Primary Care Case Management in Medicaid: A Strategy for Supporting Primary Care in Rural Areas
/in Policy Alabama, Colorado, Idaho, Maine, Montana, Oklahoma Featured News Home, Reports /by Neva KayePrimary care case management (PCCM) programs are one of the oldest types of Medicaid managed care, but over time most states have shifted to use managed care organizations (MCOs) to deliver services to Medicaid participants. However, as of 2018, 13 states still delivered services through PCCM programs to about 5.5 million Medicaid participants. In almost all of these 13 states a large portion of the population lives in rural areas, which are more likely than urban areas to have a shortage of primary care providers (PCPs). In recognition of this situation, and considering the key role that PCPs play as the entry point to medical services and in-care coordination, some of the 13 states have begun to leverage their PCCM programs to strengthen primary care. NASHP identified five states (Alabama, Colorado, Maine, Idaho, and Oklahoma) leveraging their PCCM programs to encourage and support PCPs to improve the delivery of care to Medicaid participants and interviewed representatives of three of these states. These five states implemented three major types of strategies:
- Colorado, Idaho, and Oklahoma reward PCCM providers for improving their capabilities. Idaho, for example, established a tiered PCCM payment system that rewards PCCM providers who demonstrate greater capabilities with higher per member per month (PMPM) payments.
- Colorado, Idaho, Maine, and Oklahoma all reward PCCM providers for performance. Oklahoma, for example, offers PCCM providers incentive payments tied to specific achievements, such as screening patients for potential behavioral health conditions.
- All five states offer non-financial supports to PCCM providers, including technical assistance (Idaho and Oklahoma), data analytics (Maine and Oklahoma), and organizations to support affiliated PCCM providers in a variety of ways (Alabama, Colorado, and Oklahoma).
These states’ experience also revealed several lessons for designing innovative strategies to strengthen primary care. Perhaps the most important is to identify specific goals and objectives early on to guide the details of design, such as the choice of quality metrics for incentive payments. In addition, it is important to build in measurement at the start and to think of state efforts as iterative — moving to tackle new priorities as performance improves.
The strategies discussed here were developed for PCCM programs. The strategies could, however, be implemented via MCO contracts or even in fee-for-service programs. It is therefore our hope that the strategies and experience presented here will inform the efforts of states operating PCCM programs and those that use other delivery systems.
Introduction
State Medicaid agencies have operated primary care case management (PCCM) programs for 40 years.[1] During this time, these programs have evolved, and in recent years states have begun leveraging these programs to improve primary care. Compared to other states, most states that operate PCCM programs have a greater portion of their population living in rural areas.[2] Rural areas are highly likely to suffer from shortages of primary care and other providers. As a result, these states’ efforts to leverage their PCCM programs to improve primary care can produce significant benefits for rural residents. This report examines the efforts of five states to leverage their PCCM programs to strengthen primary care. Because these strategies could be implemented in Medicaid managed care organization (MCO) contracts we hope that the report will be useful not only to those currently operating PCCM programs but also to any state Medicaid agency seeking to strengthen primary care in rural areas.
Background
Only 19.3 percent of the U.S. population lives is rural areas.[3] However, as of March 2021, 61 percent of all primary care shortage areas were in rural areas.[4] These shortages of primary care providers (PCPs), who serve as the entry point to medical care and often play a large role in coordinating patient care, create challenges for residents of rural areas, the PCPs who serve them, and the Medicaid agencies responsible for providing access to services for program participants throughout the state. For example, rural residents are less likely than urban residents to obtain preventive services, including services needed to identify health conditions early in their onset.[5] Also, those living in rural areas are more likely to experience a preventable hospitalization.[6] Shortages of other providers — including mental health, oral health, home health, and obstetric providers[7] — exacerbate the primary care shortages as PCPs in rural areas have few other providers to refer their patients to for treatment.
State Medicaid agencies have operated PCCM programs to help manage and coordinate patient care for 40 years. Although most states have now shifted to using MCOs to deliver care to Medicaid enrollees, 13 states still operate PCCM programs that serve about 5.5 million Medicaid enrollees. Ten of these 13 states have a greater percent of their population in rural areas[8] than other states and, relative to their population, have fewer physicians directly delivering patient care.[9]
Some of the state Medicaid agencies that operate PCCM programs have begun to view them as a vehicle for investing in primary care and supporting PCP efforts to meet the needs of the Medicaid patients — a critical need in rural areas. Under this model of managed care, the state Medicaid agency has a direct agreement with PCPs (or an entity representing them), who accept responsibility for managing the services provided to their panel of patients. Historically, PCCM providers were paid on a fee-for-service basis for the services they provide plus a small per member per month (PMPM) fee. The PMPM fee was intended to recognize the costs associated with more active management of their patients’ care that are not associated with a specific service, such as implementing new office procedures to ensure that all patients are screened for depression or extending office hours.
Through internet research, NASHP identified five states that were using their PCCM programs as a vehicle for primary care investment (Alabama, Colorado, Idaho, Maine, and Oklahoma). Four of these states deployed payment models that create incentives for PCCM providers to develop new capabilities or improve their performance. All five established non-financial supports to help providers improve performance and coordinate patient care. This report examines the approaches these five states have taken to strengthen primary care. It uses information collected from internet research and interviews with state Medicaid officials in three of the five states (Colorado, Idaho, and Oklahoma[10]). It also incorporates input from Montana’s Medicaid agency, which had requested this analysis to help it develop options for improving its PCCM program.[11]
PCCM Programs: A Catalogue of Innovations
NASHP identified five states that were leveraging their PCCM programs[12] to encourage and support PCPs to improve the delivery of care to Medicaid participants (Table A). Examining the efforts of the five states finds three major approaches to investing in primary care: payment that rewards providers for improving their capabilities to deliver care, payment that rewards providers for improving performance, and non-financial support to help providers succeed in their efforts to improve care delivery. Each of these approaches is examined in more detail in this section.
Table A: Innovations to support primary care providers in five state PCCM programs
| State | Payment to improve capabilities | Payment to incent performance | Non-financial Supports for PCCM providers |
| Alabama | Coordinated health networks | ||
| Colorado | x | x | Regional accountable entities |
| Maine | x | Provider profiles | |
| Idaho | x | X (effective 7/2021) | Technical assistance provided by Medicaid staff, developing data analytic support |
| Oklahoma* | x | x | Provider profiles, technical assistance provided by Medicaid staff, and health action networks in some regions |
Note: * = Oklahoma plans to move to an MCO delivery system in October 2021.
Using Payment to Promote Practice Capabilities
Three of the study states (Colorado, Idaho, and Oklahoma) established PCCM programs that reward providers for improving their capabilities. These states have both established ongoing payment models that reward PCCM providers with more advanced capabilities with higher PMPM payments and have offered providers time-limited incentives to promote development of specific capabilities.
Idaho and Oklahoma: PCCM payment varies by provider capabilities
In 2016, Idaho established a four-tiered PCCM program, referred to as Healthy Connections PCMH Tier Program. Under this program, PMPM payments to PCCM providers vary by provider tier. Tiers were named to signal which capabilities were the focus of that tier’s requirements. For example, tier 2 was named Healthy Connections Access Plus to reflect that PCCM providers had to offer some form of enhanced access, such as telehealth, to qualify for the tier. The tiers were designed to reward PCCM providers as they gradually increased their patient-centered medical home (PCMH) capabilities. For example, to move from tier 3 to tier 4, the provider must meet all the requirements of tier 3 and several new requirements, such as having a well-established quality improvement process. Idaho also offered flexibility to providers. For example, providers seeking to join tier 2 had five options for demonstrating enhanced access.
Most PCPs can meet the requirements of tier 1 and, at implementation, all PCCM providers that had not qualified for a higher tier were assigned to tier 1. PCCM providers may move up in tier (and thus increase their PMPM payment amounts) at any time by submitting a tier application documenting the required capabilities. In most cases, the Medicaid agency specifies documentation[13] needed to prove capabilities and also verifies the capabilities via telephone or a site visit.
State officials estimate that they spend about $25 million per year on PMPM payments. They also reported that providers did respond well to the program by seeking to qualify for a higher tier, especially in the early years of the program and especially among rural providers, where the need for increased capabilities is greater. As demonstrated in the table below, at the inception of this program, only 66 providers, serving 24 percent of Medicaid participants, were classified as tier 3 or 4. As of May 2021, 156 providers, serving 62 percent of participants, had qualified for an upper tier. One Medicaid official said, “We saw providers in rural areas moving into higher tiers. Many moved into the fourth tier.”
Table B: Healthy Connections provider and participant enrollment by tier, 2016 and 2021
| Healthy Connections (HC) Tier | February 2016 | May 2021 | ||||
| # PCCM Providers
|
# Medicaid Participants | % Participants | # PCCM Providers
|
# Medicaid Participants | % Participants | |
| Tier I HC | 337 | 100,950 | 39% | 173 | 42,490 | 12% |
| Tier II HC Access Plus | 98 | 96,438 | 37% | 192 | 90,803 | 26% |
| Tier III HC Care Management | 41 | 51,955 | 20% | 43 | 76,628 | 23% |
| Tier IV HC Medical Home | 15 | 11,888 | 4% | 113 | 134,470 | 39% |
| TOTALS | 491 | 261,231 | 100% | 521 | 344,391 | 100% |
Source: Idaho Department of Health and Welfare
Oklahoma’s tiered payment model is very similar to Idaho’s. In 2009, Oklahoma created three tiers of medical homes (PCCM providers) and began varying the PMPM payment to the provider based on the provider’s tier and each enrollee’s Medicaid eligibility group. New medical home providers request a tier assignment, and Medicaid staff evaluate whether the provider qualifies for the tier. Requirements increase gradually as providers move through the tiers, but providers have some flexibility to choose which capabilities they will acquire to qualify for the tier. In Oklahoma, practices seeking to increase their tier level (and payment) apply for the new tier by September 30 of each year. Medicaid staff then evaluate whether the provider meets the qualifications of the higher tier. If approved, the new tier becomes effective on January 1 of the next year. Medicaid staff also audit about one-third of providers each year to make sure that they continue to meet their tier’s qualifications. State officials report that, based on the large shift of providers among tiers in the first few years of the program, the program succeeded in encouraging providers to increase their capabilities.
Colorado: Incentives to develop specific capabilities
From 2015 to 2018, Colorado Medicaid operated the enhanced primary care medical provider (PCMP-E) program, which rewarded those PCCM providers (referred to in Colorado as PCMPs) that met at least five of nine enhanced factors with a $0.50 PMPM increase in their regular PMPM rates. The nine factors were extended hours, timely clinical advice, data use and population health, behavioral health integration, behavioral health screening, patient registry, specialty care follow-up, consistent Medicaid provider, and patient-centered care plans. The most commonly met factor was “timely clinical advice,” which was defined as “provides timely clinical advice by telephone or secure electronic message both during and after office hours. Patients and families are clearly informed about these procedures.” This program was intended to ready providers to meet increased expectations under phase 2 of Colorado’s accountable care collaborative (ACC),[14] which was under development at that time.
