYSHCN using measures that account for their unique needs, as compared to 2017. States are required by federal Medicaid regulations to develop a quality assessment and improvement strategy and to contract with an external organization to evaluate the quality of care provided by their MCOs. In addition to meeting these regulations, 39 states now include specific language in their contract regarding measuring quality of care provided to CYSHCN through MMC delivery systems, an increase of seven states since 2017.
MMC Enrollment Policies for CYSHCN
CYSHCN may be eligible for Medicaid coverage through specific pathways to coverage, including those who are eligible for Medicaid’s aged, blind, and disabled (ABD) category, those receiving Social Security Income (SSI), and those who are enrolled in foster care or who are receiving adoption assistance. Additional subcategories of CYSHCN who may be enrolled in Medicaid include American Indian/Alaskan Native (AI/AN) children, those enrolled in Medicaid home- and community-based service 1915(c) waiver programs, and those enrolled in state Title V CYSHCN programs. States are increasingly mandatorily and voluntarily enrolling these subpopulations into MMC. The majority of states continue to enroll children that are eligible for Medicaid through ABD, SSI and youth in foster care or receiving adoption assistance in managed care. Over the past three years, the number of states that enroll AI/AN children and those enrolled in 1915(c) waiver programs has increased by more than 10 for each subgroup. Together, these trends may point to an increased understanding among state Medicaid programs of the diverse needs among CYSHCN subgroups.
Specialized MMC Plans for CYSHCN
Several states have developed specialized managed care plans to meet the unique needs of CYSHCN or subgroups. These plans typically offer tailored benefits that are often not available through their standard MMC plan. The number of states that have specialized MMC plans for CYSHCN has nearly doubled over the last three years.
- Thirteen states (DC, FL, GA, IL, IN, ND, TN, TX, UT, VA, WA, WI, and WV) operate 12 specialized health care plans to serve some or all CYSHCN, an increase of six states since 2017.
- Nine states’ (DC, GA, IL, IN, TN, TX, WA, WI, and WV) specialized plans serve youth in foster care and/or receiving adoption assistance, representing over half of the specialized MMC plans. In 2017, only two such plans existed.
- Six states (DC, IN, ND, TX, UT, and VA) have specialized plans that serve children who are eligible for Medicaid through the ABD category.
- Five states (ND, TN, TX, VA, and WV) enroll children who are enrolled in 1915(c) waiver programs in their specialized plans.
Behavioral Health Service Delivery for CYSHCN
States have historically been more likely to carve behavioral health services out of their MMC plans and deliver these services through distinct behavioral health organizations (BHO) or through FFS arrangements. As more states are shifting to integrate behavioral health and primary care services, they are increasingly providing behavioral health services through their MCOs. As of 2020, 41 states provide behavioral health services through MMC, an increase of eight states since 2017. Six states continue to provide behavioral health services through carve-out FFS and BHO arrangements.
Table 1: States’ MMC Program Design: 2017 – 2020
The table below summarizes key trends across states’ Medicaid managed care programs that serve CYSHCN, such as increases in the number of states that enroll CYSHCN in MMC, offer specialized health care plans that serve CYSHCN, and integrate behavioral health services with primary care for CYSHCN. These and other insights can be found in NASHP’s updated 50-State Chart and Map.
| Feature | Number of States – 2017 | Trend | Number of States – 2020 |
| Contract language | |||
| Contract provides a clear definition of CYSHCN | 23 | ↑ | 29 |
| Specific quality measures for CYSHCN | 32 | ↑ | 39 |
| Subpopulation enrollment in MMC (mandatory or voluntary for at least one plan) | |||
| Aged, blind, and disabled | 40 | ↑ | 42 |
| American Indian/Alaskan Native | 22 | ↑ | 36 |
| Foster care youth/adoption assistance | 39 | ↑ | 46 |
| Social Security Income (SSI) | 20 | ↑ | 33 |
| Title V CYSHCN | 14 | ↑ | 17 |
| 1915(c) | 14 | ↑ | 25 |
| Specialized plans for CYSHCN* | |||
| Total states with specialized plans | 7 | ↑ | 13 |
| Includes aged, blind, and disabled | 3 | ↑ | 6 |
| Includes youth in foster care/adoption assistance | 2 | ↑ | 9 |
| Includes Social Security Income | 2 | ↑ | 3 |
| Includes CYSHCN | 2 | —- | 2 |
| Includes Title V CYSHCN | 1 | ↓ | 0 |
| Includes 1915(c) | 2 | ↑ | 5 |
| Behavioral health service delivery system for CYSHCN** | |||
| MCO provides behavioral health services | 33 | ↑ | 41 |
| Behavioral health services are carved-out into FFS | 7 | ↓ | 6 |
| Behavioral health services are carved-out of managed care and provided by a behavioral health organization | 8 | ↓ | 6 |
*Specialized plans may include more than one subpopulation.
**Some states use more than one approach to provide behavioral health services.
Notes
[1] Children with Special Health Care Needs.” Maternal and Child Health Bureau, December 17, 2019. https://mchb.hrsa.gov/maternal-child-health-topics/children-and-youth-special-health-needs.
[2] See NASHP’s 2017 chart and map here: https://www.oldsite.nashp.org/state-medicaid-managed-care-program-design-for-children-and-youth-with-special-health-care-needs/
[3] MaryBeth Musumeci and Priya Chidambaram, How Do Medicaid/CHIP Children with Special Health Care Needs Differ from Those with Private Insurance? (Menlo Park, CA: Kaiser Family Foundation, June 2019). https://www.kff.org/medicaid/issue-brief/how-do-medicaid-chip-children-with-special-health-care-needs-differ-from-those-with-private-insurance/
[4] Children with Special Health Care Needs.” Maternal and Child Health Bureau, December 17, 2019. https://mchb.hrsa.gov/maternal-child-health-topics/children-and-youth-special-health-needs
State Roles in Preventing and Improving Foster Care Placements for Children with Medical Complexity
/in Policy Featured News Home, Reports Care Coordination, Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, Integrated Care for Children, Maternal, Child, and Adolescent Health, Physical and Behavioral Health Integration /by Catherine HessChildren with medical complexity (CMC) generally require intensive family support and high-cost health care services – needs that may lead to out-of-home placement when they are not available or affordable. The Family First Prevention Services Act of 2018 offers resources to transform state foster care systems to emphasize prevention – and when necessary placement in a foster care home rather than an institution.[1] CMC could benefit if states applied its goals to improve foster care prevention and placement options for CMC. Medicaid and Title V services also can help keep CMC at home. This report explores how states can leverage federal and state policy tools to improve options for CMC in or at risk of foster care placement.
Background
Children with medical complexity have substantial needs for health care, which can have major impacts on their families’ well-being.[2] Making up fewer than than 1 percent of all US children,[3] CMC are a subset of children and youth with special health care needs. CMC are generally defined as children who are medically fragile and have substantial functional limitations, as well as increased needs for and costs of health care services.[4]
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CMC are generally defined as children who are medically fragile and have substantial functional limitations, as well as increased needs for and costs of health care services. |
Roughly two-thirds of CMC are enrolled in Medicaid,[5] and according to one recent study, they account for over one-third of Medicaid costs for children’s health care. Yet, services that CMC or their families need may not be covered or not covered adequately by private or public insurance.[6] Families must devote considerable time and energy to caring for their CMC and coordinating the many services the children need. These demands can take a toll on families’ finances, health, and well-being. For some families, the demands of caring for their CMC may be beyond their resources or capabilities, especially when community-based supports are inadequate, resulting in some CMC entering the foster care system.[7] While the numbers of CMC that are placed in foster care is unknown, given their needs and the strain on their families, they appear to be a population at significant risk for out-of-home placements.
State child welfare, Medicaid, and Title V Maternal and Child Health/Children and Youth with Special Health Care Needs (MCH/CYSHCN) officials have opportunities to collaborate to transform options for preventing out of home placement of CMC or for providing family-centered options when placement outside the home cannot be avoided. Title V CYSHCN programs have expertise in the needs of CMC and working with their families, and Medicaid programs have a number of state options to help families care for children at home.
In the child welfare domain, consistent with the 1999 Supreme Court’s Olmsted decision[8] and subsequent deinstitutionalization movements, the Family First Prevention Services Act of 2018 provides impetus, requirements, and resources to transform state foster care systems to emphasize prevention and when necessary, placement in a foster care home rather than an institution.[9] While not addressed explicitly in the law, CMC could benefit if its goals are applied to improve prevention and placement options for this unique population of children.
Overview of CMC in the Foster Care System
CMC in the foster care system have not received extensive research or policy attention, despite the intensity of their needs and their high health care and support costs for families and child welfare and health care systems. Data on CMC in the foster care system is quite limited. Nationally, an estimated 20,000 to 40,000, or about 5 to 10 percent, of all children in foster care have medical complexities.[10] The national Adoption and Foster Care Analysis and Reporting System (AFCARS) requires state child welfare agencies to submit data on special needs status, but states vary on how they define this term – some states include such factors as race and age, and not just disability or medical condition.[11] The limited Information about CMC and foster care includes a lack of data documenting the reasons and circumstances under which they are placed in foster care. Some CMC are placed in the system because their medical needs have outstripped their families’ capabilities, resources, and the supports available to them. Some CMC are placed primarily for reasons of abuse or neglect, and some may result from a combination of these reasons.[12]
While the provision of comprehensive community-based systems, services, and supports could arguably better enable families to provide an appropriate level of care for their children, thereby allowing the children to remain in the home, these services are typically limited or may not be available preventively. CMC and foster care expert Rebecca Seltzer, assistant professor of pediatrics at Johns Hopkins School of Medicine, noted, “If the added layer of supports provided to [medical foster care] parents were offered to biological parents struggling to care for their child’s medical needs, then perhaps placement into foster care could be avoided for some of these children. While state policies vary in regard to voluntary placement agreements, such provision of upfront resources and supports may be particularly relevant to assist families that feel the only way to adequately care for their child is to give them up voluntarily.”[13] In the context of very strained budgets in 2020 due to the effects of COVID-19, state resources to improve these services are expected to be even harder to come by.
Most foster care placements are court-ordered. Overall, only about 3 percent of all foster care children are placed through voluntary agreements between child welfare agencies and parents. Voluntary placements are more likely than court-ordered placements to be among children with disabilities, with the majority of placements related to disabilities for behavioral health issues. Voluntary placements also are more likely than court-ordered placements to be in group homes or institutions rather than in foster homes.[14]
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“If the added layer of supports provided to [medical foster care] parents were offered to biological parents struggling to care for their child’s medical needs, then perhaps placement into foster care could be avoided for some of these children. While state policies vary in regard to voluntary placement agreements, such provision of upfront resources and supports may be particularly relevant to assist families that feel the only way to adequately care for their child is to give them up voluntarily.”— Rebecca Seltzer, assistant professor of pediatrics, John Hopkins School of Medicine |
Challenges in providing quality foster care homes can be multiplied for CMC, and there is limited information on children’s outcomes. Fragmentation of care and financing, and lack of coordination across multiple agencies and providers are issues.[15] Recruiting, training and supporting foster parents to meet the specialized care needs of CMC add to the general challenges of engaging foster families.[16] Medical decision making can be more complex given the number of those involved – multiple public agencies, health care providers along with biological and foster parents – as well as regulations that may restrict information sharing. Compounding placement issues, transitioning CMC back to their biological homes or to an adoptive family is more of a challenge than for children without medical complexity.[17] An analysis of 2014 AFCARs data found poorer placement outcomes for children with disabilities, with the number of disabilities increasing the odds of poor outcomes in areas such as length of stay, placement stability, and permanency.[18]
State Approaches to Preventing and Providing Foster Care Placements for CMC
Many states and state-based organizations have developed tailored approaches to preventing or improving placements for CMC in foster care. Care coordination, case management, respite care, and home health services are among the prevention services provided by the health sector, which may be funded by Medicaid, Title V Children and Youth with Special Health Care Needs (CYSHCN), or exclusively state funded programs. When CMC are placed in foster care, placements tailored to their needs generally fall within the rubrics of therapeutic or treatment foster care (TFC), and more specifically medical foster care (MFC), although there are no standard definitions of these terms across states or at the federal level.
CMC researchers have noted that specialized foster homes serving CMC may encompass “variable terms [to] designate medical foster care placements, including ‘intensive,’ ‘exceptional,’ specialized,’ ‘special needs,’ ‘handicapped, ‘therapeutic,’ ‘medically complex,’ and ‘medically fragile.’ Some states do not distinguish children with medical needs but group them with children with mental or behavioral health needs into ‘therapeutic foster care.’…When CMC in foster care cannot be identified by virtue of widely differing assignations, they and their health outcomes become invisible.”[19] While the services rendered in these foster care settings may be similar, the absence of a standard definition or specific designation for those specifically serving CMC further compounds the challenges for understanding, surveilling, and adequately caring for CMC.
