BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2645
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          ASSEMBLY THIRD READING
          AB 2645 (Chesbro)
          As Introduced February 19, 2010
          Majority vote 

           HEALTH              18-0        APPROPRIATIONS      15-0        
           
           ----------------------------------------------------------------- 
          |Ayes:|Monning, Fletcher,        |Ayes:|Fuentes, Conway, Ammiano, |
          |     |Ammiano, Carter, Conway,  |     |Coto, Davis, Bonnie       |
          |     |Caballero, Emmerson, Eng, |     |Lowenthal, Hall, Harkey,  |
          |     |Gaines, Hayashi,          |     |Miller, Nielsen, Norby,   |
          |     |Hernandez, Jones, Bonnie  |     |Skinner, Solorio,         |
          |     |Lowenthal, Nava,          |     |Torlakson, Hill           |
          |     |V. Manuel Perez, Salas,   |     |                          |
          |     |Smyth, Audra Strickland   |     |                          |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Expands current law which imposes a reimbursement rate  
          freeze on specified skilled nursing facilities (SNFs) to include  
          institutions for mental disease (IMDs) licensed as SNFs.  

           EXISTING FEDERAL LAW  :

          1)Defines an IMD as a hospital, nursing facility, or other  
            institution of 17 or more beds that is primarily engaged in  
            providing diagnosis, treatment, or care of persons with mental  
            diseases, including medical attention, nursing care, and  
            related services. 

          2)Establishes the IMD exclusion, which prohibits federal  
            financial participation through Medicaid (Medi-Cal in  
            California) for individuals in an IMD between the ages of 22  
            and 65.  These individuals may still be eligible for  
            state-only Medi-Cal.

           EXISTING STATE LAW :

          1)Requires the Department of Health Care Services (DHCS) to  
            contract with SNFs that have been designated by the Department  
            of Mental Health as IMDs to provide services to residents.

          2)Establishes the Bronzan-McCorquodale Act, also known as  
            "Realignment," which shifted responsibility for the provision  








                                                                  AB 2645
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            of mental health services from the state to counties.   
            Provides funding for local programs with revenues from  
            increased vehicle licensing fees and sales taxes.

          3)Imposes a rate freeze on the following long term care  
            facilities: SNFs, intermediate care facilities, rural  
            swing-bed facilities, subacute and pediatric subacute care  
            units that are distinct parts of general acute care hospitals,  
            and adult day health centers. 

          4)Requires IMDs licensed as SNFs to be reimbursed for services  
            at the rate established by DHCS.  Mandates, effective July 1,  
            2008, an annual 4.7% increase in the reimbursement rate for  
            IMDs.    

           FISCAL EFFECT  :  According to the Assembly Appropriations  
          Committee, annual county savings in the range of $3 million to  
          $5 million for the first year a rate freeze for IMDs is in  
          effect. The accumulation of future county savings would depend  
          on changes in the SNF rate freeze statute. 

           COMMENTS  :  The sponsor of this bill, the California Mental  
          Health Directors Association (CMHDA), notes that federal law  
          statutorily prohibits federal Medicaid funds from being used for  
          the treatment of individuals who are in facilities that are  
          licensed as IMDs.  Due to this federal "IMD exclusion" and  
          California's existing Realignment policies that make counties  
          responsible for the provision of mental health services,  
          California counties must pay for 100% of the cost of services  
          for patients in IMDs.  Current state law requires counties to  
          indefinitely pay DHCS-licensed SNF IMDs a 4.7% increase to their  
          annual rates.  CMHDA maintains that this rate increase is  
          unsustainable for counties given that every dollar spent by  
          counties on the escalating costs of SNF IMD care, the most  
          restrictive level of care available in the community, is one  
          less dollar available to counties for other community-based  
          services.  While the State Budget Act of 2009 (AB 5 X4 (Evans)),  
          Chapter 5, Statutes of 2009-10, Fourth Extraordinary Session)  
          froze nursing home rates for many licensed facilities at 2008-09  
          levels, the rate freeze excluded SNF IMDs. CMHDA argues that,  
          without the change in law proposed by this bill, counties must  
          use significantly reduced funding streams to pay for IMD-level  
          care.  This bill is intended to enable counties that are  
          currently facing serious economic difficulties to allocate the  








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          dollars they save from the rate freeze toward other  
          community-based programs and services. 

          IMDs are a type of SNF with 17 or more beds that provide 24-hour  
          nursing care and supervision to mentally ill persons in need of  
          continuous psychiatric and nursing care.  Federal law excludes  
          these facilities from eligibility for federal Medicaid funds  
          when serving Medicaid clients.  This federal IMD exclusion  
          applies only to adult Medicaid beneficiaries between the ages of  
          21 and 65.  In California, IMDs include facilities in the  
          following licensing categories, if the facility has 17 beds or  
          more: acute psychiatric hospitals, psychiatric health  
          facilities, SNFs with a certified special treatment program, and  
          mental health rehabilitation centers.  According to the  
          Department of Public Health, which licenses SNFs, there are 15  
          IMDs statewide that would be affected by the rate freeze  
          proposed in this bill.  

          The California Association of Health Facilities (CAHF),  
          representing IMD providers in the state, opposes this bill  
          unless it is amended to impose a one year rate freeze for IMDs,  
          effective July 1, 2010, through June 30, 2011.  CAHF argues  
          that, while it recognizes the economic realities that counties  
          face during these fiscal times, freezing IMD rates permanently  
          does not make sense given the increasing costs of providing  
          services.  CAHF contends that a one year rate freeze seems to be  
          reasonable in light of current budgetary issues.  Lastly, CAHF  
          asserts that there needs to be some basis to adjust IMD rates  
          going forward and adds that since IMDs are licensed SNFs and  
          have similar operating costs, it makes sense to tie rate  
          increases to the actual cost increases for SNFs.

           
          Analysis Prepared by  :    Cassie Rafanan / HEALTH / (916)  
          319-2097 


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