Using payment to create incentives to improve performance
Four of the five study states (all but Alabama) used payment to create incentives for performance. Most of these states tied provider payments to achieving quality metrics or decreasing growth in the total cost of care (TCOC). However, one has also used payment to increase patient engagement, and one is implementing a shared savings component in their program.
Colorado, Maine, and Oklahoma: Payment tied to quality metrics or total cost of care
Oklahoma offers PCCM providers incentive payments tied to specific achievements and reports, spending $2.9 million on these incentives in fiscal year 2018. The structure of these payments varies by the incentive. Two examples illustrate the possibilities:
- Oklahoma offers PCCM providers $5 for each annual behavioral health screen they conduct (paid quarterly).
- Oklahoma earmarked $250,000 per quarter to be divided among those providers who achieve a specified Early and Periodic Screening, Diagnostic and Treatment (EPSDT) screening rate. The funding is divided using a methodology intended to award a bonus payment equal to 25 percent of the standard cost of the EPSDT screens.
In 2013, Colorado, as part of the first phase of its ACC, added a quality incentive to its PCCM payment structure. All PCCM providers received $3 PMPM for all enrollees but were also eligible for incentives of as much as $1 PMPM based on their performance on specific quality measures. Each measure was assigned a PMPM amount, and those providers that met performance criteria for that measure received a bonus based on the assigned PMPM amount. The measures changed each year. The incentive began with an initial set of three measures that were all related to cost containment. These measures sought to promote reductions in emergency room utilization, high-cost imaging utilization, and hospital readmission. Later, the Medicaid agency added a measure related to quality, which sought to promote increases in well-child visits among children ages 3 to 9.
In 2019, Colorado launched its alternative payment model (APM) for primary care providers. Under this program, the fee-for-service payment rates for specific services (referred to as the APM code set) vary based on participating providers’ performance on 10 quality measures. This model is for providers who serve at least 200 ACC enrollees or earn at least $30,000 annually in paid claims for providing the services included in the APM code set. Each year each participating provider selects 10 measures from a list developed by the state. In 2021, that list includes 63 measures. Each measure is worth a set number of points. Providers who, across the 10 measures, earn a total of 200 or more points are paid the full fee-for-service rate for the services in the APM code set. Payments paid to those who earn fewer than 200 points are reduced by a percentage calculated based on the total number of points earned. Fewer points result in greater reductions. A provider that did not earn any points would incur a reduction of four percent. All providers who qualify for participation must choose measures or the Medicaid agency will assign default measures. To date, very few providers have been assigned default measures.
Maine created the Primary Care Physician Incentive Payment (PCPIP) in 1998 and spends about $2.6 million per year on the program. The PCPIP rewards physicians who provide quality primary care to their Medicaid patients. Each quarter, physicians receive scores in three categories: access (e.g., total number of Medicaid patients served per quarter), utilization (e.g., emergency visit rate per quarter), and quality (e.g., percentage of mothers in practice who had a checkup within six weeks after delivery). The performance of each physician’s practice is compared to that of other practices in their primary care specialty and then given an overall ranking. All physicians ranking above the 20th percentile receive a share of available funds; those who rank below that mark do not receive a share. The size of the share that each receives is determined by their ranking. Those who rank higher receive larger shares.[15]
As of October 2021, Maine plans to merge the PCPIP and both its PCCM and health home programs to create Primary Care 2.0. Participating providers will receive risk-adjusted population-based payments (PBP) based on the three levels of qualifying practice characteristic (base, intermediate, and advanced), with the advanced tier reserved for primary care practices that are part of Maine’s Accountable Communities program. This PBP will be adjusted for provider performance on no more than 10 quality measures, one of which is total cost of care and another antidepressant medication management.
In the first phase of the program, providers will continue to receive the current fee-for-service rates for the services they provide. In the second phase, Maine will look to move away from fee-for-service and incorporate more services into the PBPs. Maine has officially aligned this model with the Centers for Medicare and Medicaid Innovation’s Primary Care First initiative.
Oklahoma: Patient engagement required for payment
In addition, Oklahoma does not pay for care coordination until a PCCM provider has established a relationship with the patient. Specifically, Oklahoma does not make a PMPM payment to a provider for any enrolled patient unless the provider has provided at least one service to the enrollee within the previous 15 months.
Idaho: Providers earn shared savings
Idaho is currently transitioning to a new model under which PCCM providers may receive shared savings through their participation in an accountable care program. The Healthy Connections Value Care program went live July 1, 2021, and requires participation for PCCM providers. Value care organizations may participate under a risk or shared savings only option. Savings/losses are calculated based on total cost of care for medical services and shared based on the providers’ performance on a set of quality measures. Under this approach, PCCM providers will continue to be incentivized to transition to the PCMH model of care as well as provide better quality, more cost-effective care, through their affiliation with value care organizations.
Non-financial Supports
All five of the study states offer non-financial supports to PCCM providers. These supports consist of technical assistance, data or data analytics, and access to networks that support provision of care.
Idaho and Oklahoma: technical assistance
PCCM providers in Idaho and Oklahoma can receive technical assistance and other support from Medicaid staff. Oklahoma’s care management and quality departments support the PCCM providers. The nurses in the care management department support PCCM providers by helping their enrollees with complex needs navigate the health care system to access the specialized services needed to treat their conditions. The quality department staff works directly with PCPs to improve the delivery of specific care — usually in alignment with the previously described incentive payment topics (e.g., increasing the EPSDT screening rate or screening for behavioral health conditions). Medicaid staff in both states also visit PCCM providers on a regular basis. These visits are now conducted via telephone, but before the COVID-19 pandemic, they were in-person visits. During these visits, the staff not only check that providers are meeting program requirements but work with them to identify changes the provider could make to qualify for a higher tier.
Maine and Oklahoma: data analytics
Maine and Oklahoma currently generate provider profiles for PCCM providers that show their performance on measures aligned with payment. These reports also help PCCM providers identify “gaps in care,” meaning the reports show providers which of their patients need specific services, such as a well-child visit. Oklahoma generates four types of provider profiles showing performance on emergency room utilization, breast cancer screening, cervical cancer screening, and well-child visits. These reports detail the individual performance and how that performance ranks among their peers. With implementation of shared savings, Idaho plans to also begin offering providers reports that show their performance on the quality measures incorporated into the payment model and on cost.
Alabama, Colorado, and Oklahoma: organizations that support provision of primary care
The final type of non-financial assistance that states offer to PCCM providers is access to organizations or networks that help them care for enrollees. Alabama, Colorado, and Oklahoma all offer this type of assistance. In Alabama and Colorado, the networks are themselves categorized as PCCM entities (PCCM-E), which are organizations that contract with the state to provide PCCM services or perform specific tasks that support the provision of primary care.[16] As previously discussed, both of these states also contract with PCCM providers.
In 2019, Alabama implemented a regional PCCM program that featured a single PCCM-E, called an Alabama coordinated health network (ACHN), for each region of the state. The ACHN program combined multiple programs designed to deliver various levels of care coordination to various populations (PCCM, health homes, maternity care, etc.). The state conducted a procurement process to secure the contractors. Each is to serve as a single care coordination delivery system that links patients, providers, and community resources in its region. Like a traditional PCCM program, an ACHN does not deliver medical services. ACHNs are paid a combination of PMPM payments, payments for specific care coordination services provided during a month, and a bonus payment of up to 10 percent of revenue based on performance on 10 quality metrics. Recognizing the unique challenges of rural areas, regional budgets adjusted for rural areas cap total payment in each region. Alabama Medicaid views the program as a quality improvement program built on a care coordination infrastructure and has established performance requirements, such as required screens, for new enrollees. The ACHN assists PCP/PCP groups with care coordination, including providing referrals to medical services and arranging non-emergency transportation.
In 2011, Colorado implemented phase 1 of its ACC, which supported PCCM providers’ efforts to deliver care by providing them access to a statewide data contractor and PCCM-Es referred to as regional care collaborative organizations (RCCOs). The data analytics contractor provided a dashboard to each PCCM provider that offered aggregate and patient level data needed to help providers manage their panel. The RCCOs provided care coordination (beyond what would normally be expected of a PCP), including coordination for behavioral health, long-term services and supports, and some social services. They also provided practice support, including tools and technical assistance aimed at helping the practice become and function as a high-performing medical home. In this phase of the program, the Medicaid agency required PCCM providers to affiliate with at least one RCCO. Many providers, however, chose to contract with several RCCOs because their patients were enrolled in those RCCOs.
In 2018, Colorado launched phase 2 of the ACC when it folded the responsibility for delivering behavioral health services into the program. In this phase, Colorado replaced the RCCOs with seven new PCCM entities referred to as regional accountable entities (RAEs). RAEs support a local network of medical PCCM providers, deliver behavioral health services, coordinate members’ care across systems, and are accountable for the cost and quality of care delivered to Medicaid members. Colorado assigns almost all Medicaid participants to a RAE. Through this program, Colorado is seeking to both improve behavioral health services and better integrate them with physical health. PCCM providers are required to contract with one RAE in order to serve Medicaid enrollees. PCMPs continue to receive fee-for-service payments from the Medicaid agency, but the PMPM payments to PCCM providers now flow through the RAEs. State officials report that making the RAEs responsible for distribution has given them greater flexibility to design value-based payment arrangements. Many of the RAEs have established tiered PMPM payment structures based on the capacity/performance of the provider.
In 2010, Oklahoma began piloting three health access networks (HANs), which wrap around PCCM providers to help them fulfill their role as primary care providers. The HANs offer care coordination and care management services to the patients of the PCCM providers that the HAN supports. The support includes helping enrollees access services that address their health-related social needs, such as food insecurity. The HANs also work with enrollees who frequently (and inappropriately) use the emergency room to help them obtain needed care from more appropriate sources. The HANs receive $5 PMPM — and a state evaluation found that the state netted a savings of $3.2 million in one 12-month period. The evaluation also found evidence of improvements in quality, as well as decreased emergency room use. The HANs were selected via an application process that describes them as an entity representing a collection of providers that is “organized for the purpose of restructuring and improving the access, quality, and continuity of care to SoonerCare members, the uninsured and the underinsured; and offers patients access to all levels of care, including primary, outpatient, specialty, certain ancillary services, and acute inpatient care, within a community or across a broad spectrum of providers across a service region or state.” (Note: The HANs will cease operation when the new MCO program launches in October 2021.)
Lessons Learned Using PCCM Programs to Improve Primary Care
Innovations Need to be Designed to Achieve Specific Goals and Objectives
Interviewees emphasized that the innovations they implemented were designed with specific goals in mind. In most cases, the overarching goal was to strengthen primary care — often by encouraging PCCM providers to develop more advanced PCMH capabilities. Colorado Medicaid stressed making primary care investment a clear policy goal to set the tone for state health planning not just in Medicaid but also in the private health care sector and with the state legislature. State interviewees also reported that it was important to have specific objectives under the overarching goal, such as better integration of behavioral health and primary care or improving children’s services. These objectives would govern which provider capabilities states would call out in tier requirements or the performance measures they would attach incentives to. States reported that it was best to secure stakeholder input and support of these goals and objectives. But at a minimum, providers needed to know what the goals were and why the Medicaid agency was changing the PCCM program.