With federal Title IVE foster care funding support, states have the flexibility to determine their own classification systems for foster care categories. Given this flexibility, placements supporting the needs of CMC have different names, requirements, and program structures. There is no national compilation of these programs. Some states adopt distinct programs whereas other states incorporate a tiered framework, with each tier corresponding to a higher acuity and thus greater need and level of care. Other states group all children with high needs, including those with medical complexity, behavioral health, or severe trauma, into one classification. TFC and MFC are two common classifications. While many TFC programs are designed to serve children with severe mental, behavioral, or emotional needs, some also provide care for children with distinct or concurrent complex health conditions.
Funding for foster care generally and TFC or MFC more specifically is fairly complex and varies state by state. Foster care is administered at the state level by child welfare agencies which administer Title IVE federal foster care funds as well as state appropriated funds. Federal Title IVE financing is available for children who are in the custody of these agencies, and generally has paid for care and supervision. Treatment costs for children in the custody of child welfare agencies are generally paid by Medicaid, as these children automatically qualify. Other children not in state custody who receive services from child welfare agencies also may qualify for Medicaid on the basis of their income levels or their disability status. Although Medicaid’s Early, Periodic, Screening, Diagnostic and Treatment program provides some consistency in benefits for children, there is some variation across states, in part due to varying definitions of medical necessity.[20] Other funding sources include other state agency funds, such as for behavioral health. That resources are often not sufficient is highlighted by a recent state level lawsuit seeking to improve public support for in-home services for CMC.[21]
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Federal Title IVE financing is available for children who are in the custody of these agencies, and generally has paid for care and supervision. Treatment costs for children in the custody of child welfare agencies are generally paid for by Medicaid, as these children automatically qualify. |
Given the variations in terminology for CMC and for their foster care placements, understanding how states across the country are approaching services for this small but growing population is challenging without more in depth research. Florida is featured here as an example of a coordinated interagency approach to CMC placement in foster family homes.
State Medical Foster Care Programs: Florida’s Interagency Approach
Florida has a Medical Foster Care (MFC) program coordinated by the state’s Medicaid agency (Agency for Health Care Administration – AHCA), the Department of Health Office of Children’s Medical Services Managed Care Plan and Specialty Programs (DOH-CMS), which includes its Title V Children and Youth with Special Health Care Needs program, the Child Welfare (Department of Children and Families-DCF) state agency, and the local non-profit community-based care (CBC) programs with which DCF contracts. The CBC lead agencies work to manage and deliver child welfare services in Florida.
To be eligible for Florida’s MFC program, children must be younger than age 21, in the foster care system, and have complex medical needs. Medical necessity for program eligibility and medical stability – capable of receiving care in a home setting – is determined by a Children’s Multidisciplinary Assessment Team (CMAT) facilitated by DOH-CMS. The CMAT is comprised of a medical director, registered nurse, a social worker, and representatives from the DOH-CMS Early Steps program (for children under age 3), the Agency for Persons with Disabilities (APD), the child’s Managed Medical Assistance (MMA) plan, as well as the child’s CBC and legal guardian.
Children in Florida’s MFC program may have conditions such as:
- Complications of prematurity (respiratory problems, feeding problems, apnea);
- Chronic problems, such as asthma or diabetes, that require stabilization, monitoring or medication maintenance;
- G-tubes with little or no nutrition by mouth;
- Potential life-threatening illnesses such as HIV/AIDS, cancer, cystic fibrosis, or sickle cell anemia;
- Medical problems resulting from abuse or neglect (burns, fractures, shaken baby syndrome); and,
- Newborn drug exposure and requirements for medication or treatment.[i]
In 2018, Medicaid services for the 300 children in Florida’s Medical Foster Care Program were transitioned from fee-for-service to statewide Medicaid managed care, with the health plans taking on some roles previously carried out by DOH-CMS. Health plans now are responsible for the children’s plans of care, care coordination, and medical services. The DOH-CMS MFC team provides oversight of the medical foster parents to ensure quality and safety, child-specific training, meeting annual education requirements, home and community visits as well as reviews of care and documentation. DOH-CMS notes that the transition to Medicaid managed care required significant attention to determining the roles of DOH-CMS and the MMA plans, and a solid change management plan. State and local agency partners now have regular calls for ongoing communication and coordination.[ii]
MFC foster parents must meet a number of conditions to be eligible for enrollment in the program. They must be licensed by DCF, complete competency-based training through DOH-CMS, enroll as Medicaid providers, and be credentialled through the MMA plans. These foster parents receive rates through DCF for board and care of the children, and daily rates from MMA plans for medical services provided. The rates vary by the level of care (1-3) that the children require, as determined by the CMAT.
What Services Do Florida Medical Foster Care Parents Provide?
- Implement the child’s individualized plan of care, including administration of medications and interventions, and attendance at all medical, developmental and therapeutic appointments.
- Provide a home environment.
- Monitor or complete usual activities of daily living including:
- Personal hygiene: Assist the child with bathing, grooming, oral, nail and hair care;
- Continence management: Assist a child who may not be mentally and physically able to properly use the bathroom;
- Dressing: Assist the child in selecting and putting on clothes;
- Feeding: Assist with self-feeding or other feeding needs as ordered; and
- Ambulating: Assist a child’s ability to change from one position to the other and to walk independently.
- Provide transportation and shopping.
- Plan and prepare meals.
- Manage medications: Keep medications up to date and assure taking meds on time and in the right dosages.
- Advocacy: Make dependency court appearances as necessary to address the status of the child.[iii]
State Programs that Support Families in Keeping CMC at Home
While the research for this brief did not identify state-level policies or programs explicitly designed to prevent out-of-home foster care placement for CMC, there are state policies and programs in place designed to provide or finance services that support families to keep their CYSHCN at home. Such services, especially where they reach families of CMC, presumably would help prevent the need for out-of-home placement for many of these children.
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Medicaid finances many of the services that help support families of CYSHCN to keep their children at home. |
Through a number of state options or waivers, Medicaid finances many of the services that help support families of CYSHCN in keeping their children at home. All but one state (Tennessee) have adopted the “Katie Beckett” Medicaid waiver or state plan option to cover care at home for children who would otherwise need an institutional level of care.[i] Eligibility is based solely on the child’s – not the family’s – income. Comparable coverage also is being provided by five states through the Family Opportunity Act state plan option, which requires Supplemental Security Income eligibility, but not institutional-level of care requirements.[ii] Eighteen states have Medicaid Home- and Community-Based Waivers that target children who are medically fragile or technology dependent and cover medical and other services, such as respite care. These programs serve state-determined numbers of people in need, and often have waiting lists.[iii] Fourteen states provide long-term services and supports to qualifying CYSHCN through their Medicaid managed care programs.[iv]
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A new State Plan option for Health Homes designed specifically for medically complex children was added by the Medicaid Services Investment and Accountability Act of 2019 (MSIA). |
The Affordable Care Act included a state option for Medicaid Health Homes benefits for individuals with chronic conditions, including mental illness, although many states have targeted this benefit to conditions primarily affecting adults.[v] A new state plan option for health homes designed specifically for medically complex children was added by the Medicaid Services Investment and Accountability Act of 2019 (MSIA), but is not effective until Oct. 1, 2022.[vi]
In addition to providing expertise regarding CMC, state Title V MCH and CYSHCN programs offer resources and services to support family-centered care, care coordination, and address social determinants of health (SDOH). Social determinants, such as housing, food and social needs, may be factors affecting whether CMC may need an out-of-home placement.
Georgia’s Childkind Prevention Services, Part of the State’s Child Welfare System
Childkind’s prevention program surfaced in NASHP’s research as an example of child welfare services specifically designed to prevent out-of-home placement – other programs like it may exist in other states as well. Childkind, a nonprofit agency founded in 1988 to serve children with HIV/AIDs, later expanded to serve all children with complex medical challenges, and in 2010 implemented its Home-Based Services with the “goal of preventing avoidable medical neglect and keeping children out of the foster care system.” Childkind provides in-home training and supports for families, in addition to providing placement services.[i]
Childkind reports that most of the families it works with are living well below the poverty line. They are most often referred by pediatric specialists or by the state Division of Family and Child Services (DFCS). The agency works with them for four-to-six months, or sometimes longer. The program focuses not just on “the ability to handle g-tube feedings, trach suctioning, equipment, medications, and the like, we also want to make sure they understand the diagnosis itself and the impact it has on all aspects of family life. From there we look at all of the barriers to success – lack of bonding, no community or personal support, and service navigation, eventually teaching the parents to become their own case managers and care coordinators.”[ii]
Childkind is funded by a mix of federal and state programs and private sources. These include federal Promoting Safe and Stable Families (Title IV-B) grant funds, which Childkind matches with private donations, a DFCS contract for placement services, and a DFCS grant for prevention services. Childkind’s executive director notes that managing the various funding sources is challenging given differing requirements and restrictions.
Childkind is a Medicaid provider for some disability-related services for children aging out of foster care, but its home-based services are not Medicaid reimbursable. At Childkind’s request, Georgia Medicaid analyzed claims data for 56 home-based services program participants selected by Childkind and determined that, “Childkind achieved a significant impact on the total Medicaid claims paid for these children from FY13 to FY15. The average per member per month (PMPM) cost (on an incurred basis) for FY13 was $4,880.37, while the PMPM for FY15 is $2,508.78. This represents a decrease of 49 percent.” This decline compared to a 22 percent drop in the same time period for a comparison group matched on age and aid category, but not condition.[iii]
Two other evaluations were conducted to assess outcomes for children who graduated from the program:
- One evaluation found that for 40 technology-dependent children referred by pediatric hospitals, post discharge inpatient days were down 70 percent and patient charges were down 69 percent.
- Another study of 135 children who were referred to Childkind by DFCS found that one year after program graduation, 77 percent of families participating in Childkind’s Take Charge model of home-based services did not require DFCS intervention, compared with 46 percent of non-participating families. Just 3 percent of children whose families participated in the program were placed in foster care, while 12 percent of children whose families did not participate were placed in foster care.[iv]
The Family First Prevention Services Act: Moving Child Welfare Systems toward Home- and Community-Based Care
Enacted in 2018, the Family First Prevention Services Act (Family First) was designed to transform state foster care systems by shifting federal funding to prevention of out-of-home placement, or when necessary, to foster family homes over congregate care. In recognition of the state work in preparing for implementation of the new law, the Family First Transition Act was passed at the end of 2019, providing $500 million in grants to assist states in implementation, as well as some modifications in the law’s requirements. Importantly, the law phases in the evidence based requirements that states have found challenging.[i]
Family First focuses strongly on the needs of children with behavioral health issues, and particularly at this early point in implementation, it is unclear how much the shift in funding and services will address the specific needs of CMC. Once states have a plan approved by the federal Children’s Bureau in the Administration for Children and Families, they can use Title IVE funds for mental health and substance abuse prevention and treatment services, and for in-home, parent skill-based programs to prevent placement in the foster care system. Family First also seeks to move children who are placed in the foster care system from congregate or group care settings to foster family homes. With some exceptions that generally are not relevant to CMC, states will be reimbursed only for two-week stays in group care. As of publication, 15 jurisdictions had submitted plans, and six had been approved.[ii]
Prevention services funded through Title IVE pursuant to Family First must meet several conditions. Children must be “candidates for foster care” as defined by states and within federal guidelines. Importantly, the services must be evidence based, as reviewed and approved by the Title IVE Prevention Services Clearinghouse established through Family First. As of April 1, 2020, 25 programs have been reviewed and the results published by the clearinghouse. Federal reimbursement is available for up to 12 months of prevention services.[iii]
Georgia may incorporate Childkind’s Take Charge! Medically-Based Parenting program in its Family First Title IVE plan if the program is included in the federal Title IVE Prevention Services Clearinghouse. Following its public call for submissions, Georgia’s DFCS submitted this Childkind program to the clearinghouse for review and inclusion as an in-home, parent skill-based program. As of publication, Childkind’s program had not yet been reviewed. Georgia was developing its plan for submission with a planned implementation date of October 2021.
[i] “Family First Prevention Services Act.” National Conference of State Legislatures. April 1, 2020. https://www.ncsl.org/research/human-services/family-first-prevention-services-act-ffpsa.aspx#over
[ii] “Status of Submitted Title IV-E Prevention Program Five-Year Plans.”Children’s Bureau, Administration for Children and Families, U.S. Department of Health and Human Services. September 7, 2020.
https://www.acf.hhs.gov/cb/resource/title-iv-e-five-year-plan
[iii] “Family First Legislation.” National Conference of State Legislatures. May 20, 2020. https://www.ncsl.org/research/human-services/family-first-updates-and-new-legislation.aspx
Strategies for States and Conclusion
CMC have received inadequate attention in research and policy, especially given their growing numbers, unique and intense needs, and costs to their families and child welfare and health care systems. National attention, particularly to the need for better data on CMC and foster care, is needed.
