BILL ANALYSIS Ó
AB 1231
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Date of Hearing: May 20, 2015
ASSEMBLY COMMITTEE ON APPROPRIATIONS
Jimmy Gomez, Chair
AB
1231 (Wood) - As Introduced February 27, 2015
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Urgency: No State Mandated Local Program: NoReimbursable: No
SUMMARY:
This bill adds "nonmedical transportation" (NMT) to the schedule
of Medi-Cal benefits, where nonmedical transportation means
transportation by public or private conveyance for a beneficiary
to obtain covered specialty care Medi-Cal services, if those
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services are more than 60 minutes or 30 miles from the
beneficiary's place of residence.
FISCAL EFFECT:
Unknown cost pressure, potentially in the range of $1 million in
Medi-Cal managed care, and low hundreds of thousands in direct
costs in fee-for-service (FFS) Medi-Cal annually (GF/majority
federal). Due to data limitations this estimate is fairly rough,
it assumes a small percentage of rural Medi-Cal enrollees
receives transportation services each year for a single
specialty visit; is based on 20,000 additional transports in
managed care, and 5,000 in FFS annually at a cost of $50 per
transport. The cost of mandating NMT as a covered benefit in
Medi-Cal depends on several factors, which are in turn subject
to significant uncertainty and change. Some additional cost
dynamics and cost offsets are described below:
1)To the extent better access to transportation increases
utilization of specialty care services, additional unknown
costs in FFS and cost pressure on managed care rates for more
specialty care visits. These increased costs for specialty
care would be offset to some extent by cost savings from
better management of chronic conditions, fewer complications,
and reduced emergency room use. It is difficult to say, based
on the number of increased transports, what percentage of
specialty visits would be made regardless of the availability
of transportation.
2)Managed care plans, as well as the Department of Health Care
Services (DHCS), are likely to experience some administrative
costs to institute policies and procedures to ensure coverage
complies with the defined standards. The coverage of a
benefit subject to geographic standards based on an enrollee's
home location and the potential location of services appears
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to be novel within Medi-Cal, and would necessitate some tool,
either automated or manual, to decide whether services are
indeed covered, as well as to facilitate audits and oversight
of the provision of this benefit.
3)The actual impact on managed care rates from the potential
increased cost pressure identified here is unknown and may
depend in part on how it compares to what plans currently
provide. Since some plans already provide NMT at their option,
mandating broader coverage of transportation services for
specialty care visits with specified distance criteria is
likely to affect different plans differently. Voluntary NMT
coverage by some plans suggests potential benefits and/or cost
savings may be significant compared to cost. However, many
plans that cover NMT also impose conditions on such coverage.
4)Since the coverage of NMT is only available for visits that
meet a certain time/distance standard, to the extent provider
networks in both managed care plans and FFS Medi-Cal grow more
robust, the demand for transportation services would decrease.
The inverse is also true; if networks grew more sparse,
demand for transportation would increase based on a higher
likelihood that visits meet the defined standard.
5)Utilization of transportation services for specialty visits,
and corresponding costs, could also vary dramatically based on
whether beneficiaries and providers know it is a covered
benefit, and how easy it is to access.
6)The bill requires the transportation be provided "in a form
and manner that is the most beneficial and accessible, in
terms of physical and geographic accessibility, for the
beneficiary." This provision could pose significant additional
fiscal risk beyond what is assumed here, as the "most
beneficial" methods are likely to be the most expensive-for
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example, private conveyance is arguably more beneficial than
public conveyance.
COMMENTS:
1)Purpose. The author states this bill ensures low-income
beneficiaries in rural areas have access to transportation for
their specialty care needs. It is sponsored by the Western
Center on Law and Poverty, who works closely with health law
programs throughout the state that report severe accessibility
challenges for specialty visits, particularly among rural
Medi-Cal enrollees and particularly given the recent expansion
of managed care to rural counties.
2)Background. DHCS distinguishes between Non-Emergency Medical
Transportation (NEMT), which is medical transportation but on
a non-emergency basis, and Non-Medical Transportation (NMT),
which is ordinary transport to medical services by passenger
car, taxicabs, or other forms of public or private
conveyances. NEMT is a covered benefit for all enrollees as
it is provided when transport by ordinary means of public or
private conveyance is medically contraindicated, and
transportation is required for the purpose of obtaining needed
medical care. However, NMT (i.e., "ordinary" transportation
of enrollee to medical services) is only provided to children
and individuals enrolled in the Coordinated Care Initiative,
a demonstration project in certain counties for those dually
eligible for Medicare and Medi-Cal. This bill would make NMT
a covered benefit for all enrollees, but only for visits to
specialty care providers that meet certain time/distance
standards.
Federal regulations require the state to provide "necessary"
transportation services to and from medical appointments.
Supporters note the Medi-Cal state plan "assures"
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transportation to and from health care services, and consider
this bill further clarification of what the state plan already
requires, but is not being implemented.
3)Staff Comments. As discussed in fiscal comment (6), the
provision requiring the "most beneficial" form of transport
could drive up costs unnecessarily. If the author's intent is
to ensure accessibility for individuals with disabilities,
this provision should be clarified to allow reasonable cost
management as it pertains to transportation methods.
Analysis Prepared by:Lisa Murawski / APPR. / (916)
319-2081