With the exception of Alabama, all of the study states used multiple, mutually reinforcing strategies to achieve their goals and objectives for improving primary care. Idaho, for example, complemented its payment tiers with technical assistance to help providers develop the capabilities needed to move up in tiers and is developing data analytics that will help providers improve their performance on quality measures. Oklahoma established payment tiers, incentives for making specific improvements, and reports of provider performance on key issues, such as emergency department utilization.
“Remember that this program (ACC) is not totally the end. Rather, it is part of a process.”
-Colorado Medicaid official
All state officials interviewed said that their programs were iterative. They expected to make changes as they achieved current objectives and were able to tackle new ones. Colorado did not add behavioral health services to its ACC program until phase 2 of that program. State officials made this decision because they wanted PCCM providers to first develop their medical home capabilities and become the focal point of care for patients’ physical health services before working to break down the silos in care. Both Idaho and Oklahoma reported that their efforts to encourage providers to gradually increase their PCMH capabilities had worked, as most providers had gradually moved to higher payment tiers. Idaho built on the broad improvements in capabilities by moving to shared savings. Oklahoma, which is implementing an MCO program, is requiring the MCOs to build their networks around a PCMH delivery system.
Available Resources Impact State Decisions
Study states with the resources to make a long-term investment in strengthening primary care were likely to select an ongoing innovation that would produce change over time, such as a tiered payment structure. Idaho, for example, invests about $25 million/year (out of a $3 billion budget) in its tiered PCCM payments. Colorado also secured new funding to increase PCCM payments made under its ACC. However, interviewees reported that not all investments require new funding. Colorado worked with its contracted RCCOs to redirect $.50 PMPM of a performance incentive payment available to the RCCOs to instead be used, through the PCMP-E program, as a short-term incentive for the PCCM providers to develop specific capabilities that would contribute to the RCCOs’ success. The three states that tie provider payment to performance on a set of quality measures can also reap ongoing value from these established investments by updating their measure sets to create incentives to promote improvement in new areas.
State resources are not limited to funding for payments. System capabilities and staffing must also be considered. Oklahoma Medicaid, for example, needed to change its claims processing system to track services at the individual provider, and not just the provider group level, in order to implement its policy to only pay PMPM PCCM payments to providers who have seen the enrollee at least once within the previous 15 months. This state also hired provider education specialists who were tasked with visiting PCCM providers to assist them in meeting the criteria to which payment is tied — both the tier and incentive requirements. Colorado hired new staff to focus on system innovation and invested staff time in creating work groups to receive feedback.
Interviewees reported that the audit function (ensuring the PCCM providers meet program requirements) could be particularly staff intensive, and each had developed strategies to minimize that need. Idaho allows providers to “self-attest” to their capabilities when applying for a new tier, but Medicaid staff verify a sample of these applications each year. Colorado delegates this audit function to its contracted RAEs. Oklahoma Medicaid staff visit most PCCM providers about once every three years to verify that the providers are still meeting program requirements but does not visit those providers who are certified as PCMHs by an outside entity such as the National Committee for Quality Assurance (NCQA). State officials in all three states emphasized that the audit visits also provided an opportunity to educate the provider about program requirements and identify changes that the provider could make to qualify for incentive payments or higher PMPM payments.
Consider Measurement from the Start
“We need more data on the outcomes. We want to show that people have less hospitalization and people with diabetes are getting A1C.”
-Idaho Medicaid Official
Several interviewees reported that if they were designing their innovations now, they would place a greater emphasis on measurement and assessment. Officials from both Idaho and Oklahoma explained that they can demonstrate that providers increased their capabilities because over time more providers have shifted to higher tiers. Evidence indicates that these provider capability improvements should produce patient outcome improvements. These states, however, did not incorporate patient outcome measures into their plans and, thus, have not been able to quantify those improvements. Building in patient outcome metrics as part of program development would help to support further program improvement and budget justification over time.
Motivate PCCM Providers to Participate
Interviewees reported that one of their keys to success was to motivate PCCM providers to participate in their innovations. These states implemented strategies to secure provider interest and support and designed their innovations to be attractive to providers.
“Every year, we talk with physicians and groups and discuss what we missed. Every year we would add an element to the tiers.”
-Oklahoma Medicaid Official
To secure provider interest and support, states engaged providers in program design and worked to obtain the support of physician leaders. Oklahoma established a primary care physician task force in 2008 to help the state re-envision their PCCM program. Members of this group, who were all well-respected by their peers, were dissatisfied with the capitated PCCM model then in place in Oklahoma. This was also the time when many states were pursuing PCMH initiatives, so the task force and the Medicaid agency worked together to develop a new PCCM program that would foster development of a PCMH-based delivery system. The task force, which included a broad range of providers, held monthly meetings with Medicaid staff. The staff did research between meetings, including learning from other states, to develop proposals to bring back to the group. Together, the group developed a tiered PCCM payment system group members agreed was fair. The group believed that the tiers give physicians freedom to choose the tier that best fits their business model. Similarly, Colorado implemented an extensive and ongoing effort to engage not just providers but also other stakeholders in ACC design.
“Find a champion to get buy-in. Find someone who understands why the changes are important.”
-Colorado Medicaid Official
Idaho did not develop a specific task force but had worked closely with the Idaho Primary Care Association (IPCA), which represents federally qualified health centers (FQHCs), for many years and had a strong relationship with the organization and the FQHCs. The agency also had a strong relationship with the Idaho Academy of Family Physicians (IAFP) and its then-president. Both the IPCA and the IAFP were involved in the design of Idaho’s tiered PCCM payment system and were strong supporters of the model. They played a key role in helping other providers understand the model and how they might benefit from it.
“Prepare providers. Providers were comfortable where they were, but they welcomed the tiers as a new opportunity.”
-Idaho Medicaid Official
Interviewees had three specific suggestions for innovation design that they believed would make it easier to engage PCCM providers in actively working toward the state goals embodied in the innovation. These suggestions were to align payment criteria with national standards, make the reward obtainable, and offer providers flexibility. Idaho, for example, aligned the criteria for its payment tiers with those of NCQA’s PCMH recognition standards, including requiring PCMH recognition to enter the fourth tier. The tiers provided a path of gradually increasing criteria (and payment) to obtaining recognition. Each tier was achievable from the previous one. Idaho Medicaid also offered providers flexibility in meeting the criteria. For instance, to enter tier 2, a PCCM provider had to demonstrate enhanced access, but the Medicaid agency gave providers five options for meeting that criterion, including offering at least 46 hours per week of primary care access, telehealth, or a patient portal. Similarly, Colorado drew the nine factors considered in its PCMP-E program from NCQA’s PCMH standards and enabled PCCM providers to earn the incentives by implementing any five of the nine factors.
Finally, Colorado Medicaid officials noted that providers are motivated by recognition as well as money. They found that, often, the competition to earn reward payments was as important of a motivating factor as the payments themselves. Providers also realized, due to the alignment with national standards, that meeting the Medicaid standards could also earn rewards from other payers, including Medicare. The distinction of being an advanced primary care provider was also a draw for some providers. In light of these observations, Colorado began offering providers certificates recognizing their achievements in addition to payment.
Help PCCM Providers Succeed
State officials reported that, because the innovations were designed to achieve state goals, the state benefitted from helping providers succeed in earning the rewards associated with the innovations. In other words, helping providers develop new capabilities or improve their delivery of care for the chronic or potentially high-cost conditions prevalent among Medicaid enrollees ultimately helped the agency contain cost and improve care quality. Medicaid officials in all three interview states reported providing assistance to providers.
In both Idaho and Oklahoma, Medicaid staff provided technical assistance to PCCM providers. Prior to the COVID-19 pandemic, the assistance was delivered in provider offices, but it is now offered virtually. These staff found that explaining that their assistance could result in financial rewards increased provider interest in implementing specific improvements that addressed state goals. Colorado worked with local organizations, such as the Children’s Healthcare Access Program, that were already providing relevant technical assistance to providers to develop assistance that explicitly supported the improvements incented by the ACC. The Children’s Healthcare Access Program created resources to share data and teach providers about ACC requirements and goals.
“Making sure providers understand screening is one thing. Having somewhere to send [enrollees who screen as at-risk] is just as important.”
-Oklahoma Medicaid Official
All three states also offered other resources. Idaho provided forms that providers could use to demonstrate that they met tier criteria, and Colorado tasked its RAEs with providing both technical assistance and data analytics to PCCM providers to help them earn rewards by improving performance. Oklahoma first created a compendium of screening tools that providers could use to qualify for the behavioral health incentive payment. Providers, however, were concerned that they would not be able to act on any positive screening results because they did not know where to refer enrollees with potential behavioral health conditions for services. In response, the agency gave PCCM providers information about every behavioral health provider available to serve Medicaid enrollees in their county.
Summary
States can leverage their PCCM programs to strengthen primary care, particularly in rural areas where access and care coordination can be challenging. States that have taken this approach have found that they can design innovations that reward providers for improving the care most often needed by Medicaid enrollees. Through these programs, states can offer PCPs incentives to increase their capabilities or improve their performance. They can also offer non-financial supports such as technical assistance and access to the aggregate and person-level data they need to improve performance. States, however, need to design these innovations to achieve (and show they have achieved) clear goals and objectives and with consideration of available resources. They also need to ensure that PCCM providers understand, and ideally agree with, the goals of the program and offer providers the flexibility to implement the specific improvements that make sense for their practice.
Notes
[1] Primary care case management programs were authorized by the Omnibus Budget Reconciliation Act of 1981.
[2] In 2010, 10 of the 13 states with PCCM programs were among the 25 states with the greatest percentage of their population living in a rural area. Source: U.S. Census Bureau (2010), Percent Urban and Rural in 2010 by State. www2.census.gov/geo/docs/reference/ua/PctUrbanRural_State.xls.
[3] U.S. Census Bureau (2019). What is Rural America? www.census.gov/library/stories/2017/08/rural-america.html.
[4] U.S. Health Research and Services Administration (2021). Designated Health Professional Shortage Areas Statistics. Second Quarter of Fiscal Year 2021. Designated HPSA Quarterly Summary. https://data.hrsa.gov/Default/GenerateHPSAQuarterlyReport.
[5] Kurani SS, McCoy RG, Lampman MA, et al. Association of Neighborhood Measures of Social Determinants of Health With Breast, Cervical, and Colorectal Cancer Screening Rates in the U.S. Midwest. JAMA Netw Open. 2020;3(3):e200618. Doi:10.1001/jamanetworkopen.2020.0618; and Ziller E and Lenardson J. Rural-Urban Differences in Health Care Access Vary Across Measures. Portland, ME: University of Southern Maine, Muskie School of Public Service, Maine Rural Health Research Center; 2009 http://muskie.usm.maine.edu/Publications/rural/pb/Rural-Urban-Health-Care-Access.pdf.