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Supporting families in caring for CMC at home, or if not possible in specialized foster care families, also can help reduce state costs in areas such as nursing home care and hospital readmissions. |
As states focus on health care, and now, foster care transformation, this population of children and families – who have substantial needs that may lead to out-of-home placement – calls for attention. Federal resources are available to support improved care for CMC. While state budget constraints make further state investments challenging, supporting families in caring for CMC at home, or if not possible in specialized foster care families, also can help reduce state costs in areas such as nursing home care and hospital readmissions. According to one study, “Hospitalized children with CCCs [chronic complex conditions] discharged to HH [home health] experienced fewer short-term readmissions, subsequent hospitalizations, and lower hospital costs over a 12-month period than matched controls of children with similar attributes who were not discharged to HH.”[i]
With supports, many families of CMC can successfully care for their children at home and for those unable to do so, placement in medical or therapeutic foster care can be an option but requires specialized training and support for foster families. Given the high costs of CMC care and state responsibility for much of those costs, it is important for states to assure cost-effective care that optimizes outcomes for CMC and their families.
Given different but complementary knowledge, resources, and authorities, it is important that state agencies and programs collaborate to develop, finance, maintain, and improve services that prevent and provide out of home placements for CMC. State agencies responsible for Medicaid, Child Welfare, and Title V Maternal and Child Health/Children with Special Health Care Needs programs each have something they could contribute to address these needss. There are multiple Medicaid options and waivers that can support families in providing care for CMC at home, including the new Health Homes 1945A option to establish Health Homes for CMC specifically. State Title V CYSHCN programs may offer or help to arrange services, including for children who are not eligible for Medicaid. Title V MCH programs may be able to assist with strategies to address social determinants of health for these children and families, such as adequate housing that can be adapted to meet the needs of the child with medical complexity. These agencies and programs individually and together could review the options and consider which to modify, adopt and deploy to prevent, or when still needed, provide out-of-home placements for CMC. Florida provides one model of interagency collaboration in placements tailored to the specialized needs of CMC.
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State Strategies to Prevent and Improve Foster Care for CMC |
In working together to address the needs of CMC and their families, state officials could benefit in learning from and exchanging ideas with other states. Forums such as state associations and interagency convenings could support state learning and exchange in this area. An important barrier to effective exchange is the lack of common nomenclature, definitions, and data collection systems, a barrier that might be addressed by states coming together and working with federal agencies around data, as progress has already been made in areas such as quality measurement.
The Family First Prevention Services Act opens the door to more focus on preventing out-of-home placement of CMC. While much of the focus in the law is on addressing the behavioral health needs of children, it can create momentum for examining and improving how all children, including CMC, can be better served by the system. A starting point is interagency consultation on the state-developed definition of “candidate for foster care,” to ensure that it enables, if not specifies, inclusion of CMC. This definition is one of the conditions for receipt of prevention services. Particularly relevant to CMC is the prevention services option of in-home parent training. Programs that offer parent training tailored to the needs of CMC might be incorporated in state Family First plans, if not now, then later, as more programs are evaluated to create the necessary evidence base, and as states’ attention shifts from immediate implementation challenges to how to use the federal goals and funding to achieve systemic improvements that benefit all of the children served.
Additional collaboration with the private sector, including health care providers, health plans, and nonprofit community agencies, can help to develop, evaluate, and sustain successful and innovative approaches to home-based and foster care services for CMC. Childkind is one example of a local nonprofit that has developed and worked, within its resources, to evaluate its effectiveness in preventing and providing out of home placements for CMC. There also are nonprofits working to address the challenges in providing high quality foster care for CMC. For example, Angels in Waiting in California recruits and trains nurses to serve as foster parents for CMC.[ii] State agencies are in position to encourage, identify, support, and evaluate innovative approaches that might be identified as evidenced based practices and brought to scale.
Conclusion
Children with medical complexity are a particularly vulnerable group of children who have unique, specialized needs, including for high cost health care services, and whose families require supports to care for their children at home and in the community. In the absence of such supports, some children who could otherwise be cared for at home are at-risk of out-of-home placement. State programs have current and newly available options and federal financing to support families in caring for CMC at home, or when that still may not be possible, in specialized foster family homes. While variation in state terminology and approaches make sharing best practices challenging, state child welfare, Medicaid, and Title V CYSHCN program officials can gain from working within and across states and with the private sector to learn from each other and improve services to prevent and to improve foster care for CMC and their families.
Notes
[1] “Family First Prevention Services Act Bill Summary.” Campaign for Children. Accessed May 18, 2020. https://campaignforchildren.org/wp-content/uploads/sites/2/2016/06/FFCC-Short-Summary-FFPSA.pdf
[2] Eyal Cohen et. al., “Patterns and Costs of Health Care Use of Children with Medical Complexity.” Pediatrics. 130, 6 (2012): 1463-1470.
[3] Jay G. Berry et al., “Children with Medical Complexity and Medicaid: Spending and Cost Savings.” Health Affairs. 33, 12 (2014): 2199-2206.
[4] Eyal Cohen et al., “Status Complexicus? The Emergence of Pediatric Complex Care.” Pediatrics. 141, S3 (2018): S202-S211.
[5] Jane Perkins and Rishi Agrawal, “Protecting Rights of Children wth Medical Complexity in An Era of Spending Reduction.” Pediatrics. 141, S3: S242-S249.
[6] Berry, et al., “Children with Medical Complexity and Medicaid”
[7] Rebecca R. Seltzer et al., “Exploring Medical Foster Care as a Placement Option for Children with Medical Complexity.” Hospital Pediatrics. 9, 9 (2019); 697-706.
[8] “Serving People with Disabilities in the Most Integrated Setting: Community Living and Olmstead.” HHS. Accessed May 18, 2020. https://www.hhs.gov/civil-rights/for-individuals/special-topics/community-living-and-olmstead/index.html
[9] “Family First Prevention Services Act Bill Summary.” Campaign for Children. Accessed May 18, 2020. https://campaignforchildren.org/wp-content/uploads/sites/2/2016/06/FFCC-Short-Summary-FFPSA.pdf
[10] Rebecca R. Seltzer, Carrie M. Henderson and Renee D. Boss, “Medical Foster Care: What Happens When Children with Medical Complexity Cannot be Cared for by Their Families?” Pediatric Research. 79, 1 (2016): 191-196.
[11] Seltzer, “Medical Foster Care”
[12] Ibid.
[13] Rebecca R.Seltzer, “Medical Foster Care for Children with Chronic Critical Illness: Identifying Strengths and Challenges.” Children and Youth Services Review. 88 (2018): 18–24.
[14] Katharine Hill, “Prevalence, Experiences, and Characteristics of Children and Youth who Enter Foster Care Through Voluntary Placement Agreements.” Children and Youth Services Review. 74 (2017): 62-70.
[15]Ibid.
[16] Seltzer, “Medical Foster Care for Children with Chronoic Critical”
[17] Ibid.
[18] Rebecca R. Seltzer, Sara B. Johnson, and Cynthia S. Minkovitz, “Medical Complexity and Placement Outcomes for Children in Foster Care.” Children and Youth Services Review. 83 (2017): 285-293.
[19] Erin P. Williams, Rebecca R. Seltzer and Renee D. Boss, “Language Matters: Identifying Medically Complex Children in Foster Care.” Pediatrics. 140, 4 (2017): e20163692.
[20] Amy Clary and Barbara Wirth, State Strategies for Defining Medical Necessity for Children and Youth with Special Health Care Needs. National Academy for State Health Policy. October 2015. https://oldsite.nashp.org/wp-content/uploads/2015/10/EPSDT.pdf
[21] “Lawsuit Filed to Improve Medicaid In-Home Services for Children with Complex Medical Needs.” National Health Law Program. Accessed May 18, 2020. https://healthlaw.org/news/lawsuit-filled-to-improve-medicaid-in-home-services-for-children-with-complex-medical-needs/?utm_source=newsletter&utm_medium=email&utm_content=Read%20more&utm_campaign=2020.03.05_CSHCN_Network_Newsletter
[22] “Medical Foster Care Services in the Statewide Medicaid Managed Care Program.” Agency for Health Care Administration. November 20, 2018. Updated by Joni Hollis and Lalania White through email. April 2020. https://ahca.myflorida.com/Medicaid/statewide_mc/pdf/Medical_Foster_Care_Training.pdf
[23] Joni R. Hollis and Lalania White, Florida Children’s Medical Services. Emails and a discussion with the author in April and May 2020.
[24] “Medical Foster Care Services in the Statewide Medicaid Managed Care Program.” Agency for Health Care Administration. November 20, 2018. Updated by Joni Hollis and Lalania White through email. April 2020. https://ahca.myflorida.com/Medicaid/statewide_mc/pdf/Medical_Foster_Care_Training.pdf
[25] MaryBeth Musumeci, Priya Chidambaram, and Molly O’Malley Watts, “Medicaid Financial Eligibility for Seniors and People with Disabilities: Findings from a 50-State Survey.” Kaiser Family Foundation. 2019. https://www.kff.org/report-section/medicaid-financial-eligibility-for-seniors-and-people-with-disabilities-findings-from-a-50-state-survey-issue-brief/
[26] Ibid.
[27] MaryBeth Musumeci, Molly O’Malley Watts, and Priya Chidambaram, “Key State Policy Choices About Medicaid Home and Community-Based Services.” Kaiser Family Foundation. 2020. https://www.kff.org/medicaid/issue-brief/key-state-policy-choices-about-medicaid-home-and-community-based-services/view/footnotes/#footnote-447292-50
[28]Kate Honsberger et. al., “How States Use Medicaid Managed Care to Deliver Long-Term Services and Supports to Children with Special Health Care Needs: A 50-State Review of Medicaid Managed Care Contracts.” National Academy for State Health Policy. 2018. https://oldsite.nashp.org/wp-content/uploads/2018/12/MLTSS-and-CYSHCN-Issue-Brief-Final.pdf
[29] “Medicaid Health Homes: An Overview.” CMS Health Home Information Resource Center. January 2019. http://www.chcs.org/media/HH-Fact-sheet-January-2019.pdf
[30] “Coordinating Care From Out-of-State Providers for Medicaid-Eligible Children With Medically Complex Conditions.” Federal Register. January 21, 2020. https://www.federalregister.gov/documents/2020/01/21/2020-00796/coordinating-care-from-out-of-state-providers-for-medicaid-eligible-children-with-medically-complex
[31] “History and Mission.” Childkind, 2020. https://childkind.org/about/history-mission/
[32] Karl Lehman (Childkind Executive Director). Email. March 27, 2020.
[33] “Response to Open Records Request ChildKind.” Georgia Department of Community Health. February 26, 2015. (PDF provided by Childkind April 20, 2020).
[34] “Childkind’s Home-Based Services Take Charge! Medically Based Parenting.” Childkind. 2018. Provided by Executive Director Karl Lehman.
[35] “Family First Prevention Services Act.” National Conference of State Legislatures. April 1, 2020. https://www.ncsl.org/research/human-services/family-first-prevention-services-act-ffpsa.aspx#over
[36] “Status of Submitted Title IV-E Prevention Program Five-Year Plans.”Children’s Bureau, Administration for Children and Families, U.S. Department of Health and Human Services. September 7, 2020.
https://www.acf.hhs.gov/cb/resource/title-iv-e-five-year-plan
[37] “Family First Legislation.” National Conference of State Legislatures. May 20, 2020. https://www.ncsl.org/research/human-services/family-first-updates-and-new-legislation.aspx
[38] James C. Gay et. al., “Home Health Nursing Care and Hospital Use for Medically Complex Children.” Pediatrics. 138, 5 (2016): e20160530
[39] “Angels in Waiting.” Angels in Waiting. Accessed May 23, 2020. https://www.angelsinwaitingusa.org
Acknowledgements
This issue brief was written by Catherine Hess, National Academy for State Health Policy (NASHP) policy fellow. Other current and former NASHP staff contributed to the brief through research, input, guidance, or draft review, including Emma Sinkoff, former intern, Anna Matilde Tanga, former research analyst, Veronnica Thompson, policy associate, Kate Honsberger, project director, and Karen VanLandeghem, senior program director. The author wishes to thank the following state officials for their input and review: Joni Hollis, Bureau Chief, and Lani White, Office of Children’s Medical Services Managed Care Plan and Specialty Programs, Florida Department of Health, and Shelby Zimmer, Family First Program Director, Georgia Division of Family and Children Services. Rebecca Seltzer, assistant professor of pediatrics, Johns Hopkins School of Medicine, and Karl Lehman, executive director of Childkind in Georgia, also provided information and review, and their assistance is appreciated. NASHP also wishes to thank officials at the Health Resources and Services Administration, Maternal and Child Health Bureau, for their review.
This project was supported by the Health Resources and Services Administration (HRSA) of the US Department of Health and Human Services (HHS) under grant number UD3OA22891, National Organizations of State and Local Officials. This information or content and conclusions are those of the authors and should not be construed as the official position or policy of, nor should any endorsements be inferred by HRSA, HHS or the US government.
States Redesign Home Visiting Programs for a Telehealth World during COVID-19
/in COVID-19 State Action Center Michigan Blogs, Featured News Home Care Coordination, Chronic and Complex Populations, Community Health Workers, COVID-19, Health Equity, Integrated Care for Children, Integrated for Pregnant/Parenting Women, Maternal Health and Mortality, Maternal, Child, and Adolescent Health, Population Health, Social Determinants of Health /by Taylor PlattAs families face immense stress from the pandemic, states have rapidly reworked their home visiting programs to continue to support women and children. Because face-to-face services, including case management and family support and counseling, are no longer an option, health departments now deliver these vital services by telehealth. But with this new operating platform, states have needed to quickly address issues such as privacy requirements and billing, reimbursement, and enrollment processes as they launch their telehealth services.
Recently, the Centers for Medicare & Medicaid Services (CMS) released a toolkit in response to COVID-19 with guidance and steps for state Medicaid programs as they transition services to telehealth. The updated CMS guidance allows for greater flexibilities, including reimbursement for telephonic visits. To streamline the process, CMS stipulated that “no federal approval is needed for state Medicaid programs to reimburse for telehealth services in the same manner or at the same rate paid for face-to-face services, visits, or consultations.” However, a state plan amendment (SPA) is necessary to accommodate any revisions to payment methodology to account for telehealth costs.
Additionally, the Office of Civil Rights at the Department of Health and Human Services issued guidance that allows for enforcement discretion for noncompliance with the Health Insurance Portability and Accountability Act (HIPAA) regulatory requirements related to providers and telehealth, such as using non-HIPAA-compliant systems, such as the free version of Zoom.
How Michigan Converted its Home Visiting Service
Michigan, a state with a robust home visiting program prior to COVID-19, took quick action to support home visiting staff and the families they served to ensure continuation of services during the pandemic. The Maternal and Infant Health Program (MIHP) is administered and financed by the state Medicaid agency and is the largest home visiting program in the state. MIHP is available to all pregnant women enrolled in Medicaid and their infants up to age 12 months, with some exceptions. The program promotes healthy pregnancies and positive birth outcomes through a standardized, systemwide process of case management. When Michigan Gov. Gretchen Whitmer announced a state of emergency and stay-at-home orders in March 2020, the program quickly moved its home visiting services to telehealth.
The Michigan Department of Health and Human Services (MDHHS) updated guidance on telehealth visits for Medicaid beneficiaries. The provider bulletin allows for greater flexibilities on distant and originating sites and outlines the billing codes and modifiers providers should use. The MIHP operations team took numerous steps to ensure a smooth transition to telehealth services for their providers and families, including:
- Both the state Medicaid agency and the MIHP operations team had early and continued communication with providers, including making staff available to answer questions and provide support.
- The MIHP program created additional guidance specifically for MIHP providers. The guidance includes instructions on how to obtain and properly document verbal consent, billing procedures and codes specific to the MIHP program, and documentation procedures for all virtual visits.
- MDHHS held a provider webinar with detailed information related to telemedicine flexibility, including information targeted to MIHP providers and others.
- MIHP operations conducted a provider survey about how MIHP programs were continuing to provide services during this time, which netted a near 100 percent provider response rate. The survey revealed that a large majority of agencies adjusted successfully and quickly to the telehealth service delivery model. In addition, only a small number of agencies suspended services temporarily, primarily due to agencies shifting resources to cover COVID-19 emergency functions.
As states begin to reopen, many home visiting programs will begin to consider returning to face-to-face visits exclusively or as a part of their support programs. Considerations for the role of telehealth in home visiting is expected to factor into state decisions. While it is unclear how state home visiting programs will transition, some groups including The National Alliance of Home Visiting Models have encouraged all home visiting programs to continue to use telehealth to ensure the safety of women and their families, as well as home visitors. With the greater flexibilities allowed by CMS, states have the option to continue using telehealth for their home visiting programs during the pandemic. This allows for the continuation of important services for women and children and helps decrease the spread of COVID-19.
States will be weighing a number of considerations as they begin to open, including the benefits of telehealth for home visits and the costs associated with telehealth compared to in-person visits. These new policies will be important to monitor and will have implications for longer-term and possibly permanent use of telehealth to deliver essential services to families.
Additional Resources:
- NASHP Infographic: How State Medicaid Programs Can Use Telehealth to Serve Pregnant Women during COVID-19, May 2020
- NASHP Blog: States Rapidly Build their Telehealth Capacity to Deliver Opioid Use Disorder Treatment, April 2020
- Institute for the Advancement of Family Support Professionals: Rapid Response Virtual Home Visiting Collaborative
Six States’ Strategies to Providing Home Health Services to Children Enrolled in Medicaid
/in Medicaid Managed Care Connecticut, Delaware, Iowa, Maryland, Ohio, Washington Blogs, Featured News Home Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, Community Health Workers, COVID-19, Health Coverage and Access, Health Equity, Integrated Care for Children, Long-Term Care, Maternal, Child, and Adolescent Health, Physical and Behavioral Health Integration, Population Health, Social Determinants of Health, Special Populations and Services, Workforce Capacity /by Olivia Randi and Kate HonsbergerTo improve the quality of services for children and youth with special health care needs (CYSHCN) and reduce health care costs, states are implementing strategies to improve access to home health services. Of particular importance as states confront COVID-19-related budget challenges, home health services can help to avoid costly emergency department use, hospitalizations, and institutional care.
The Early, Periodic, Screening, Diagnostic and Treatment (EPSDT) Medicaid benefit mandates coverage of all medically necessary services for children under age 21 who are enrolled in Medicaid. However, states vary in their definitions of medical necessity, prior authorization processes, and approaches to home health service delivery.
Prior to National Academy for State Health Policy’s (NASHP) analysis, there was limited information available on home health services for CYSHCN, and few studies had analyzed states’ approaches to delivering these services.
In its new report, State Approaches to Providing Home Health Services to Children with Medical Complexity Enrolled in Medicaid, NASHP examines six states’ (WA, OH, IA, MD, DL, CT) strategies to support access to home health services for CYSHCN. These include addressing provider capacity, advancing the person-centered medical home model, streamlining prior authorization processes, collaborating with Title V Maternal and Child Health Services Block Grant Programs for CYSHCN, and promoting stakeholder collaboration.
Home health services are provided in a person’s residence and include:
- Nursing services;
- Home aide services provided by a home care agency;
- Medical supplies and equipment for use in home-based settings; and
- Physical and occupational therapy, or speech pathology and audiology services.
Through analysis of these states’ home health service delivery systems, NASHP identified several key insights that other state health policymakers can leverage in their own systems to improve service delivery and reduce costs. A shortage of home health providers was the primary challenge that states faced in delivering these services to CYSHCN, which states have addressed through training programs and by increasing or modifying reimbursement policies.
Partnerships across agencies and families were recognized as key to developing informed strategies to improve home health services for CYSHCN. States have leveraged these partnerships, as well as implemented technologies and streamlined processes, to deliver more coordinated, cost-effective home health services.
- Prioritize efforts to address provider shortages. To address the lack of home health provider capacity, several states have focused on developing, enhancing, and raising awareness of training programs to increase the supply of home health agency staff. States have also modified their reimbursement policies, including increasing their reimbursement rates for home health providers, and proposing a structured fee schedule to streamline the reimbursement process for home health agencies. Ohio, for example, allows for reimbursement of family caregivers for providing services for children enrolled in its Medicaid waivers in an effort to increase home health service provider capacity.
- Leverage the benefits of cross-sector and stakeholder collaboration. Partnering with a variety of state agencies, including Title V CYSHCN programs, provider groups, families, and other key stakeholders helps build the infrastructure necessary to deliver comprehensive home health services to CYSHCN. Stakeholder groups in Ohio, Maryland, and Delaware were crucial to developing strategies to improve access to home health services for CYSHCN. Two of these states also referenced the importance of family engagement to inform the work of the stakeholder group. In Ohio and Iowa, Medicaid agencies, providers, and Title V CYSHCN programs have formed collaborations to improve care coordination and access to home health services for CYSHCN.
- Adjust service delivery models to increase capacity. The medical home is a primary care service delivery model that emphasizes coordinated care through a team-based approach. Connecticut and Delaware, have looked to this model to encourage providers to improve care coordination for CYSHCN, including home health services. States have also looked to streamline their prior authorization processes to reduce administrative challenges for CYSHCN to access home health services. Delaware and Iowa are implementing changes to simplify this process through a “flag” in their data system and by developing a standardized prior authorization form for all managed care plans, respectively.
Other key insights from this analysis include seeking regular feedback from families, strengthening oversight, and customizing fee-for-services and managed care approaches. States interested in improving children’s access to home health services through Medicaid may benefit from the approaches implemented by the six states highlighted in this issue brief. For a list of NASHP’s reports, blogs, and other resources related to improving care for CYSHCN, please click here.
State Approaches to Providing Home Health Services to Children with Medical Complexity Enrolled in Medicaid
/in Policy Care Coordination, Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, Community Health Workers, COVID-19, Health Coverage and Access, Health Equity, Integrated Care for Children, Maternal, Child, and Adolescent Health, Population Health, Social Determinants of Health, Workforce Capacity /by Kate Honsberger, Ellen Bayer, Anna Matilde “Tilly” Tanga and Karen VanLandeghemStates are implementing new and enhanced strategies to improve the delivery and quality of home health services (e.g., nursing, home health aides, therapies) for children with medical complexity enrolled in Medicaid. This policy brief examines how six states structure, finance and provide home health services that are designed to provide important home-based care and family supports, improve quality of care, and avoid costly, hospitalizations and institutionalized care.
Read a related NASHP blog, Six States’ Strategies to Providing Home Health Services to Children Enrolled in Medicaid.
Background
State Medicaid agencies can use home health services to improve the quality of care and life for Medicaid enrollees and reduce costs. Today, many states are renewing their focus on this critical set of services as part of their Medicaid delivery system reforms, including managed care delivery arrangements and value-based care. Home health services are important for individuals with complex needs, especially for children with chronic, serious, and complex conditions.
Quality home health care can help children avoid emergency department use and prolonged hospitalization or institutional care.[1] Access to high- quality home health services can improve the outcomes and health of children and their families.[2]
States seeking new ways to improve health outcomes for Medicaid enrollees with complex needs have been challenged by longstanding policy barriers and workforce shortages. Few policy studies have analyzed state approaches to coverage and delivery of home health services for children and youth with special health care needs (CYSHCN). This brief describes how six states structure and provide home health services to children enrolled in Medicaid.
Nearly 20 percent (14.6 million children) of US children from birth to age 18 have chronic or complex health care needs that require physical and behavioral health care services and supports beyond what children normally require.[3] CYSHCN often depend on home health services as part of primary and specialty care, and other services and supports.[4] Of CYSHCN in the United States, 52 percent are white, 21 percent are Latinx, and 18 percent are African American.[5] A subset of CYSHCN – children with medical complexity – who comprise approximately 0.5 percent of US children, are even more likely to require home health services.[6] In 2016, nearly 500,000 families of CYSHCN reported needing home-based medical and therapeutic services.[7]
Medicaid plays a crucial role in providing coverage for CYSHCN, serving almost half of the CYSHCN population (48 percent).[8] CYSHCN are eligible for Medicaid through a variety of coverage pathways, some of which are mandatory under federal Medicaid law and others are optional at the state level. These pathways include Medicaid coverage for children:
- Based solely on their household income;
- Enrolled in the Medicaid Aid to the Aged, Blind and Disabled (ABD) category of assistance;
- Receiving Supplemental Security Income (SSI);
- Enrolled in foster care or receiving adoption assistance;
- Enrolled through a Medicaid waiver, including the Katie Beckett waiver that provides home-based services for children with complex health care needs
How Home Health Services Are Defined, Delivered, and Covered
Federal regulations broadly define home health services to include a range of specific services for adults and children that are provided at a “beneficiary’s place of residence,”[9] including:
- Nursing services;
- Home aide services provided by a home care agency;
- Medical supplies and equipment for use in home-based settings; and
- Physical therapy, occupational therapy, or speech pathology and audiology services, provided by a home health agency.[10]
These services are outlined in federal regulations, but state Medicaid programs have the discretion to deliver them in varying ways, with unique policies and procedures. For example, a state may offer home nursing services through Medicaid managed care delivery systems but provide home-based therapies through a fee-for-service system. Prior authorization policies may also vary for different home health services within a state.