[6] Johnston, K. J., H. Wen, and K. E. Joynt Maddox. 2019. “Lack of Access to Specialists Associated with Mortality and Preventable Hospitalizations of Rural Medicare Beneficiaries.” Health Aff (Millwood) 38 (12): 1993-2002. And Laditka JN, Laditka SB, Probst JC. “Health Care Access in Rural Areas: Evidence that Hospitalization for Ambulatory Care-Sensitive Conditions in the United States May Increase with the Level Of Rurality.” Health Place. 2009 Sep;15(3):731-40. doi: 10.1016/j.healthplace.2008.12.007. Epub 2009 Jan 10. PMID: 19211295.
[7] Rural Health Information Hub. Rural Healthcare Workforce. 2020. www.ruralhealthinfo.org/topics/health-care-workforce#characteristics.
[8] In 2010, 10 of the 13 states with PCCM programs were among the 25 states with the greatest percentage of their population living in a rural area. Source: U.S. Census Bureau (2010), Percent Urban and Rural in 2010 by State. Retrieved from www2.census.gov/geo/docs/reference/ua/PctUrbanRural_State.xls.
[9] Nine of the 13 have fewer active patient care physicians per 100,000 than the nation as a whole. Source: https://store.aamc.org/downloadable/download/link/id/MC4wNzQ5NDEwMCAxNjE3NzQxMTQ3NzY0MDIzNjkxMjAxMTE2OQ%2C%2C/.
[10] After the interview Oklahoma began moving its delivery system to an MCO delivery system, which is planned for launch in October 2021.
[11] The information presented in this brief was gathered to help Montana Medicaid better understand its options for improving its PCCM program. Thus, Montana’s program is not part of this study, but Montana state officials selected the interview states, participated in the interviews, and provided input to the findings presented here.
[12] Four of these states also operate other managed care programs: Colorado made its RAEs responsible for operating the state’s prepaid inpatient health plan (PIHP) for behavioral health; Idaho operates a PIHP for behavioral health, one prepaid ambulatory health plan (PAHP) for oral health services, a second PAHP for non-emergency transportation (NEMT), and has two contracts with health plans to serve dually eligible Medicaid program participants; and both Maine and Oklahoma have PIHPs for NEMT.
[13] For example, providers who choose to use a patient portal to meet one of the tier 3 requirements must, according to the application, submit the following along with their application: portal policies and procedures or other documentation that includes clinic’s expected response time to portal inquiries and screenshots of their live patient portal demonstrating that the portal has the features required by the state.
[14] The ACC is Colorado’s version of a Medicaid ACO program.
[15] Maine Department of Health and Human Services. MaineCare Benefits Manual, Chapter II, §90.09-4. (2019 update) www.maine.gov/sos/cec/rules/10/ch101.htm. Retrieved June 18, 2021.
[16] Per §438.2 of the CFR, primary care case management entity (PCCM-E) means an organization that provides any of the following functions, in addition to primary care case management services. (1) intensive telephonic or face-to-face case management; (2) development of enrollee care plans; (3) contract and/or oversight responsibilities for the activities of providers in the fee-for-service program; (4) payments to fee-for-service providers on behalf of the state; (5) enrollee outreach and education activities; (6) operation of a customer service call center; (7) review of provider claims, utilization, and practice patterns to conduct provider profiling and/or practice improvement; (8) implementation of quality improvement activities; (9) coordination with behavioral health systems/providers; (10) coordination with long-term services and supports systems/providers.
Acknowledgements: The National Academy for State Health Policy (NASHP) would like to thank the state officials from Montana and the staff of the Montana Healthcare Foundation whose interest in improving the care delivered to Montana Medicaid participants led to the creation of this brief. We also thank the state officials from Alabama, Colorado, Idaho, Maine, and Oklahoma who contributed to the brief, as well as Health Resources and Services Administration Project Officer Diba Rab and her colleagues for their feedback and guidance. The author also wishes to thank Hemi Tewarson, Trish Riley, Kitty Purington, Jodi Manz, and Luke Pluta-Ehlers of NASHP for their contributions to the paper. This project was supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) under co-operative agreement number UD3OA22891, National Organizations of State and Local Officials. The information, content, and conclusions are those of the author and should not be construed as the official position or policy of, nor should any endorsements be inferred by HRSA, HHS, or the U.S. government.
State Approaches to Leveraging Neonatal Abstinence Syndrome Data to Inform Policymaking
/in Opioid Center Kentucky, Ohio, Pennsylvania, Tennessee Featured News Home, Reports Behavioral/Mental Health and SUD, Opioid Use Disorder /by Eliza Mette, Jodi Manz, Kitty Purington and Mia AntezzoState Maternal Mortality Review Committees Address Substance Use Disorder and Mental Health to Improve Maternal Health
/in Policy Featured News Home, Reports /by Taylor Platt and Carrie HanlonState Approaches to Implementing Federal HIV Prevention Strategies
/in HIV/AIDS Featured News Home, Reports HIV/AIDS /by Eliza Mette, Mia Antezzo and Jodi ManzThe Centers for Disease Control and Prevention (CDC) estimates that 1.2 million Americans over the age of 13 are living with Human Immunodeficiency Virus (HIV), the virus that causes Acquired Immunodeficiency Syndrome (AIDS). Prevention of new HIV transmissions, along with diagnosis, treatment, and quick response to outbreaks, is among the key strategies identified by the Health Resources and Services Administration (HRSA) to end the HIV epidemic in the United States.
Policy Actions for HIV Prevention
- Increase access to and provision of Pre-Exposure Prophylaxis (PrEP) medication to individuals at increased risk of HIV infection.
- Implement syringe services programs (SSP) that provide a continuum of comprehensive harm reduction services to individuals who inject drugs.
Source: Hiv.gov
As part of the federal government’s goal of reducing new HIV infections by 90% by 2030, two policy approaches that states can employ for HIV prevention are highlighted: provision of Pre-Exposure Prophylaxis (PrEP) medication and availability of Syringe Service/Exchange Programs (SSPs/SEPs). Both interventions are cost-effective and can lead to significant cost-savings for states over time, particularly as Medicaid bears the largest cost-burden for HIV care.
New HIV infections have decreased over the decades since the virus was discovered, but prevention of HIV transmission remains challenging for states. Nationally, 220 counties across 26 states are in the midst of or at risk of an HIV outbreak among people who inject drugs. Forty-eight percent of young people who inject drugs report sharing syringes, which significantly increases the risk of HIV transmission, and people who inject drugs make up about 10% of U.S. HIV diagnoses.
HIV Prevention Strategy for States: Providing PrEP
Pre-Exposure Prophylaxis (PrEP) is an oral medication that, when taken consistently and as prescribed, reduces the risk of HIV infection by approximately 74% – 84% in people who inject drugs and nearly 99% in HIV-negative men who have sex with men (MSM), heterosexual men, and heterosexual women. Providers are encouraged to prescribe PrEP as a preventive measure to patients who engage in sexual behavior or injection drug use that increases their risk of exposure to HIV infection.
Demographic disparities in HIV infections, 2018:
- 42% of new HIV diagnoses were among Black Americans, despite making up 13% of the population.
- 23% of the people living with HIV were Latino, despite making up 18% of the population.
- Gay and bisexual men received 69% of new HIV diagnoses.
- Transgender women are also at elevated risk for infection.
Build Provider Confidence and Capacity: Despite the number of individuals that qualify for PrEP services, there are not enough providers trained in prescribing and administering PrEP to realize the full prevention capacity of this intervention. The regions of the U.S. with higher rates of new HIV diagnoses also have lower rates of PrEP use, and just nineteen percent of federally qualified health centers (FQHCs) operating in the country’s largest metropolitan areas have PrEP services available. Primary care providers (PCPs) are able to prescribe and provide PrEP in primary care settings but frequently report feeling ill-equipped or hesitant to prescribe PrEP. States have a number of strategies to improve provider confidence and increase capacity to prescribe PrEP:
- Use Project Echo to train more providers on PrEP. Project ECHO is an educational model through which a specialist provides clinical guidance via telemonitoring to another clinician rendering services to improve clinical capacity. Beginning in 2015, the Washington State Department of Health, in collaboration with the University of Washington, began incorporating PrEP into an existing HIV-specific Project ECHO program. In the first three years of the PrEP program, the program has held talks on PrEP and hosted case discussions which have supported community providers on PrEP related questions. As part of their prevention efforts, Washington also worked to identify clinicians in the community willing to prescribe PrEP and developed tools and other resources to healthcare systems, including a decision tree on how to pay for PrEP.
- Integrate PrEP into primary care. Recognizing the potential preventive impact of PrEP, New York integrated PrEP statewide within primary care and HIV specialty care The State Department of Health worked with the New York City Department of Health and Mental Hygiene to design a PrEP toolkit for primary care providers and developed a PrEP provider directory. The state’s AIDS Institute published PrEP clinical guidelines on its website, which have since been updated, and NYC developed a PrEP provider FAQ resource and created an email address specifically for questions regarding PrEP. New York’s efforts to raise awareness about and provider confidence in PrEP resulted in a fourfold increase the number of Medicaid recipients receiving the medication.
- Encourage pharmacists to prescribe PrEP. As accessible community providers, pharmacist provision of PrEP can reduce barriers to access and at the same time, reduce stigma associated with the medication. California passed a law that allows pharmacists who have undergone training to provide PrEP without a prescription. The law also prevents health insurers from requiring prior authorization and mandates coverage of pharmacist-prescribed PrEP. Iowa’s telehealth PrEP (telePrEP) program similarly relies upon pharmacists to maximize access to PrEP services through a collaborative practice agreement with the University of Iowa. Colorado and New Jersey also permit pharmacists to prescribe and dispense PrEP.
Leverage TelePrEP: States are supporting telePrEP in order to increase access to HIV prevention services and reduce associated stigma. In Iowa, nearly three quarters of all HIV cases are within 10 of the state’s 99 counties, none of which are near large cities. The state’s Department of Public Health conducted a community assessment to inform the creation of a telePrEP program that mitigates transportation and location-based barriers to access. Louisiana has implemented a similar telePrEP program, and although the state is still working to improve program retention, data show that is has been successful in engaging hard-to-reach individuals; 61% of continuing clients were from rural parts of the state, and all of Louisiana’s nine health care regions were represented.
PrEP services can be cost-prohibitive; medications for PrEP can cost up to $2,000 per month for those without insurance. While most state Medicaid programs cover PrEP medications, the majority of states do not provide payment parity for the provision of telehealth services, although there are some exceptions (e.g., Arizona, Colorado, and New Hampshire). Iowa funds its telePrEP program using savings from HRSA’s 340B Drug Pricing Program. The program also received a four-year $2 million CDC grant in 2018, which has been used to expand the reach of telePrEP services and evaluate the program’s effectiveness and replicability.
Engage Community Health Workers: States are also leveraging community health workers (CHW) to increase access to Medicaid-reimbursable preventive services, including HIV prevention and treatment care. The Centers for Medicare and Medicaid Services (CMS) changed a rule in 2013 to allow non-licensed practitioners, including CHWs, to deliver preventative services that are recommended by a physician. Louisiana and Rhode Island employ CHWs through Medicaid managed care organizations, FQHCs, community organizations, health departments, and others for HIV care.