Home nursing care in particular can be an important service for children with medical complexity (CMC). CMC often face a range of conditions and diagnoses that require care in a home-based setting and without access to home health services they would face higher hospitalization rates.[11] Community-based care is also considered a best practice for children with special health care needs and is typically more cost effective than institutional care.[12]
Home health services are provided by a range of providers including nurses, home health aides, personal care assistants, and others. Additionally, families play a critical role in delivering home health services to children. Family caregivers provide over 1.5 billion hours annually of health care for their children, according to a recent report.[13] Several states have begun to recognize the invaluable role families play and, as a result, provide training support and reimbursement to family caregivers for certain home health services, such as personal care services.[14]
Medicaid Coverage of Home Health Services for Children
Medicaid coverage of home health services for children is established by the Early, Periodic, Screening, Diagnosis and Treatment (EPSDT) benefit. Medicaid EPSDT mandates coverage of all services that are medically “necessary health care, diagnostic services, treatment, and other measures to correct or ameliorate defects and physical and mental illnesses and conditions.”[15] Coverage of these services includes all mandatory and optional services that the state can cover under Medicaid, whether or not such services are covered for adults.[16]
The EPSDT benefit is mandated for all children enrolled in Medicaid under age 21. Determining if a service is medically necessary is a key step for states when establishing whether a service is covered under the EPSDT benefit.[17] States are required to determine medical necessity, but they do so in a variety of ways depending on the delivery system providing the service.[18] The table in Appendix A details how the six states define medical necessity under Medicaid EPSDT and the prior authorization processes states use to determine medical necessity for all services, including home health services.
Federal law underscores the role of states in providing community-based and home-based services for children enrolled in Medicaid. Most notably, the US Supreme Court case, Olmstead v. L.C., established that unjustified institutionalization of Medicaid beneficiaries violates the Americans with Disabilities Act. As a result of the ruling, states must cover services in their programs, including Medicaid, in the community rather than institutions.[19]
State Medicaid programs are using a variety of strategies to improve access to home health services, particularly for CYSHCN. Some strategies are unique to home health services and others focus on improving care overall. The six study states (WA, OH, IA, MD, DL, CT) use a variety of delivery systems to provide home health services. Their strategies include addressing provider capacity, advancing the person-centered medical home model, streamlining prior authorization processes, collaborating with Title V CYSHCN programs, and promoting stakeholder collaboration.
Innovations to Address Home Health Services Workforce Shortages
The availability of well-trained providers is foundational to the timely delivery of high-quality home health services for CYSHCN. The extensive needs of CYSHCN and children with medical complexity often require ongoing skilled care by nurses and therapists. The design of service delivery models, provider education and training, and the adequacy of home health provider payment rates are all important factors affecting the home health workforce for CYSHCN.
Lack of sufficient home health provider capacity is one of the most significant challenges for states. States are experiencing shortages of pediatric nurses, licensed practical nurses (LPNs), and physical, occupational, and speech therapists. As a result, CYSHCN and their families can often experience barriers and wait lists for home health services.
State Innovations
Staff shortages are attributed to a variety of factors including geographic access challenges in rural areas, lack of home health services training programs, and payment rates that lag behind those of competing institutions or nearby regions. In Ohio, staff shortages are mostly concentrated in rural areas. Maryland has provider shortages in areas that are adjacent to Washington, DC where Medicaid payment rates are higher. Maryland also experiences home health care provider capacity challenges in certain areas due to competition from nursing facilities within the state.[20] In Connecticut, home health agencies that serve CYSHCN enrolled in Medicaid face competition for pediatric nurses from hospitals.
States are actively seeking solutions to address provider shortages. The Maryland Department of Health developed the Task Force to Study Access to Home Health Care for Children and Adults with Medical Disabilities using input from a variety of stakeholders in an effort to improve LPN training in home nursing skills and use of durable medical equipment.[21] The Maryland task force explored a range of options including:
- Partnerships between home health agencies and nursing programs at universities and community colleges to create training programs for LPNs interested in home health work;
- Opportunities for agency staff to participate in training simulation labs; and
- Preceptorships in which families would participate in training environments with providers in training.
The task force also recommended that provider agencies pool their resources to provide home health skills training and use a skills checklist to evaluate LPN competency on an annual basis to allow for a better understanding of how to continuously improve home health LPN skills, certifications, and competencies.
In an effort to improve the supply of home health nurses, Ohio’s Medicaid agency has increased awareness of the state’s workforce loan forgiveness and training programs.[22] In addition, an Ohio children’s hospital has partnered with a home health agency serving CYSHCN enrolled in Medicaid to provide home health nurses with specialized training in pediatric nursing.
Several states have either considered or implemented increases in home health care provider payment rates as a strategy to increase the number of providers participating in the Medicaid delivery system. Given the substantial fiscal impact of increasing payment rates, states have had to weigh the impact that these rate increases would have compared to other strategies for addressing workforce shortages. Ohio increased payment rates for home health nurses in 2017. Maryland’s task force provided several recommended options for significant increases to Medicaid home- and community-based services waiver and other community-based nursing providers’ payment rates. After an analysis of the fiscal impact of proposed increases, Maryland’s task force suggested that a phased-in approach to increases could be a pathway to modifying rates. This approach was implemented, and in May 2018 Maryland announced a 3 percent payment increase.[23] In an effort to streamline the reimbursement methodology for home health agencies, Connecticut Medicaid proposed a structured fee schedule approved by the state legislature in 2017, which allows for improved fiscal monitoring and data collection. Delaware’s Children with Medical Complexity Steering Committee, in studying how to improve the system of care for children with medical complexity,[24] recommended a workforce study to investigate possible shortages of private-duty nurses available to provide care to this population.
Recognizing the different levels of care that CYSHCN may need from home health care can also help make the best use of the limited number of pediatric home health providers. Maryland Medicaid allows for reimbursement of several tiers of service, with different payment rates to meet a range of needs within the fee-for-service (FFS) component of the program. For example, Medicaid covers certified nursing assistants (CNAs) and certified medical technicians (CMTs) to provide services, such as medication administration, that do not require an LPN level of care.
States are also acknowledging the crucial role that families play in understanding and supporting the unique needs of children as part of broader strategies to address shortages of home health providers. For children enrolled in Medicaid waivers, Ohio Medicaid allows family caregivers to be reimbursed for providing home-based personal care services to children. The Maryland task force recommended efforts to foster dialogue between parents and home care providers to increase feedback, manage expectations, and increase transparency about wait times. In Delaware, CYSHCN families were extensively engaged in the state’s steering committee process that identified challenges and developed solutions for managing the health care needs of children with medical complexity.[25]
Innovations to Advance the Medical Home Model
The American Academy of Pediatrics has identified medical homes as a core component of a comprehensive system of care for CYSHCN.[26] The medical home model can create the infrastructure needed for primary care provider (PCP) practices to engage with and coordinate home health and other providers involved in the care of CYSHCN. The model can help integrate home health services with all aspects of children’s care and provide the care coordination support needed to monitor access to home health services, ensure that authorized services are delivered, and close gaps in care.
State Innovations
In Connecticut, the medical home model is central to the state’s managed fee-for-service approach to delivering care to all members, particularly CYSHCN. Primary care practices receive in-office, ongoing support to attain and maintain National Committee for Quality Assurance (NCQA) or The Joint Commission medical home recognition. In addition, care coordinators employed by the state’s contracted Administrative Services Organizations support primary care providers and offer home visits and telephonic follow-up as needed. To the extent that PCMH practices have difficulty connecting families with home health care providers, they work closely with the state’s medical, behavioral, and dental administrative services organizations (ASO) to find qualified providers. ASOs are organizations that are contracted by the state to provide administrative services such as management of claims and benefits and provider delivery reform support. Delaware’s steering committee on medical complexity[27] recommended implementing the PCMH model as part of a comprehensive strategy to manage the health care needs, including home health services, of this population. Delaware found that the PCHM model could help ensure primary care provider leadership in coordination across all sectors of the health care system, including home health.
Innovations to Streamline Prior Authorization
The prior authorization process within Medicaid is intended to hold providers accountable for delivering medically necessary care and achieving cost savings in the health care system. However, because CYSHCN often need home health and other services on an ongoing basis, requirements for repeated prior authorizations can have the unintended effect of impeding access.[28] Access to home health for CYSHCN can be further delayed because of administrative challenges associated with navigating multiple prior authorization processes and forms used by different managed care plans.
State Innovations
To streamline the process and reduce unnecessary duplication of effort, Delaware managed care plans are working on a method to create a “system flag” within the Medicaid managed care data system for children with medical complexity. Using this system strategy will streamline and simplify the prior authorizations process, so that prior authorization processes can be simplified and not overly onerous. Additionally, to enable ongoing monitoring of managed care organization (MCO) prior authorization processes, Delaware Medicaid requires quarterly reporting on prior authorization decisions. Iowa Medicaid has recognized the challenges and delays associated with lack of uniformity in prior authorization requirements for MCOs. The state is working with managed care plans to develop a standard prior authorization form to be used across all plans. This will ease the burden on providers who were forced to be familiar with a wide assortment of forms and processes for multiple MCOs. State Medicaid officials anticipate that the form will be available in the next 18 months.
Improving Collaboration with Title V CYSHCN Programs and Stakeholders
In some states, state Title V Maternal and Child Health Services Block Grant (Title V) CYSHCN programs partner with Medicaid agencies to coordinate home health services for CYSHCN. State Title V CYSHCN programs are mandated under federal statute to support coordinated, community-based care for CYSHCN. Additionally, state Title V programs have extensive data and expertise on the needs of the population, as well as connections to pediatric specialists who can facilitate access to home health and other needed services. In some states, Title V programs provide important gap-filling services and supports, such as durable medical equipment, to supplement Medicaid or private insurance.[29]
State Innovations
In Ohio, state Medicaid and state Title V CYSHCN program staff partnered to help ensure a smooth transition for CYSHCN who transitioned to Medicaid managed care in 2012, which included children who access home health services. Ohio Medicaid and Title V program staff meet monthly to review cases of CYSHCN who have reported issues with accessing services or experiencing barriers to care. For example, medical-necessity determinations have not always considered that, due to their development, children requiring durable medical equipment may need more frequent replacements than they were receiving. This case review process has allowed for better understanding of the unique needs of children with medical complexity and better implementation of EPSDT medical necessity policies by Medicaid managed care organizations.
The University of Iowa’s Child Health Specialty Clinics (CHSC), Health and Disease Management team helps coordinate care for a subset of Medicaid-enrolled CYSHCN who are served through Medicaid fee-for-service programs and are not part of the state’s Medicaid managed care program. In Iowa, CHSC is part of the state’s Title V CYSHCN program. Care coordinators help maintain ongoing communication with home health agencies to facilitate timely access to pediatric nursing services. CHSC also trains and certifies family navigators – individuals who have lived experience with CYSHCN – to support families on waiting lists for Medicaid waiver services. This work requires coordination and collaboration between CHSC and the state Medicaid program to ensure coordinate care for children who are served by both programs.
Creating Opportunities for Stakeholder Collaboration
CYSHCN typically need services from many programs, organizations, and care systems, including Medicaid, public health, education, social services, behavioral health and substance use, foster care, and others. However, these agencies and systems historically have operated in silos, with minimal data sharing, collaboration, or integration.[30] The lack of collaboration across systems can lead to care gaps, duplication of services, fragmentation of care, and long delays in obtaining services. State officials increasingly are recognizing the need for communication and collaboration across multiple stakeholders within and outside of government to develop effective solutions for delivering home health services for children.
State Innovations
Delaware’s Children with Medical Complexity Steering Committee convened for eight months in 2017 and 2018 to develop a comprehensive plan to manage the health care needs of children with medical complexity. The steering committee included Medicaid officials, as well as other state divisions and agencies, providers, health plans, and family representatives. The committee’s goals were to strengthen the system of care, increase collaboration across agencies, encourage community involvement, and ensure adequate and appropriate access to health services for Children with Medical Complexity.[31] The steering committee divided into four work groups to address key issues, including access, and submitted recommendations to the legislature. Families provided extensive input on the nature of challenges in access to services, the need for respite care, transportation, difficulties in obtaining durable medical equipment, appeal and fair hearings processes, and coordination among payers.
Ohio Medicaid officials also convened an interagency workgroup to identify potential gaps and duplication of services for CYSHCN served by both Medicaid and state Title V CYSHCN programs. This interagency effort has allowed for sharing of CYSHCN-specific knowledge from Title V CSYHCN staff about the needs of this population with Medicaid staff to better deliver services, including home health services.
Key Strategies and Conclusion
The experiences of the six states featured in this report provide insights for other states interested in improving their coverage and delivery of home health services for children enrolled in Medicaid.
Prioritize efforts to address provider shortages. The shortage of qualified providers is the single greatest challenge for states seeking to optimize home health services for CYSHCN. The complexity of this issue requires creative and multi-faceted solutions. Stakeholder task forces and study committees, partnerships with state workforce agencies, innovative approaches to education and training, review of Medicaid payment rates, and exploration of credentialing and reimbursing family caregivers all play important roles in state strategies to improve and expand the home health care workforce for CYSHCN.
Seek regular feedback from families. Family experiences and satisfaction levels are the ultimate determinant of quality care for CYSHCN. States can leverage a variety of tools for beneficiary feedback, including annual surveys, focus groups, stakeholder advisory committees, regional forums, and one-on-one stakeholder meetings. Advisory committees may be time-limited or ongoing, depending on the nature of the issue and state agency capacity. Feedback from a range of stakeholders — including families, providers, health plans, and care coordinators —c an be critical to learn from individuals with a variety of perspectives, identify the most pressing problems, and formulate effective solutions tailored to beneficiary needs.
Leverage the benefits of cross-sector and stakeholder collaboration. Delivery of comprehensive, high-quality home health services to CYSHCN requires active engagement of many entities and systems and state agencies have recognized the need to go beyond siloed approaches to policy and program development. Partnerships across state agencies, particularly between state Medicaid and Title V CYSHCN programs and with provider groups, families of CYSHCN, and other key stakeholders can expand the knowledge base of all participants, advance innovative approaches to training, facilitate data sharing, and help build the relationships and infrastructure needed to overcome access challenges.
Adjust service delivery models to increase capacity. States are considering and implementing a variety of creative approaches to address persistent provider shortages. These strategies include development of medical home models that rely on team-based care and use of non-licensed staff (e.g., certified nursing assistants and certified medical technicians) to provide services, such as medication administration, that do not require the involvement of nurses or LPNs. Changes to prior authorization and staffing rules, such as allowing multiple agencies to provide authorized services or adjusting pediatric nurse assignments, may help maximize staffing resources to mitigate capacity challenges.
Strengthening oversight to improve quality and access to services. Medicaid programs have a variety of tools to strengthen accountability for access to quality care in either fee-for-service or managed care delivery systems. States are using a range of strategies that include requiring flagging of CYSHCN in information technology systems for targeted support, establishing provider network requirements aligned with CYSHCN needs, and requiring regular managed care plan reporting to identify challenges in delivery of authorized services. Additionally, states are enhancing oversight of home health services through targeted external reviews to validate the availability of qualified provider panels and regular evaluation of service delivery.
Customize fee-for-service and managed care approaches to improve access. State officials in both fee-for-service and managed care environments have found effective ways to advance access to home health services for CYSHCN, and leadership in both systems have viewed the payment models as critical to their success. A fee-or-service model may offer the advantage of allowing home health providers a “one-stop shop” to receive prior authorization for home health and other services and can be simple for families to understand. A Medicaid managed care model may provide the infrastructure needed to achieve effective care coordination and cost savings.
Officials in Medicaid managed care states report using fee-for-service carve-outs for specific populations and/or services in a way that is seamless to CYSHCN families and helps advance access to home health and other needed services. In carve-out environments, close coordination between health plans and providers is critical to ensure access. The optimal mix of managed care, fee-for-service, and carve-out strategies to advance access to home health services for CYSHCN will vary depending on the unique populations, policy landscape, and health care delivery systems in individual states.
Conclusion
Focusing on the unique needs of CYSCHN represents a key opportunity for states to increase quality and access to these services. The six states highlighted in this issue brief have each found unique ways of tackling both access and quality of home health services in different delivery system models. The efforts of these states demonstrate that by analyzing barriers to access, such as provider shortages, and collaborating with both stakeholders and families, states can improve the quality and delivery of home health services for children in Medicaid.
Appendix A: Summary of State Characteristics Related to Delivery of Home Health Services within Medicaid
| Home Health Services for Children and Youth with Special Health Care Needs (CYSHCN) Delivery Systems
Fee for Service (FFS) or Medicaid Managed Care (MMC) |
|
| CT | Fee for service |
| IA | Medicaid managed care[32] |
| DE | Medicaid managed care[33] |
| MD | Medicaid managed care[34]
Managed care organizations (MCOs) “may not” be required to cover a number of specified services covered under FFS, including personal care services (assistance with activities of daily living) pursuant to COMAR 10.09.20.[35],[36] |
| OH | Medicaid managed care[37] |
| WA | Medicaid managed care[38] |
| Populations of CYSHCN Enrolled in Medicaid Managed Care | |
| CT | N/A |
| IA | Mandatory enrollment for all populations of CYSHCN
Voluntary enrollment for American Indians/Alaskan Natives (AI/AN)[39] Excludes children who are enrolled in the Health Insurance Premium Payment (HIPP) program from managed care. |
| DE | Mandatory enrollment in Medicaid managed care for all populations of CYSHCN.
AI/AN are exempt from managed care enrollment.[40] |
| MD | Mandatory enrollment for all populations of CYSHCN[41] |
| OH | Managed care enrollment is mandatory for:7
· Children receiving Title IV-E federal foster care maintenance; · Children receiving Title IV-E adoption assistance: · Children in foster care or other out-of-home placement; and · Children receiving services through the Ohio Department of Health’s Bureau for Children with Medical Handicaps (BCMH) or any other family-centered, community-based, coordinated care system that receives grant funds under the Social Security Act and is defined by the state in terms of either program participation or special health care needs. Managed care enrollment is optional/voluntary for: · American Indians who are members of federally recognized tribes; or · Individuals diagnosed with a developmental disability who have a level of care that meets the criteria specified in state regulations and receive services through a 1915(c) home- and community-based services (HCBS) waiver administered by the Ohio department of developmental disabilities (DODD). |
| WA | Mandatory enrollment for most populations of CYSHCN
Voluntary enrollment for children in foster care or receiving adoption assistance[42] |
| Early, Periodic, Screening, Diagnosis and Treatment (EPSDT) Medical Necessity Definition in States’ Medicaid Managed Care Contract, Provider Manual, or Other State Documents | |
| CT | Definition of medical necessity |
| IA | State regulations do not include a definition specific to EPSDT. IAC 79.9(2) includes an overall definition of medical necessity definition.[43]
The Amerigroup Medicaid managed care contract similarly includes a general definition of medical necessity.[44] |
| DE | Medical necessity is defined as the essential need for health care or services which, when delivered by or through authorized and qualified providers, will:
For members enrolled in Diamond State Health Plan – Plus (DSHP-Plus) long-term support services, provide the opportunity for members to have access to the benefits of community living, to achieve person-centered goals, and live and work in the setting of their choice. In order that the member might attain or retain independence, self-care, dignity, self-determination, personal safety, and integration into all-natural family, community and facility environments, and activities. The contractor shall not arbitrarily deny or reduce the amount, duration or scope of a medically necessary service solely because of member’s diagnosis, type of illness or condition. The contractor shall determine medical necessity on a case-by-case basis and in accordance with this section of the contract.[45] |
| MD | Per Maryland EPSDT regulations,[46] MCOs must cover the following for Medicaid enrollees under age 21: Health care services that are medically necessary, which means that the service or benefit is:
· Directly related to diagnostic, preventive, curative, palliative, rehabilitative, or ameliorative treatment of an illness, injury, disability, or health condition; · Consistent with current accepted standards of good medical practice; · The most cost-efficient service that can be provided without sacrificing effectiveness or access to care; and · Not primarily for the convenience of the consumer, the consumer’s family, or the provider. Health care services described in the regulation include (but are not limited to): · Chiropractic services; · Nutrition counseling services; and · Private duty nursing services including: o An initial assessment and development of a plan of care by a registered nurse; o On-going private duty nursing services delivered by a licensed practical nurse or a registered nurse; and o Durable medical equipment. |
| OH | Per state regulations, medical necessity in EPSDT is defined as procedures, items, or services that prevent, diagnose, evaluate, correct, ameliorate, or treat an adverse health condition such as an illness, injury, disease or its symptoms, emotional or behavioral dysfunction, intellectual deficit, cognitive impairment, or developmental disability.[47] |
| WA | Per state regulation,[48] the standard for coverage for EPSDT is that the services, treatment or other measures are:
· Medically necessary; · Safe and effective; and · Not experimental. EPSDT services are exempt from specific coverage or service limitations which are imposed on the rest of the Categorically Needy and the Medically Needy program. Services not otherwise covered under the Medicaid program are available to children under EPSDT. The services, treatments and other measures which are available include but are not limited to: · Nutritional counseling; · Chiropractic care; · Orthodontics; and · Occupational therapy (not otherwise covered under the MN program). · Prior authorization and referral requirements are imposed on medical service providers under EPSDT. |
| Entity Reviewing Prior Authorization Requests | |
| CT | Most prior authorization requests are reviewed and processed by the department’s Administrative Services Organization (ASO), Community Health Network of Connecticut (CHNCT)[49] |
| IA | In Medicaid fee for service, the Iowa Medicaid Enterprise (IME) Medical Services Unit reviews prior authorization requests and makes coverage determinations. [50]
In managed care: [51] MCOs must use “appropriate licensed professionals” to supervise medical necessity determinations and specify the type of personnel responsible for each level of UM. MCOs must document access to board-certified consultants to help make medical necessity determinations. Any decision to deny long-term support services (LTSS) must be made by a long-term care professional with appropriate expertise providing LTSS. |
| DE | MCOs receive and review prior authorization requests for covered services including:
· Home-based services:
|
| MD | MCOs receive and review prior authorization requests for home-based services.[53] |
| OH | The Ohio Department of Job and Family Services reviews prior authorization requests for services other than those provided by MCOs.[54] |
| WA | The state’s Developmental Disabilities Administration reviews prior authorization requests for private-duty nursing.[55]
The Washington Health Care Authority reviews prior authorization requests for durable medical equipment.[56] Medicaid personal care is authorized by Home and Community Services and Developmental Disabilities administrations within the state’s Department of Social and Health Services.[57] |
Notes
[1] Simpser E, Hudak ML, AAP Section on Home Care, Committee on Child Health Financing. Financing of Pediatric Home Health Care. Pediatrics. 2017;139(3):e20164202
[2] Foster, C.C., Agrawal, R.K., & Davis, M.M. (2019). Home Health Care For Children With Medical Complexity: Workforce Gaps, Policy, And Future Directions. Health affairs, 38 6, 987-993
[3] Child and Adolescent Health Measurement Initiative. 2018 National Survey of Children’s Health (NSCH) data query. Data Resource Center for Child and Adolescent Health supported by the U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA), Maternal and Child Health Bureau (MCHB).
[4] MaryBeth Musumeci and Julia Foutz, “Medicaid’s Role for Children with Special Health Care Needs: A Look at Eligibility, Services, and Spending,” Kaiser Family Foundation, February 2018, https://www.kff.org/medicaid/issue-brief/medicaids-role-for-children-with-special-health-care-needs-a-look-ateligibility-services-and-spending/.
[5] Child and Adolescent Health Measurement Initiative. 2017-2018 National Survey of Children’s Health (NSCH) data query. Data Resource Center for Child and Adolescent Health supported by the U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA), Maternal and Child Health Bureau (MCHB).
[6] Dennis Kuo et al., “A national profile of caregiver challenges among more medically complex children with special health care needs,” Archives of Pediatrics & Adolescent Medicine 165, no. 11 (November 2011): https://dx.doi.org/10.1001%2Farchpediatrics.2011.172.
[7] Ibid.
[8] MaryBeth Musumeci and Julia Foutz, “Medicaid’s Role for Children with Special Health Care Needs: A Look at Eligibility, Services, and Spending,” Kaiser Family Foundation, February 2018, https://www.kff.org/medicaid/issue-brief/medicaids-role-for-children-with-special-health-care-needs-a-look-ateligibility-services-and-spending/.
[9] 42 CFR § 440.70
[10] Ibid.
[11] Gay, James C., Cary W. Thurm, Matthew Hall, Michael J. Fassino, Lisa Fowler, John V. Palusci, and Jay G. Berry. “Home health nursing care and hospital use for medically complex children.” Pediatrics 138, no. 5 (2016): e20160530.