CHWs fill non-clinical gaps in HIV prevention and treatment by connecting individuals to services community outreach and care coordination. A report prepared by Boston University with support from the Health Resources and Services Administration (HRSA) on integrating CHW into HIV care recommends active engagement between CHW and Ryan White Planning Councils, including through the development of leadership roles and career opportunities on the councils themselves. In Louisiana, HIV/AIDS is the second most common condition that CHW reported addressing in their work.
Other states are utilizing peer navigators to increase access to and comfort with PrEP. Florida relies on HIV peer navigators to connect patients with providers, field patient questions, and assist in connections to health care and social services. Florida’s use of HIV peer navigators has led to improved engagement and re-engagement in HIV care and treatment and more empowered HIV-positive clients. In Louisiana, patients are referred to the state’s telePrEP program through the state’s Health Hub where they can self-enroll or discuss directly with the state’s telePrEP navigator. Once a client is engaged in the program, a provider will e-prescribe PrEP to a client’s pharmacy, and the medication will be mailed directly to the patient. The telePrEP Navigator plays the vital role of keeping patients engaged by connecting with them regularly to ensure medication delivery and adherence, discussing any side effects, and scheduling follow-up appointments.
HIV Prevention Strategy for States: Supporting Syringe Services Programs (SSP).
SSPs provide comprehensive harm reduction services – screening and treatment for communicable diseases, referral to treatment for SUD and OUD, and sterile syringes and other equipment – and are cost-effective and produce cost savings for states. They have played an important role in decreasing HIV transmission among people who inject drugs by providing sterile injection equipment and safe syringe disposal and connecting individuals with needed treatment and other supportive services.
Although states have historically been able to use federal funds to support SSPs, federal rules previously prevented states from using those funds to purchase syringes. States may, however, use the recently announced $30 million appropriated through the American Rescue Plan Act for harm reduction services to purchase sterile syringes for SSPs. Of the 32 states with laws that specifically allow the operation of SSPs, Colorado, Ohio, Georgia, Delaware, and Rhode Island all require SSPs to provide HIV screening services to SSP clients. Other states, such as California, Florida, and New York, include language in their SSP authorizing statutes recognizing the role these programs play in preventing HIV transmission.
New York City realized a four percent annual reduction in new HIV infections among the injection drug user population when it increased its SSP capacity from 250,000 syringes/year to 3,000,000 syringes/year. Five months after Indiana opened SSPs in response to its 2015 HIV outbreak, only 22% of SSP clients reported sharing injection equipment, as opposed to seventy-four percent before the SSP opened. Almost all injection drug users surveyed indicated that they used the SSP; as a result of the uptake of SSP services, Scott County experienced a 96% reduction in new HIV infections by 2018, though the site was recently closed.
SSPs are cost-effective and can help states realize cost-savings over time because of the disease burden they prevent. An analysis of Kentucky Medicaid claims data showed that counties with syringe exchange programs (SEP) have lower rates of disease associated with intravenous drug use, including HIV and hepatitis C, indicating that the state’s SEPs are helping to decrease potentially costly communicable disease burden. Philadelphia and Baltimore’s SEPs together prevented over 12,000 new cases of HIV over the span of a decade, which translated into millions of dollars of savings for each city every year. States may use several strategies to maximize the potential of SSPs:
- Increasing legal access to sterile syringes. People who use drugs are frequently hesitant to use SSPs due to perceived risk of interaction with law enforcement, which may contribute to more syringe sharing and unsafe syringe disposal. Syringes, whether or not from SSPs, may be considered paraphernalia under some state statutes. Several states have taken steps to decriminalize possession of drug paraphernalia and personal use amounts of scheduled substances in an effort to reduce drug user interaction with law enforcement. New Mexico decriminalized possession of drug paraphernalia, lowering the penalty for possession with intent to use to a $50 fine and the penalty for possession with intent to deliver to a misdemeanor. Virginia exempts the possession of syringes obtained from a harm reduction program from the definition of illegal drug paraphernalia.
- Funding to support HIV prevention, testing, and referral to treatment. Sustainable funding is a perennial issue for SSPs, as programs must frequently piece together budgets through multiple grant-based funding sources. However, when SSPs receive public funding, communities experience improved syringe distribution and increased access to treatment and prevention services, which results in reduced or maintained low rates of HIV. New York’s drug user health hubs are enhanced SSPs that provide a more comprehensive array of services, including HIV testing and treatment, as well as PrEP services. Drug user health hubs provide a bundle of Medicaid-reimbursable harm reduction services, such as Hepatitis C treatment, mental health services, and SUD services including MOUD.
Looking Ahead
Despite the progress that has been made toward preventing HIV infections and improving outcomes for HIV-positive individuals across states, the U.S. still experiences 38,000 new cases each year and spends $20 billion annually on HIV. One of the four goals of the HIV National Strategic plan is to reduce new HIV infections, but the U.S. will see an estimated 400,000 additional HIV diagnoses over the next decade if action is not taken.
Recent federal actions and resources can support states as they work to implement and expand HIV prevention strategies designed to reduce rates of new HIV infections. Funding allocated to states in the ARPA totals $30 million in new investments for harm reduction, and this renewed support of harm reduction services underscores the effectiveness of these approaches.
States have played a key role in preventing new HIV infections by strengthening and maximizing access to PrEP and harm reduction services, particularly for vulnerable populations. It is more important now than ever that states bolster HIV prevention infrastructure, as the COVID-19 pandemic has significantly disrupted the provision of HIV preventive care. Despite the willingness and capacity to provide HIV care virtually, PrEP prescriptions and the number of new PrEP users both decreased between March and September 2020, and SSPs have had to reduce their in-person services due the pandemic, which has impacted syringe exchange and HIV screening.
Acknowledgements
This toolkit was supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) as part of a financial assistance award under the National Organizations of State and Local Officials (NOSLO) cooperative agreement totaling $836,859.00. The contents are those of the author(s) and do not necessarily represent the official views of, nor an endorsement, by HRSA, HHS, or the U.S. Government. For more information, please visit HRSA.gov. The authors would like to thank HRSA project officer Diba Rab and her colleagues for their guidance and helpful feedback.
Toolkit: Health Insurance Rate Review Authority to Control Health Care Costs, Including Model Legislation and Regulatory Language
/in Health System Costs Reports /by Erin Fuse Brown, JD, MPHFor over a decade, Rhode Island has used its health insurance rate review authority to constrain the growth of hospital prices to the rate of inflation plus one percent. Other states, including Colorado and Delaware, are moving to implement similar strategies giving the insurance commissioner the authority to enforce affordability standards as part of the health insurance rate review process.
This toolkit allows states to assess their existing health insurance rate review laws for the authority to regulate hospital cost growth; and proposes model statutory and regulatory text to provide a state insurance commissioner with the ability to condition health insurance rate approval on meeting affordability standards in hospital cost growth.
Assess Your State’s Existing Rate Review Authority
There are three main questions to assess a state’s existing authority to implement an affordability standard via health insurance rate review:
Type of rate review: Does your state require prior approval or file-and-use for health insurance rates? Does the type of rate review authority vary by market segment?
Scope of rate review: Does your state insurance rate review authority extend to the fully insured large group market or does it only cover the small group and individual markets?
Consumer protection authority: Do your state insurance rate review laws include as one of the purposes or duties protecting consumers, promoting the public interest or welfare, or improving affordability?
Type of Rate Review. Although a state may be in a better position to enact an affordability standard via health insurance rate review if it has prior approval authority rather than file and use authority, a state can start with the authority it has and use retrospective enforcement under file and use review.
The first question addresses the type of the state’s rate review authority, the process under which the state’s insurance commissioner reviews and approves health insurance premium rates and increases to ensure they are accurate and justifiable. There are two general types of rate review authority: “prior approval” and “file and use.” Under prior approval authority, the health insurance carriers must file their rates and supporting data a certain time period in advance of the rates’ effective date, and insurance regulators have the authority to review and disapprove any rates that they do not meet the state’s regulatory standards. Under file and use authority, insurance carriers’ rates go into effect before the insurance regulators may review it, but the regulators may be able to review and take action afterwards, usually based on consumer complaints. Many states follow a prior approval system of rate review.[1] Other states follow a file-and-use system of rate review.[2] Finally, some states use different systems for different market segments, such as requiring prior approval for individual and small groups and file-and-use for large group policies.
Scope of Authority. States should understand the scope of their health insurance rate review authority, including which market segments to which the authority extends: individual, small group, or large group markets.
States that only extend health insurance rate review requirements to the individual and small group markets could enact an affordability standard applicable to those market segments as a starting point. But to have a larger impact on health care costs overall, the rate review authority would need to extend to the large group market as well. This is particularly true if the insurance carriers in that state develop different contracts and rates for small and individual markets than for the large group market. In other states, however, there may be sufficient overlap in the carriers’ contracts and fee schedules between the market segments that even if the affordability standard is applied to a more limited segment (e.g., the individual and small group markets) there may be a spillover effect in the large group market.
Consumer protection authority. If a state’s existing health insurance rate review laws include authority to take steps to protect consumers, protect the public’s interest or welfare, or promote affordability, then the model statutory text below may be unnecessary. The state could rely on that existing authority and implement rulemaking to establish an affordability standard.
Model Statutory Authority for Health Insurance Affordability Standard
To implement an affordability standard, a state’s rate review statute must give the insurance commissioner the authority to assess a broader array of statutory factors in rate review beyond insurer solvency to include consumer protection and affordability. For example, a typical state statute may require that health insurance rates are not “excessive, inadequate, or unfairly discriminatory.” This type of rate review authority was traditionally aimed at marketplace behaviors of insurers in a property-casualty model addressing insurer insolvency and discriminatory pricing, but does not target the key problem driving health insurance premiums up: rising hospital prices. Thus, to implement a hospital affordability standard in most states, the insurance commissioner’s statutory rate review authority would likely need to be augmented.
To provide authority to implement affordability standards via health insurance rate review, the statutory text ought to be drafted broadly enough to authorize the insurance commissioner to pursue policies to protect the public interest and promote health care affordability. However, the statutory text should leave specification of the affordability standard and implementation to regulation to preserve flexibility to pursue other policy objectives, such as the promotion of primary care, alternative payment models, or the reduction of health disparities.
To extend the Insurance Commissioner’s authority to implement an affordability standard, a state could add the following text to the statutory provisions governing Commissioner’s existing rate review authority.
Powers and Duties of the Commissioner
- With respect to health insurance as defined in [code section], the Commissioner shall discharge the powers and duties of office to:
- Protect the public interest and the interests of consumers;
- Encourage the fair treatment of providers;
- View the health care system as a comprehensive entity and encourage and direct insurers towards policies that advance the welfare of the public through overall efficiency, affordability, improved health care quality, and appropriate access.
Rate Filing Requirements
- In discharging the duties of the Office, including but not limited to the Commissioner’s decisions to approve, disapprove, modify or take any other action authorized by law with respect to a health insurer’s filing of health insurance rates or rate formulas under [cite to code provisions], the Commissioner may consider whether the health insurer’s products are affordable and whether the carrier has implemented effective strategies to enhance the affordability of its products.
- The Insurance Commissioner may promulgate regulations to carry out the powers and duties of this Section, including without limitation, to implement rate filing requirements, establish affordability standards, impose penalties, and ensure compliance with this section.