[12]CMCS, and SAMHSA. “Joint CMCS and SAMHSA Informational Bulletin: Coverage of Behavioral Health Services for Children, Youth, and Young Adults with Significant Mental Health Conditions,” May 7, 2013. https://www.medicaid.gov/federal-policy-guidance/downloads/CIB-05-07-2013.pdf.
[13] Romley, John A., Aakash K. Shah, Paul J. Chung, Marc N. Elliott, Katherine D. Vestal, and Mark A. Schuster. “Family-Provided Health Care for Children With Special Health Care Needs.” American Academy of Pediatrics. American Academy of Pediatrics, January 1, 2017. https://pediatrics.aappublications.org/content/early/2016/12/23/peds.2016-1287.
[14] Coleman, Cara L. “Not Just Along For The Ride: Families Are The Engine That Drives Pediatric Home Health Care.” Not Just Along For The Ride: Families Are The Engine That Drives Pediatric Home Health Care | Health Affairs, April 18, 2019. https://www.healthaffairs.org/do/10.1377/hblog20190415.172668/full/.
[15] 42 U.S.C. § 1396d(r)
[16] 42 U.S.C. § 1396d(a)
[17] EPSDT – A Guide for States: Coverage in the Medicaid Benefit for Children and Adolescents: http://www.medicaid.gov/Medicaid-CHIP- Program-Information/ByTopics/Benefits/Downloads/EPSDT_Coverage_Guide.pdf.
[18] Clary, Amy, and Barbara Wirth. “State Strategies for Defining Medical Necessity for Children and Youth with Special Health Care Needs,” October 2015. https://oldsite.nashp.org/wp-content/uploads/2015/10/EPSDT.pdf.
[19] U.S. Department of Justice. Civil Rights Division . “Statement of the Department of Justice on Enforcement of the Integration Mandate of Title II of the Americans with Disabilities Act and Olmstead v. L.C,” n.d. https://www.ada.gov/olmstead/q&a_olmstead.pdf.
[20] Maryland Department of Health. Task Force Report on Access to Home Health Care For Children and Adults with Medical Disabilities. December 27, 2018. Baltimore, MD. Accessed on November 13, 2019. Available at: https://mmcp.health.maryland.gov/Documents/JCRs/2018/Report%20on%20Access%20to%20Home%20Health%20Care%20for%20Children%20and%20Adults%20with%20Medical%20Disabilities.pdf
[21] Ibid.
[22] Ohio Association of Community Health Centers. Benefits & Loan Repayment Programs. Accessed on November 27, 2019. Available at: https://www.ohiochc.org/page/168
[23] Maryland Department of Health. December 27, 2018.
[24] Delaware Health and Social Services Division of Medicaid and Medical Assistance. Delaware’s Plan for Managing the Health Care Needs of Children with Medical Complexity. May 15, 2018. Newcastle, DE. Accessed on November 13, 2019. Available at: https://dhss.delaware.gov/dhss/dmma/files/de_plan_cmc.pdf
[25] Ibid.
[26]https://www.aap.org/en-us/professional-resources/practice-transformation/medicalhome/Pages/home.aspx
[27] Delaware Health and Social Services Division of Medicaid and Medical Assistance. May 15, 2018.
[28] Honsberger,K., et al. How States Structure Medicaid Managed Care to Meet the Unique Needs of Children
and Youth with Special Health Care Needs. April 2018. Washington, DC. National Academy for State Health Policy. Accessed on November 28, 2019. Available at: https://oldsite.nashp.org/wp-content/uploads/2018/04/How-States-Structure-Medicaid-Managed-Care.pdf.
[29] Association of Maternal & Child Health Programs. National Title V Children and Youth with Special Health Care Needs Program Profile. April 2017. Accessed on November 29, 2019. Available at: http://www.amchp.org/programsandtopics/CYSHCN/Documents/CYSHCN-Profile-2017_FINAL.pdf.
[30] Silow-Carroll, S., et al. Interagency, Cross-Sector Collaboration to Improve Care for Vulnerable Children: Lessons from Six State Initiatives. Health Management Associates. Prepared for the Lucile Packard Foundation for Children’s Health. February 2018. Accessed on November 28, 2019. Available at: https://www.lpfch.org/sites/default/files/field/publications/hma_interagency_collaboration_national_report_02.15.2018.pdf
[31] Delaware Health and Social Services Division of Medicaid and Medical Assistance. May 15, 2018.
[32] “Medicaid for Kids with Special Needs (MKSN).” Iowa Department of Human Services. Accessed December 13, 2019. https://dhs.iowa.gov/ime/members/medicaid-a-to-z/MKSN.
[33] Delaware Health and Social Services. “Division of Medicaid and Medical Assistance 2018 Medicaid Managed Care MASTER SERVICE AGREEMENT,” December 19, 2017. https://dhss.delaware.gov/dmma/files/mco_msa2018.pdf.
[34] Code of Maryland Regulations (Last Updated: December 4, 2019), Title 10, Maryland Department of Health, Part two, Subtitle 09 Medical Care Programs, Chapter 10.09.63. Maryland Medicaid Managed Care Program: Eligibility and Enrollment.
[35] Code of Maryland Regulations (Last Updated: December 4, 2019), Title 10, Maryland Department of Health, Part two, Subtitle 09 Medical Care Programs, Chapter 10.09.70. Maryland Medicaid Managed Care Program: Non-Capitated Covered Services
[36] Code of Maryland Regulations (Last Updated: December 4, 2019), Title 10, Maryland Department of Health, Part two, Subtitle 09 Medical Care Programs, Chapter 10.09.20. Community Personal Assistance Services
[37]“The Ohio Department of Medicaid, Medicaid Ohio Medical Assistance Provider Agreement for Managed Care Plan,” n.d. https://medicaid.ohio.gov/Portals/0/Providers/ProviderTypes/Managed Care/Provider Agreements/Medicaid-Managed-Care-Generic-PA.pdf
[38] Washington State Health Care Authority. “Washington Apple Health Managed Care Contract,” n.d. https://www.hca.wa.gov/assets/billers-and-providers/model_contract_ahmc.pdf.
[39] Iowa Department of Human Services. Iowa Health Link contract with Amerigroup, effective January 2016. http://dhs.iowa.gov/sites/default/files/AmeriGroup_Contract.pdf
[40] Delaware Health and Social Services. “Division of Medicaid and Medical Assistance 2018 Medicaid Managed Care Master Service Agreement,” December 19, 2017. https://dhss.delaware.gov/dmma/files/mco_msa2018.pdf.
[41] Code of Maryland Regulations (Last Updated: December 4, 2019), Title 10, Maryland Department of Health, Part two, Subtitle 09 Medical Care Programs, Chapter 10.09.63. Maryland Medicaid Managed Care Program: Eligibility and Enrollment.
[42] “Health Care Services and Supports.” Apple Health managed care | Washington State Health Care Authority. Accessed December 13, 2019. https://www.hca.wa.gov/health-care-services-supports/apple-health-medicaid-coverage/apple-health-managed-care#changes-to-apple-health-managed-care.
[43] Iowa Department of Human Services. “General Provisions for Medicaid Coverage Applicable to All Medicaid Providers and Services.,” n.d. https://www.legis.iowa.gov/docs/iac/rule/441.79.9.pdf.
[44] Amerigroup RealSolutions in Healthcare. “Medical Policy: Medical Necessity Criteria.” Accessed July 10, 2019. https://medicalpolicies.amerigroup.com/medicalpolicies/policies/mp_pw_a044145.htm
[45] Delaware Health and Social Services. “Division of Medicaid and Medical Assistance 2018 Medicaid Managed Care Master Service Agreement,” December 19, 2017. https://dhss.delaware.gov/dmma/files/mco_msa2018.pdf.
[46] http://mdrules.elaws.us/comar/10.09.67.20
[47] Lawriter – OAC – 5160-1-01 Medicaid medical necessity: definitions and principles. Accessed December 13, 2019. http://codes.ohio.gov/oac/5160-1-01.
[48] Chapter 182-534 WAC: Accessed December 13, 2019. https://apps.leg.wa.gov/wac/default.aspx?cite=182-534&full=true#182-534-0100.
[49] Connecticut Department of Social Services (DSS). “Connecticut InterChange MMIS,” September 28, 2018. https://www.ctdssmap.com/CTPortal/Information/Get Download File/tabid/44/Default.aspx?Filename=ch9_auth_v4.5.pdf&URI=Manuals/ch9_auth_v4.5.pdf.
[50] Iowa Department of Human Services. “ALL PROVIDERS IV. BILLING IOWA MEDICAID,” February 1, 2018. https://dhs.iowa.gov/sites/default/files/All-IV.pdf?080220190110.
[51] Iowa Department of Human Services. “Iowa Health Link MCO Contract ,” February 1, 2016. https://dhs.iowa.gov/sites/default/files/AmeriHealth_Iowa_Contract.pdf?050820191355.
[52] “Physical Health Prior Authorizations.” AmeriHealth Caritas Delaware. Accessed December 13, 2019. https://www.amerihealthcaritasde.com/provider/resources/physical-prior-auth.aspx.
[53] Division of State Documents. Accessed December 13, 2019. http://www.dsd.state.md.us/comar/comarhtml/10/10.09.04.06.htm.
[54] Lawriter – OAC – 5160-1-31 Prior authorization [except for services provided through medicaid contracting managed care plans (MCPs)]. Accessed December 13, 2019. http://codes.ohio.gov/oac/5160-1-31.
[55] Chapter 182-551 WAC: Accessed December 13, 2019. https://apps.leg.wa.gov/wac/default.aspx?cite=182-551&full=true#182-551-3400.
[56] Washington Apple Health (Medicaid). “Medical Equipment and Supplies Billing Guide,” August 1, 2019. https://www.hca.wa.gov/assets/billers-and-providers/Med-Equip-Supplies-bi-20190801.pdf.
[57] “Health Care Services and Supports.” Medicaid Personal Care | Washington State Health Care Authority, January 1, 2018. https://www.hca.wa.gov/health-care-services-supports/program-administration/medicaid-personal-care.
Slide Deck: How States Can Improve Home Health Delivery for Children with Medical Complexity
This slide deck features innovative solutions states have implemented to address challenges in home health delivery, such as provider shortages, lack of coordination between Medicaid, Title V CYSHCN programs, and other stakeholders, and cumbersome prior authorization processes.
Acknowledgements: This issue brief was written by Kate Honsberger, Anna Matilde Tanga, and Karen VanLandeghem of the National Academy for State Health Policy (NASHP), and Ellen Bayer, a NASHP consultant. The authors wish to thank participating states’ Medicaid and Title V CYSHCN program staff for their time and willingness to be interviewed and their review. The authors also wish to thank officials at the Health Resources and Services Administration, Maternal and Child Health Bureau for their review and input.
This project was supported by the Health Resources and Services Administration (HRSA) of the US Department of Health and Human Services (HHS) under grant number UD3OA22891, National Organizations of State and Local Officials. This information or content and conclusions are those of the authors and should not be construed as the official position or policy of, nor should any endorsements be inferred by HRSA, HHS or the US government.
States’ Recent 1115 Waiver Applications Include Provisions to Support Children during the Pandemic
/in COVID-19 State Action Center Blogs, Featured News Home Care Coordination, Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, COVID-19, Health Coverage and Access, Health Equity, Integrated Care for Children, Maternal, Child, and Adolescent Health, Population Health, Workforce Capacity /by Kate HonsbergerMore than a dozen states have recently submitted 1115 waiver applications that have the potential to safeguard access to care and increase support for children during the COVID-19 pandemic.
If approved, these 1115 waivers would be retroactively to March 1, 2020, and expire “no later than 60 days after the end of the public health emergency.” The Centers for Medicare & Medicaid Services (CMS) created an 1115 waiver template for states to use when requesting authority to address the impact of COVID-19 on their Medicaid programs. The National Academy for State Health Policy (NASHP) April 6, 2020, blog, State Medicaid Strategies to Maintain Access to Care for Children with Special Health Care Needs during the Pandemic, outlines steps states are taking to support children with special health care needs using 1135 and 1915(c) Appendix K emergency waiver authorities.
Of the COVID-related 1115 waiver applications reviewed by NASHP, several contain provisions related to children. The 1115 waiver provisions listed below represent a selection of key strategies for serving children during the COVID-19 pandemic that other states may want to consider for their Medicaid programs, including payments to foster caregivers, reimbursement of family caregivers, and telephonic and virtual care coordination services.