Note: States may want to add provisions to the rulemaking authorization to include other policy objectives related to affordability, including investments in primary care and alternative payment models.
Model Regulations for an Affordability Standard
Under the statutory authority set forth above, the Insurance Commissioner could implement a regulatory affordability standard as a requirement for approval of health insurance rate filings. These model regulations provide for specific standards of affordability of health insurance premiums, including a provision that limits the rate of growth of hospital inpatient and outpatient rates in provider contracts. The model is based on rules in Rhode Island that limit the aggregate increase in health insurers’ contracts with hospitals to the annual rate of inflation, calculated as the Consumer Price Index – Urban plus 1 percent.[3] In addition to establishing the affordability standard, the model regulations provide for monitoring and enforcement.
Affordability Standard for Hospital Contracts
- Applicability. The Affordability Standard set forth in this Section shall apply to contracts between a health insurer and a hospital licensed in the state which are entered into, renewed, or amended on or after [January 1, 2022]. To ensure compliance with this Section, in the event of any hospital conversions, mergers, acquisitions, or changes of ownership or control, the health insurer shall, in terms of calculating the rate increase, treat the contract of the successor hospital or entity as a continuation of the contract of the predecessor hospital or entity with whom the health insurer had contracted.
- Affordability Standard. Each health insurer shall include in its hospital contracts a provision that agrees on rates for each contract year. Review and prior approval by the Commissioner shall be required if either:
- The aggregate rate increase, calculated as the weighted average increase for inpatient and outpatient services, is greater than the Consumer Price Index for All Urban Consumers: All Items Less Food and Energy(“CPI-Urban”) percentage increase, as determined by the Commissioner by [October 1] each year based on the most recently published United States Bureau of Labor Statistics data, plus one percent (CPI-Urban + 1%), or
- Separation of Inpatient and Outpatient Services. The Commissioner may, in his or her discretion, calculate average rate increases separately for inpatient and outpatient services and require that neither the inpatient nor the outpatient average rate increases in any hospital contract exceed CPI-Urban plus 1 percent.
- The Commissioner, upon petition by a health insurer for good cause shown, or in his or her discretion as necessary to carry out the purposes of the laws and regulations administered by the [Department], may modify or waive one or more of the requirements of this Section. Any such modifications shall be considered and made during the formal process of the Commissioner’s review and approval of health insurance rates filed by the health insurer, or in accordance with a process that the Commissioner may specify.
- Monitoring and Enforcement.
- Monitoring. Health insurers shall provide to the Commissioner in a timely manner and in the format requested by the Commissioner, such data as the Commissioner determines is necessary to evaluate the Affordability Standard and to monitor compliance with the Affordability Standard established in this Section. Such data may include any hospital or provider reimbursement contract, unit cost trends.
- Consent to Public Release. Hospital contracts shall include terms that relinquish the right of either party to contest the public release, by state officials or the parties to the contract of the provisions of the contract demonstrating compliance with the requirements of this Section; provided that the health insurer or other affected party may request the Commissioner to maintain specific contract terms or portions thereof as confidential, if properly supported with legal and factual analysis justifying the claim of confidentiality.
- If any health insurer fails to comply with the requirements of the Affordability Standard set forth in this Section, the Commissioner may take any or all of the following enforcement actions: deny approval of any rate filing application, condition approval on corrective action, require additional monitoring or reporting of data, and/or impose any penalties under the Commissioner’s authority under [citation to code sections].
Further Considerations.
To implement the affordability standard as part of health insurance rate review, the Office of the Insurance Commissioner must have the staffing capacity, budget, and content and actuarial experts (whether in-house or under contract). To assist with enforcement, the department can use its existing authority to conduct market conduct examinations to evaluate the payment rates in health insurance-provider contracts, and to charge the costs of the examination to the insurers.[4]
As drafted here, the affordability standard would only target hospital prices, but future iterations of the model could expand the scope of review beyond hospital services to include professional services, particularly those of physician groups owned by hospitals. Further, the affordability standard could also aim to target increased costs from utilization, not just prices, in the form of an overall revenue cap. Second, once a state has a working affordability standard in place, it can consider ways to address distributional and rate inequities particularly among independent community hospitals, rural hospitals, safety net hospitals that may be paid less than hospitals in larger health systems. Finally, states looking to implement a health care cost growth benchmark could find ways to harmonize the affordability standards with the cost growth benchmark, including coordination of information reporting and review.
It is worth noting that state regulators who have implemented an affordability standard via the health insurance rate review authority recommend keeping the program simple initially, because it is easier to implement and to communicate to policymakers, stakeholders, and the public. Thus, any future adjustments and refinements must be balanced against the costs of increased regulatory complexity.
Notes
[1] For example, North Carolina provides, “No policy of group or blanket accident, health or accident and health insurance shall be delivered or issued for delivery in this State unless the form of the policy contracts including the master policy contract, the individual certificates thereunder, the applications for the contract, and a schedule of the premium rates pertaining to such form or forms, have been filed with and the forms approved by the Commissioner.” N.C. Gen. Stat. § 58-51-85
[2] For example, Georgia provides, “Any . . . insurer that is authorized to write insurance in this state must file with the Commissioner any rate, rating plan, rating system, or underwriting rule at least 45 days prior to any indicated effective date for all insurance other than personal private passenger motor vehicle insurance. No rate, rating plan, rating system, or underwriting rule required to be filed under this subsection will become effective, nor may any premium be collected by any insurer thereunder, unless the filing has been received by the Commissioner in his office not less than 45 days prior to its effective date.” GA. Code Ann. § 33-9-21(d).
[3] 230 R.I. Code R. 20-30-4.10. Earlier, Rhode Island’s regulatory affordability standard was limited to the annual increase in the Medicare Hospital Price index, plus one percent, requiring insurers’ hospital contracts to “Limit average annual effective rates of price increase for both inpatient and outpatient services to a weighted amount equal to or less than the Centers for Medicare and Medicaid Services (CMS) National Prospective Payment System Hospital Input Price Index (“Index”), for all contractual and optional years covered by the contract.” (effective 2012).
[4] For example, Rhode Island’s market conduct examination authority is codified at 27 R.I. Gen. Laws § 27-13.1-1 to -8. The costs of examinations are paid by the insurers. See 27 R.I. Gen. Laws § 27-13.1-7.
Promoting Maternal and Child Health: Virginia’s Dental Benefit for Pregnant Women
/in Maternal, Child, and Adolescent Health, Policy Featured News Home, Reports Maternal, Child, and Adolescent Health, Oral Health /by Allie Atkeson
Dental care during the perinatal period influences health outcomes for both the parent and child, and can reduce expensive medical care that results from lack of care. With this in mind, Virginia added a pregnancy dental benefit in 2015. With nearly half of pregnancies in the United States financed by Medicaid, Virginia shows how states can play an important role in providing access to dental care for pregnant women through their Medicaid programs.
Access to Perinatal Dental Care and Health Outcomes
Inability to access dental care while pregnant can result in adverse health outcomes. Research indicates that all dental care, including procedures that require dental anesthesia during pregnancy, is safe. Poor oral health is associated with low birthweight, preeclampsia, other pregnancy complications and a lower quality of life. Nationally, 73 percent of women had dental insurance during pregnancy, but only 48 percent received a dental cleaning during pregnancy.
Evidence suggests that prenatal oral health care can improve children’s oral health by reducing the incidence of Early Childhood Caries (ECC). ECC is the presence of decayed, missing or filled tooth surfaces in primary (baby) teeth in a child under the age of 6. ECC can lead to emergency room visits and negatively impact school performance. Dental caries (tooth decay) is the most common chronic disease in US children ages 6 to 19 years. Additionally, children are at a higher risk for tooth decay if their birth parent has untreated tooth decay. Parents’ oral health behaviors and dental care utilization can influence children’s risk of dental caries.
Despite overall oral health improvement in the United States over the past several decades, racial and economic disparities persist. Access to dental clinics, insurance status, financial resources and underrepresentation of people of color in the dental workforce are cited as structural barriers for accessing dental care for people of color. These disparities are evident in children, pregnant women and adult populations:
- Latino children, regardless of insurance type, visit the dentist less frequently than white children and are more likely from age two to five have cavities.
- Black and Hispanic pregnant women are less likely to receive dental care, including teeth cleanings before or during pregnancy, than white women.
- Over 40 percent of low-income and non-Hispanic Black adults experience tooth decay, and low-income adults are three times as likely to have four or more untreated cavities as adults with higher incomes.
Dental Care for Pregnant Women in Medicaid
While state Medicaid programs are required to cover dental services for children under 21 as a part of the Early and Periodic, Screening, Diagnostic and Treatment (EPSDT) benefit, dental services for adults are optional in Medicaid. However, 36 states and Washington, DC provide services beyond emergency dental situations; 22 states and Washington, DC provide extensive services for adults, and 29 states and Washington, DC offer an extensive benefit to pregnant women. State benefit packages vary from state to state and generally fall into the following categories:
- Emergency services only;
- Limited services: a cap of $1,000 annually and fewer than 100 American Dental Association (ADA) identified services; or
- Extensive coverage: a cap greater than $1,000 dollars annually and more than 100 ADA identified services including major restorative procedures.
The American Academy of Pediatric Dentistry and the American College of Obstetricians and Gynecologists recommend diagnostic, preventative, restorative, emergency and periodontal care for pregnant women.
When states face revenue shortfalls, they tend to cut optional services, including dental services for pregnant women. For example, 19 states restricted their dental programs during the great recession and only 8 states restored their dental benefit between state fiscal years 2013 and 2016. Despite these fiscal constraints, Virginia expanded health benefits to pregnant women, citing the importance of good oral health for overall health and impact on child oral health.
Virginia’s Dental Benefit for Pregnant Women
Recognizing the importance of oral health in overall health and its key role in healthy birth outcomes, Virginia added a dental benefit in 2015. It was introduced as part of Gov. McAuliffe’s A Healthy Virginia Plan, which proposed expanding services to over 200,000 Virginians, including dental benefits to 45,000 pregnant women in Virginia. The initial cost for the program was 1.9 million over the 2014-2016 biennium budget.
In Virginia, pregnant women over age 21 with incomes less than 148 percent of the Federal Poverty Line (FPL) are covered by Medicaid, and pregnant women with incomes between 148 and 205 percent FPL are covered by the Family Access to Medical Insurance Security (FAMIS) program, which is Virginia’s Children’s Health Insurance Program (CHIP). Dental services are delivered either by the individual’s selected medical managed care organization (MCO) or through fee-for-service. All pregnant women receive dental services through the state’s Smiles For Children program, provided by a dental benefits manager (DBM). The dental benefit ends at the end of the month following an individual’s 60th day postpartum.
Virginia requires coordination between the Medicaid MCOs and the DBM. The Medicaid managed care request for proposals (RFP) outlines the MCO’s role for coordination with the DBM on outreach for dental service utilization. According to state officials, the Commonwealth has also established relationships between MCOs and the DBM to assist pregnant members in locating dentists and securing appointments.
State officials noted that there is still skepticism about going to the dentist while pregnant. This presents the state with an opportunity to collaborate with MCOs and the DBM to educate enrollees about the safety of services and the new benefit.
A staff member with the DBM is responsible for collaboration efforts including education and training. Virginia Medicaid MCOs work to promote dental services with pedicitricians, family practices and OB/GYNS through the Smiling Stork Program. The Smiling Stork program educates women about the importance of being screened for periodontal disease during pregnancy, the value of establishing good oral health habits for their babies, and how to access covered dental services during pregnancy.
The addition of dental services for pregnant women in Medicaid has yielded positive results for Virginia. Pregnancy Risk Assessment Monitoring System (PRAMS) data show that the number of pregnant women receiving dental services doubled from 2014 to 2019. The Virginia Department of Health created practice guidance for prenatal and dental providers, and it conducts outreach to maternity clinics to promote dental care access.
The expanded dental benefit was initially funded for three years. The Department of Medical Asssistance Services (DMAS), Virginia’s Medicaid program, engaged the Dental Advisory Committee and other stakeholders to maintain the expanded benefit. State officials cite strong internal collaboration among IT staff, health care services, maternal and child health, training and transportation, and executive leadership as key for successful implementation of the benefit.
Implications
Recent state Medicaid coverage expansions and a concerted focus on improving maternal health provide opportunities for states to ensure dental services for pregnant women. The expansion of dental services for pregnant women in Virginia was a part of broader coverage expansion introduced by Gov. McAuliffe, with the 2015 dental benefit for pregnant women predating Medicaid expansion in 2019 and an adult Medicaid dental benefit in 2020.
Virginia also recently submitted an amendment to its 1115 demonstration waiver to extend postpartum Medicaid coverage to 12 months. This expansion would include dental benefits, as “full benefit coverage is essential to meeting the needs of the state’s postpartum women.” The demonstration waiver amendment includes an evaluation plan to determine the impact of postpartum coverage on reducing the rate of maternal mortality, morbidity and racial disparities among postpartum women and infants.
As Virginia expands services for pregnant and postpartum women, there is an increased focus on quality care during the perinatal period at the state and federal level. The Mothers and Offspring Mortality and Morbidity Awareness (MOMMA’s) Act introduced in the House of Representatives and Senate would extend Medicaid coverage to 12 months postpartum and require states to cover preventative, diagnostic, periodontal and restorative care during pregnancy and the postpartum period. Additionally, the recently passed American Rescue Plan gives states the option to extend Medicaid coverage to 12 months postpartum through a state plan amendment (SPA). States seeking to expand postpartum coverage through a waiver may select the SPA option.
Another introduced bill, S. 560, the Oral Health for Moms Act, aims to expand dental services for pregnant women. This bill would require Medicaid and CHIP to cover dental services for pregnant and postpartum women and make dental services an essential health benefit for pregnant women who receive health insurance through the federal marketplace or small group markets. The bill would also:
- Provide grants to federally qualified health centers (FQHCs) for dental services;
- Create an oral health initiative through the Indian Health Service to address barriers to oral health for American Indian and Alaskan Native populations;
- Require the Medicaid and CHIP Payment and Access Commission to issue a maternal oral health care report;
- Establish a perinatal oral health outreach and education program to provide information on best oral health practices and connect pregnant and postpartum individuals and children to oral health care; and
- Integrate oral health care into maternal health care settings through grants to state health departments and agencies to develop trainings on oral health for maternal health providers.
With national attention on Medicaid coverage for the postpartum period, states can consider including dental services as a component of perinatal health care. New federal options including the MOMMA’s Act, ARPA, and Senate Bill 560 may allow states to expand dental services to pregnant women and lengthen the duration of services; recently introduced federal legislation might further increase opportunities for states. Experience from Virginia can serve as a case study for states looking to expand access to dental services during the perinatal period and improve maternal health outcomes.
Acknowledgement: This project is supported by the Health Resources and Services Administration (HRSA) of the US Department of Health and Human Services (HHS) under grant number U2MOA394670100, National Organizations of State and Local Officials. This information or content and conclusions are those of the author 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. The author would like to thank the Virginia state officials, including Dr. Hairston who helped review and provide feedback on this blog.
What Family Caregivers Need: Findings from Listening Sessions
/in The RAISE Act Family Caregiver Resource and Dissemination Center Featured News Home, Reports The RAISE Family Caregiver Resource and Dissemination Center /by University of Massachusetts at Boston and Community Catalyst
The family caregiver listening sessions included a range of diverse caregivers, from teen caregivers to grandparents providing care, and caregivers of varying racial and ethnic backgrounds. The listening sessions directly captured the emotional and financial stresses caregivers experience, and their priorities and concerns, including respite, caregiving education and training, and financial considerations, including direct pay for caregiving, workplace flexibility, and tax policy changes that support caregivers.
This report is a publication of NASHP’s RAISE Family Caregiver Resource and Dissemination Center and was made possible by funding from The John A. Hartford Foundation in collaboration with ACL.
Opioid Use Disorder Treatment: How Vermont Integrated its Community Treatment Standards into its State Prisons
/in Policy Vermont Featured News Home, Reports Behavioral/Mental Health and SUD /by Eliza Mette and Jodi ManzConfronted with Overdoses, Rhode Island’s Emergency Departments Employ Peer Services to Promote Treatment
/in Policy Featured News Home, Reports Behavioral/Mental Health and SUD, Care Coordination, Chronic and Complex Populations, Maternal Health and Mortality, Maternal, Child, and Adolescent Health, Physical and Behavioral Health Integration /by Jodi Manz and Kitty PuringtonDrug overdose deaths nationwide have continued to rise during the COVID-19 pandemic, exceeding 88,000 between August 2019 and August 2020, signaling a critical need for substance use disorder (SUD) treatment services and the workforce to provide them. Non-fatal overdoses, which are a predictor of future fatal overdoses, also rose, leading to an increase in opioid-related emergency department (ED) visits even as overall ED visits declined during the pandemic.
While overdose-related ED incidents are traumatizing to individuals and costly to payers – especially state Medicaid programs – Rhode Island has found that hospital emergency rooms can be low-barrier and successful access points to SUD treatment with the right crisis response – including peer services – in place.
Background
Peer recovery services for substance use disorder (SUD) have been demonstrated to help individuals stay in treatment, increase satisfaction with treatment experiences, and reduce rates of return to use.
Responding to existing and projected behavioral health workforce shortages, states are building capacity for SUD treatment by developing certification pathways and reimbursement structures for peers as a non-licensed, supportive workforce.
Rhode Island, and 38 other states, have integrated the use of peers as care team members who can provide Medicaid-reimbursable, non-clinical treatment and recovery support services. In 2014, the state developed an innovative model, AnchorED, that introduced peers into hospital EDs to link patients who experienced overdoses with treatment and recovery. This program is the result of cross-agency collaboration among Rhode Island’s Department of Health (RIDOH), Department of Behavioral Health, Developmental Disabilities and Hospitals (BHDDH), the Providence Center (a community behavioral health provider), and Anchor Recovery Community Centers.
Currently, post-overdose peer services are accessible at all hospitals in the state – with the exception of a Veterans’ Affairs hospital – and peers who provide services are available 24 hours a day, seven days a week. Early evaluation of AnchorED showed that in the program’s first year, peers had contact with 1,329 patients. Among those patients, 88.7 percent were trained to use naloxone and 86.8 percent agreed to engage with a peer after hospital discharge. Further evaluation showed that ED providers consulted with peers in over 85 percent of overdose cases, and referral to treatment upon discharge increased from 9 to nearly 21 percent.
Building Blocks for Rhode Island’s AnchorED Program
State Leadership
State leadership ensures that peer services are recognized as a valuable component of opioid/substance use disorder (OUD/SUD) systems in Rhode Island. The Rhode Island Governor’s Overdose Prevention and Intervention Task Force, established through an Executive Order in 2015, provides a forum for consistent communication related to all SUD-related initiatives and has been important in promoting the peer workforce. This group, composed of stakeholders as well as state policy leaders, is co-chaired by the directors of the RIDOH and BHDDH, the two agencies that were instrumental in implementing policy for peer services in hospital EDs. In 2017, the governor signed another Executive Order making additional policy actions in response to the needs of the state emerging from the task force, including several initiatives supporting peer services that align to the task force’s Action Plan. Outcomes, including data on the number of peer recovery specialists (PRS) in the state and the number of services they provide, are reported on regularly updated public dashboards.
Data for 2020 showed an increase in the number of newly trained PRS, which reached 958 by September, and new client enrollments in services, which has increased steadily from a low point in April, 2020, likely related to the COVID-19 pandemic. The task force, which continues to hold open monthly meetings, recently issued an updated strategic plan that includes goals to further expand and enhance the peer recovery workforce. Task force meeting notes and presentation archives are also publicly posted.
Rhode Island state leaders were also engaged in concurrent efforts on workforce development as a component of their State Innovation Model (SIM) project. The state’s Health System Transformation Program published a Healthcare Workforce Transformation report that advocated expanding the role of peers as members of integrated behavioral health teams. The report recommended providing a pathway for state certification for peers as a strategy to build behavioral health workforce capacity with non-clinical team members in supportive roles.
Infrastructure
Rhode Island, through a number of policy actions, has created a regulatory framework that supports delivery of peer services in hospital EDs. In 2016, the state passed legislation that requires hospitals to submit comprehensive discharge plans to its health department director and outlines specific requirements for post-overdose patient care. Aligning with this statute, RIDOH and BHDDH developed standards for hospital EDs, requiring integration of peer services into ED overdose response across all state hospitals, as well as Freestanding Emergency Care Facilities (FECF) that provide emergency services outside of a hospital’s structure. The agencies delineated these standards in the Levels of Care for Rhode Island Emergency Departments and Hospitals for Treating Overdose and Opioid Use Disorder, creating three levels of certification for EDs across the state. In order to gain certification at any of these levels, hospitals and EDs are required to complete and submit a self-assessment that reviews where each facility falls on the continuum of services identified in the standards.
Rhode Island Hospital Levels of Care Standards
| Level 3: Minimum standards – indicating readiness and capacity to: | Level 2: These certified facilities must meet Level 3 criteria, and also show capacity to: | Level 1 In addition to meeting levels 1 and 2 criteria, these certified facilities must: |
| 1. Offer peer recovery support services in their emergency departments.
2. Follow the discharge planning standards as stated in current law. 3. Administer standardized substance use disorder screening to all patients. 4. Educate all patients who are prescribed opioids on safe storage and disposal. 5. Dispense naloxone for patients who are at risk, according to a clear protocol. 6. Provide active referral to appropriate community provider(s). 7. Comply with requirements to report overdoses within 48 hours to RIDOH. 8. Perform laboratory drug screening that includes fentanyl on patients who overdose. |
1. Conduct comprehensive standardized substance use assessments.
2. Maintain capacity for evaluation and treatment of opioid use disorder using support from addiction specialty services. |
1. Maintain a Center of Excellence or comparable arrangement for initiating, stabilizing, and re-stabilizing patients on medication-assisted treatment:
· Evaluate and manage medication assisted treatment, and · Ensure transitioning to/from community care to facilitate recovery. |
These standards for EDs also inform licensing regulations for both hospitals and Freestanding Emergency Care Facilities (FECF) in Rhode Island. Those regulations require that overdose patients and/or patients who are evaluated and found to have SUD are informed of available treatment services and that those patients are offered an opportunity to speak with a PRS. RIDOH also encourages hospitals in Rhode Island to use the BHDDS model consent form language for peer services, facilitating patient consent to both peer and medical services simultaneously. This approach to incorporating peer services into hospital consent forms was mandated by the legislature in 2018.