Payments to foster caregivers: Children in foster care are more likely to experience physical and mental health challenges compared to children in the general population. During the COVID-19 pandemic, children in foster care may not be able to access their typical support services through schools and specialty physical and mental health providers. Arkansas, for example, is acknowledging the importance of providing stability and support to these vulnerable children by requesting authority through a 1115 waiver, to provide an additional monthly payment to all foster caregivers (“licensed foster parents, relative caregivers, and fictive kin”) for providing at-home care for children in their care. These monthly payments would be designed to “prevent negative impacts to physical and mental health during emergency period.”
Reimbursement for family caregivers: Both Georgia and New Hampshire have included provisions in their 1115 COVID-19 waiver requests asking for Medicaid reimbursement of family caregivers for caring for youth with special health care needs. Georgia’s 1115 waiver request would add a family caregiver service to its Georgia Pediatric Program in the event that licensed professional nurses (LPNs) are not available to provide the child’s needed services. New Hampshire’s 1115 waiver request asks to waive CFR 440.167 and allow family members to perform and be reimbursed for personal care services. Both of these approaches allow children who receive services in their homes to remain in a home setting and potentially reduce the need for hospital or nursing facility placement during a time when these facilities are being overwhelmed with COVID-19 patients.
Care coordination through telehealth for Medicaid managed care organizations (MCOs): Care coordination services are critical for children with special health care needs and are important services to improve health outcomes, reduce caregiver and patient burden, decrease health care costs, and strengthen systems of care for children with chronic and complex conditions. Currently, New Mexico’s Medicaid MCOs are required to conduct many care coordination activities (including initial screenings, needs assessments, and nursing facility level of care determinations) via home visits involving face-to-face interactions. As a result of COVID-19, New Mexico is requesting in its 1115 waiver application to allow its MCOs to continue to conduct their care coordination supports virtually – by telephone or, if possible, using video technology. This provision may help ensure that these valuable supports and services are continued and that children and youth with special health care needs (CYSHCN), in particular, are maintaining access to their care coordinators and care coordination services.
The National Academy for State Health Policy will continue to closely follow CMS responses to these waiver submissions and track any additional state 1115 waiver actions in response to the COVID-19 pandemic.
As states look for ways to ensure their systems are designed to support children during the pandemic, especially those with special health care needs, the National Standards for Systems of Care for CYSHCN can be a helpful resource. The standards address the core components of the structure and process of an effective system of care for CYSHCN such as access to care, eligibility and enrollment, and care coordination.
Many state waiver proposals during the pandemic are designed to improve aspects of the health care delivery system that are addressed by the National Standards, such as acknowledging the critical role families play in caring for children and children with special health care needs and allowing for flexibility in how care coordination is provided to best meet the needs of families and children. The standards can provide states with a framework to help ensure that key provisions and health care system components and protections are maintained during a time of disruption in the traditional health care delivery system.
State Medicaid Strategies to Maintain Access to Care for Children with Special Health Care Needs during the Pandemic
/in COVID-19 State Action Center Blogs, Featured News Home Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, COVID-19, Maternal, Child, and Adolescent Health /by Kate Honsberger and Karen VanLandeghemStates and the federal government are taking unprecedented steps to address the health needs of individuals impacted by COVID-19, including children and adults with chronic and complex health care conditions who are vulnerable to infection and to changes in the health care delivery system that may impact their ability to access much-needed primary and specialty care, home- and community-based services.
States are modifying Medicaid policies and programs so individuals and their families can continue to access critical services during the pandemic.
Nearly 20 percent of US children up to 18 years (14.6 million) have a chronic or complex health care need that requires physical and behavioral health care services and supports beyond what children normally require. Medicaid plays a crucial role in providing coverage for children and youth with special health care needs (CYSHCN), serving almost half of the CYSHCN population (48 percent).
Read the NASHP blog, States Modify Medicaid Home- and Community based Waivers to Respond to COVID-19
The Centers for Medicare & Medicaid Services (CMS) recently released guidance to states outlining strategies, existing federal authorities, and authorities granted through Section 1135 waivers – waivers that are only available to states during an emergency or natural disaster. The 1135 Medicaid emergency waiver, emergency Medicaid State Plan Amendments (SPAs), and 1915(c) Appendix K authorities enable states to implement temporary policies to help maintain access to care during the pandemic. There are also additional steps states can take without CMS approval to help ensure CYSHCN and their families can access services during the pandemic.
Relaxing prior authorization requirements: State Medicaid programs may require that certain services, such as behavioral health and home health services, receive prior authorization before being approved for Medicaid reimbursement. For children, these prior authorization processes will also determine if services are medically necessary and therefore are covered under the Medicaid Early and Periodic Screening, Diagnostic, and Treatment benefit. Using a 1135 waiver, states can temporarily waive prior authorization requirements for services or extend existing prior authorizations for services to help ensure that CYSHCN are able to access needed services through Medicaid providers without prior authorization delays. CMS does note that states can amend their prior authorization policies in fee-for-service delivery systems and can direct managed care organizations to do so without CMS approval. SPAs may be needed depending on the goal and scope of services included. For example, if a state wanted to waive or extend prior authorizations for prescriptions, it may need an SPA to change the quantity authorized.
Closing home health services gaps: Using the 1915 (c) Appendix K waiver authority, states can expand the number of qualified Medicaid providers by loosening qualifications, including permitting payment for services rendered by family caregivers or legally responsible individuals, if this strategy is not already included in their waiver. This strategy can be a welcome support to family caregivers in a time of crisis who otherwise might not be able to access home-based care. Alaska’s approved 1915(c) Appendix K waiver includes provisions that allow providers to hire family caregivers as direct service workers when “regular staffing for services approved in a support plan cannot be assured.” The services include respite care, supportive living services, and in-home supports. One of West Virginia’s approved waivers allows for legal representatives to be paid as personal attendants “should the member’s primary caregiver become unable to provide services/supports.” Five other states (Colorado, Connecticut, Kansas, New Mexico, and Pennsylvania) have included payment for family caregivers in their approved 1915(c) Appendix K waivers for some, if not all, of their 1915(c) waivers.
Extending timelines for Medicaid fair hearings and appeals: When prior authorization for services is denied, Medicaid enrollees are entitled to appeal and a fair hearing process. Under the 1135 waiver authority, states can extend the 90-day timeframe for enrollees to request a fair hearing to 120 days. This extended timeline can help provide families of CYSHCN with additional time to have denied services reviewed for approval during a fair hearing. To date, 39 states have included this provision in their approved 1135 waivers.
Increasing opportunities for telehealth: CYSHCN often need to access primary and multiple specialty providers on a regular basis to manage and treat their condition. With COVID-19 impacting the ability of providers to conduct typical office hours and the need for CYSHCN with potentially compromised immune systems to limit their time outside of the home, telehealth services are a valuable alternative for care. States are taking steps to make accessing services via telehealth easier, and CMS has encouraged states to increase the use of telehealth services. According to federal guidance, “No federal approval is needed for state Medicaid programs to reimburse providers for telehealth services in the same manner or at the same rate that states pay for face-to-face services. A SPA would be necessary to accommodate any revisions to payment methodologies to account for telehealth costs.” Alabama recently sent a memo to providers outlining temporary expansion of Medicaid coverage for telehealth services that includes chronic disease management and behavioral health services.
The impact of COVID-19 on public health, state budgets, health care delivery systems, and CYSHCN and their families that these systems serve, will last much longer than the pandemic itself. State Medicaid, public health, mental health, and other state agencies that serve CYSHCN and their families are currently experiencing an overload on their programs, infrastructure and workforce. They also face new policy questions that had not been necessarily considered prior to the pandemic and challenges to their public health and health care coverage systems that are unprecedented in recent history. NASHP staff will continue to report on state strategies that assure access to health care services for CYSHCN and their families. Questions that will be considered include:
- How are changes in federal and state policies helping children and adults with chronic and complex health care conditions maintain access to and continuity of care during the COVID-19 pandemic?
- What other policy changes are states considering, and is additional federal guidance needed to further support state efforts?
- Should policies enacted to ensure access to services during the pandemic be extended beyond the emergency period?
- What impact do temporary policy changes have on the ability of states to measure quality of care for children and adults with chronic and complex conditions in the short- and long-term?
- What are the budget implications of these types of changes to state policies?
Serving Children and Youth with Special Health Care Needs in Medicaid Managed Care: Targeted Contract Language
/in Medicaid Managed Care Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, Cost, Payment, and Delivery Reform, Featured Policy Home, Maternal, Child, and Adolescent Health, Medicaid Managed Care, Medicaid Managed Care, Medicaid Managed Care, Program Design, Quality and Measurement, Special Populations and Services /by Kate Honsberger, Anna Matilde “Tilly” Tanga and Karen VanLandeghemCMS Requests Input to Better Coordinate Care for Children with Complex Conditions from Out-of-State Providers
/in Policy Blogs, Featured News Home Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, CHIP, Chronic and Complex Populations, Chronic Disease Prevention and Management, Cost, Payment, and Delivery Reform, EPSDT, Health Equity, Health System Costs, Integrated Care for Children, Maternal, Child, and Adolescent Health, Medicaid Managed Care, Medicaid Managed Care, Medicaid Managed Care, Medicaid Managed Care, Population Health, Social Determinants of Health /by Kate HonsbergerThe Centers for Medicare & Medicaid Services (CMS) recently released a request for information (RFI) for input from states, providers, health systems, and families to better coordinate care from out-of-state providers for children with complex health conditions enrolled in Medicaid. The deadline to submit comments is March 23, 2020.
States have long addressed issues of access to care, provider availability, service delivery system design, and public insurance reimbursement for children with medical complexity (CMC). This RFI addresses considerations for CMC who may require specialized treatment or therapy that is not offered by in-state providers and therefore need services in other states, complicating the ability of states to coordinate and deliver care effectively.
Coordinating care for enrollees from out-of-state providers can also present an administrative burden for state officials who are required to screen and enroll these providers in their Medicaid programs in order to provide payment for services. This RFI is part of a requirement from the Medicaid Services Investment and Accountability Act of 2019 which calls for the secretary of the Department of Health and Human Services to issue guidance to states on this topic.
CMS is seeking input from states and stakeholders who have experience with specific aspects of coordinating care from out-of-state providers, including:
- Sate initiatives that have promoted and/or improved the coordination of services and supports provided by out-of-state providers to children with CMC;
- Administrative, fiscal, and regulatory barriers that states, providers, and enrollees and their families experience that prevent children with CMC from receiving care, such as community and social support services, from out-of-state providers in a timely fashion, as well as examples of successful approaches to reducing those barriers;
- Measures that have been or can be employed by states, providers, health systems, and hospitals to reduce barriers to coordinating care for children with CMC when receiving care from out-of-state providers; and
- Best practices for developing appropriate and reasonable contract terms and payment rates for out-of-state providers in both Medicaid fee-for-service and managed care systems.
For a full list of requested information please review the RFI. CMS will review input from states and stakeholders and issue guidance by October 2020. The new guidance will include:
- Best practices for using out-of-state providers to provide care to children with CMC;
- Coordinating care provided by out-of-state providers to children with CMC, including services provided in emergency and non-emergency situations;
- Reducing barriers that prevent children with CMC from receiving care from out-of-state providers in a timely fashion; and
- Processes for screening and enrolling out-of-state providers, including efforts to streamline these processes or reduce the burden of these processes on out-of-state providers.
The National Academy for State Health Policy (NASHP) encourages states to submit relevant information to shape future guidance.
The RFI was posted on January 21, 2020 and comments are due March 23, 2020.
View the CMS RFI for instructions on how to submit comments. NASHP will share the release of any future CMS guidance on this topic as part of its ongoing work in the area of children with medical complexity.
To review NASHP resources related to children with medical complexity and children and youth with special health care needs, please visit its resource page.
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For individuals living with complex, often chronic conditions, and their families, palliative care can provide relief from symptoms, improve satisfaction and outcomes, and help address critical mental and spiritual needs during difficult times. Now more than ever, there is growing recognition of the importance of palliative care services for individuals with serious illness, such as advance care planning, pain and symptom management, care coordination, and team-based, multi-disciplinary support. These services can help patients and families cope with the symptoms and stressors of disease, better anticipate and avoid crises, and reduce unnecessary and/or unwanted care. While this model is grounded in evidence that demonstrates improved quality of life, better outcomes, and reduced cost for patients, only a fraction of individuals who could benefit from palliative care receive it. 























































































































