At this time, the standards are currently under revision by a workgroup of state leaders and stakeholders to identify and address gaps in alignment between the standards and the provider experience. These revisions, however, are not expected to lead to changes in the regulations.
Workforce Development
As officials developed certification requirements for peers, members of the peer community and people in recovery from SUD explained that being paid to help others conflicted with an important tenet of their personal journeys, which is to give freely of their time helping others with SUD and “pay it forward.”
The state began laying the groundwork for peer certification in 2012 when BHDDH began trainings for mental health peer recovery specialists through certification planning developed as part of the Substance Abuse and Mental Health Services Administration’s (SAMHSA) Transformation Transfer Initiative (TTI). In 2014, the Rhode Island Certification Board (RICB) – not a state entity – began certifying SUD peer recovery specialists as well, this led to BHDDH ultimately integrating mental health and SUD peer recovery trainings after the state brought together stakeholders through SAMHSA’s Bringing Recovery Supports to Scale Technical Assistance Center Strategy (BRSS TACS) program.
Peer certification in Rhode Island begins with the state’s integrated peer recovery and mental health training provided through Anchor Recovery. Requirements include:
- 46 hours of didactic learning across four domains (advocacy, mentoring/education, recovery/wellness support, and ethical responsibility)
- 500 internship hours, including or in addition to 25 supervised hours.
- Evidence of passing the International Certification and Reciprocity Consortium (IC&RC) peer recovery certification exam. To prepare for the exam, IC&RC provides a Candidate Guide, and BHDDH contracted with JSI International to develop the Rhode Island Peer Recovery Specialist Certification Study Guide.
Peers delivering services in Rhode Island must receive ongoing supervision from either licensed health care practitioners or certified peers who provided peer services for at least two years. Supervisors must also complete BHDDH-approved core competency training provided through a contract with Anchor Recovery. Agencies providing peer services must maintain a ratio of 1 supervisor for every 10 peer full-time-equivalents, and document provision of supervision totaling at least two hours per month or 30 minutes per week. Agencies must also provide at least a monthly opportunity for group meetings for working peers. In order to deliver services, these agencies must also be certified by BHDDH as Peer Based Recovery Support Services (PBRSS) providers and can use the PBRSS Provider Billing Manual to bill for services.
State Investment and Resources
Initial grant funding. Peers initially began meeting with overdose patients in hospital EDs as a volunteer engagement opportunity supported by Providence Center’s Anchor Recovery, a community recovery organization established in 2010 and funded through the state’s Substance Abuse Prevention and Treatment (SAPT) block grant.
Direct patient crisis response in partnership with a community organization was a familiar approach for the first Rhode Island hospital site to provide SUD peer services. The hospital already had an agreement with a local intimate partner violence organization that allowed volunteers to connect with patients in the ED. The hospital also maintained an agreement with the Providence Center to provide a clinician to triage and assess patients who came into the ED indicating mental health and SUD-related needs. Initial grant funding and existing relationships helped to facilitate development of peer integration.
Medicaid reimbursement. In the long term, paying for peers meant developing a source of sustainable funding for the program, and Rhode Island’s health policy leaders saw an opportunity to reimburse for peer services in Medicaid. While states have a variety of authority options to cover recovery support services in Medicaid, including health home models and 1915(b) and 1915(c) waivers, Rhode Island is one of nine states to provide these services under an 1115 demonstration waiver, submitted to the Centers for Medicare & Medicaid Services (CMS) in 2016 and approved in 2018. The waiver specifies that reimbursable services under the authorized Recovery Navigation Program (RNP) and Peer Recovery Specialist (PRS) Program include “an array of interventions that promote socialization, long-term recovery, wellness, self-advocacy, and connections in the community,” delivered as part of a care team.
Rhode Island’s waiver requires the state to credential peers using the International Certification & Reciprocity Consortium (IC&RC) exam and to develop standards for peer supervisors, as outlined in the previous section. The Rhode Island waiver created a bundled payment, which incorporates services provided by peer recovery specialists as part of the Recovery Navigation Programs. Services outside of such programs, which include those provided in EDs, are billed by the Medicaid-enrolled provider organization employing the PRS and are paid as a flat fee – peer services are reimbursed by Medicaid at rates of $13.50/15 minute unit for one-on-one services and $4/15 minute unit for up to 10 participants for group services.
Reporting and Outcomes
State regulations require that hospitals must report all opioid overdoses to RIDOH within 48 hours through a case report form that captures information about the patient and the overdose event. Additionally, AnchorED captures and reports on each unique patient contact, including data describing whether peer or other counseling services were accepted by the patient. Patients may also be referred to outpatient MOUD treatment, admitted to detox, or refuse engagement altoghter. This data is reported to the state by each hospital as de-identified, aggregate demographic and incident data. This is used to inform state leaders about who is seeking services and what factors may be leading to overdose, and how services are being initiated by PRS.
Anchor Recovery peer specialist services include:
- Linking individuals to treatment and recovery resources;
- Educating about overdose, prevention, and how to obtain naloxone, a drug that reverses the effects of an opioid overdose when administered quickly;
- Providing additional resources to individuals and family members; and
- Contacting the individual after release from the ED with a follow-up phone call.
Source: Anchor Recovery
AnchorED reports:
- Average minutes between contact and team connection to a patient;
- Whether naloxone training was done;
- Whether an individual agreed to see a PRS;
- Whether an individual agrees to a treatment referral; and
- Whether an individual agrees to initiating MOUD that day.
State agencies use these data sets to track outcomes and understand how hospitals are engaging individuals after an overdose to ensure connections to treatment are made. Rhode Island’s overall SUD response strategy includes collection and analysis of treatment and recovery data, and the state uses its Prevent Overdose RI website as a platform to publicly report on measures. ED overdose visits are reported publicly on a monthly basis, along with location and naloxone provision data, and the AnchorED outcomes of patient engagement. Reports include quarterly numbers showing total ED visits, as well as post-overdose counseling, which was accepted by 26 percent of overdose patients in the most recent data reported for the fourth quarter of 2020. Data for that time period also shows that of a total 267 overdose patients, with 45 percent receiving naloxone before being discharged from the hospital.
Challenges and Considerations in Maximizing Peer Workforce
Engage stakeholders. Peer stakeholders have been engaged with policymakers since the inception of the AnchorED program. These relationships helped to develop the policies that support the program, particularly for peer certification requirements. Stakeholder and cross-agency communication continues to drive policy in Rhode Island; regular informal communication through weekly calls among PRS contractors/peer recovery organizations, ED providers, law enforcement, detox centers, and state agencies has been key to identifying emerging trends and resulting needs.
Build workforce diversity. Several state leaders and stakeholders noted that diversity is lacking in the existing peer workforce and suggested that targeted recruitment of peers who are people of color, are bilingual, and/or identify as LGBTQ may help better meet the state population’s needs. A February 2021 update to the Governor’s Task Force – which has recently created a Racial Equity Workgroup – prioritizes this as a goal for the state’s recovery work, listing recruitment and training of people of color and those who speak languages other than English as a short-term recommendation.
Delineate peer roles. While the goals of peer engagement include patient retention and continuity of care, ED providers and stakeholders repeatedly stressed that connecting overdose patients to medications to treat opioid use disorder (MOUD) was the most important intervention to reduce overdose death. Providers noted concern regarding peers advocating for patients to choose either MOUD or abstinence-based recovery, a clinical decision that may test role definition and boundaries. While they emphasized that most peer-to-patient interactions are not clinical in nature and do not include discussions of medical interventions, there have been occasions when providers felt that peers may be overstepping in their roles by dissuading overdose patients from initiating MOUD. Providers and peers alike are mindful of existing tension in the recovery community regarding the use of medications. Abstinence-based recovery programming sometimes discourages medications, though this perspective is far from universal. In the most recent Governor’s Task Force strategic plan update, Rhode Island included a goal to develop PRS who focus on supporting patients in MOUD treatment, and to integrate these specialty PRS into services across the SUD continuum of care.
Identify hiring barriers. When Rhode Island first shifted toward employing peers to work within the hospital, leaders within the recovery organization and the hospital system had to decide whether peers would need to go through hospital system human resources checks and procedures, which may have posed barriers to peers being able to work in the hospital environment due to felony backgrounds or other prior issues. Rhode Island determined that the best course of action was to have peer candidates evaluated as part of the the recovery organization’s human resources to avoid this. Within some health systems, internal hospital policies can prevent the hiring of individuals with felony records, a challenge for some people in recovery who had past convictions. To mitigate this, states can consider approaches in which peers are hired by the organizations that bill for peer services rather than directly by hospitals.
Conclusion
The importance of relationships across systems and among team members in developing and integrating peer services in EDs was a dominant theme in interviews with state leaders and stakeholders. Relationships between the recovery community and hospital clinicians were already in place before AnchorED became a Medicaid-reimbursable model, and leaning on those relationships was key to licensure and Medicaid policy creation. Further, the relationships that develop between team members when providing peer services in the ED help to reduce stigma. As one peer leader said, integrating “education along the way” by talking with providers about the realities of active use and the fears that emerge from it helped humanize recovery for ED providers. Rhode Island’s leaders routinely pointed to the small size of the state and the opportunity that affords them to develop such relationships across systems. While the state’s small size is a unique factor that cannot be replicated, it suggests that states can support regional relationships among community behavioral health, community recovery organizations, and hospital systems through formal regional networks and activities.
Acknowledgements: This brief was supported by the Health Resources and Services Administration (HRSA) of the US Department of Health and Human Services (HHS) as part of a financial assistance award under the National Organizations of State and Local Officials cooperative agreement. The contents are those of the authors and do not necessarily represent the official views of, nor an endorsement, by HRSA/HHS, or the US government. The authors would like to thank HRSA project officer Diba Rab for her support and guidance. Further, the authors would like to acknowledge the dedication, leadership, and input of Rhode Island state agency leaders and staff, as well as providers, stakeholders, and peers who contributed to this brief.
Sign Up for Our Weekly Newsletter
Sign Up for Our Weekly Newsletter
Washington, DC Office:
1233 20th St., N.W., Suite 303Washington, DC 20036
p: (202) 903-0101
f: (202) 903-2790
Contact Us
Phone: 202-903-0101


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. 























































































































































