BILL ANALYSIS Ó SB 586 Page 1 SENATE THIRD READING SB 586 (Hernandez) As Amended August 2, 2016 Majority vote SENATE VOTE: 40-0 ------------------------------------------------------------------ |Committee |Votes|Ayes |Noes | | | | | | | | | | | | | | | | |----------------+-----+----------------------+--------------------| |Health |18-0 |Wood, Maienschein, | | | | |Bonilla, Burke, | | | | |Campos, Chiu, Gomez, | | | | |Roger Hernández, | | | | |Lackey, Nazarian, | | | | |Olsen, Patterson, | | | | |Ridley-Thomas, | | | | |Rodriguez, Santiago, | | | | |Steinorth, McCarty, | | | | |Waldron | | | | | | | |----------------+-----+----------------------+--------------------| |Appropriations |20-0 |Gonzalez, Bigelow, | | | | |Bloom, Bonilla, | | | | |Bonta, Calderon, | | | | |Chang, Daly, Eggman, | | | | |Gallagher, Eduardo | | SB 586 Page 2 | | |Garcia, Holden, | | | | |Jones, Obernolte, | | | | |Quirk, Santiago, | | | | |Wagner, Weber, Wood, | | | | |McCarty | | | | | | | | | | | | ------------------------------------------------------------------ SUMMARY: Extends the sunset date on the California Children's Services (CCS) "carve out" to 2021, and establishes the Whole Child Model (WCM) program for CCS eligible children under the age of 21 in counties with county organized health systems for delivery of Medi-Cal managed care (COHS counties). Specifically, this bill: 1)Prohibits CCS covered services from being incorporated into any Medi-Cal managed care (MCMC) contract (known as the CCS "carve out") entered into after August 1, 1994, until January 1, 2021, with the exception of contracts entered into by county organized health systems (COHS) or regional health authority (RHA) in the Counties of San Mateo, Santa Barbara, Solano, Yolo, Marin, and Napa. 2)Permits Department of Health Care Services (DHCS), no sooner than July 1, 2017, to establish a WCM program for Medi-Cal and State Children's Health Insurance Program (S-CHIP) eligible CCS children and youth enrolled in a managed care plan under a COHS or RHA in the Counties of Del Norte, Humboldt, Lake, Lassen, Marin, Mendocino, Merced, Modoc, Monterey, Napa, Orange, San Luis Obispo, San Mateo, Santa Barbara, Santa Cruz, Shasta, Siskiyou, Solano, Sonoma, Trinity, and Yolo. 3)Establishes the goals for the WCM program for children and youth under 21 years of age who meet CCS eligibility requirements and are enrolled in a managed care plan under a COHS or RHA, including all of the following: SB 586 Page 3 a) Improving the coordination of primary and preventive services with specialty care services, medical therapy units (MTU), Early and Periodic Screening, Diagnosis, and Treatment (EPSDT), long-term services and supports (LTSS), and regional center services, and home- and community-based services using a child and youth and family-centered approach; b) Maintaining or exceeding CCS program standards and specialty care access, including access to appropriate subspecialties; c) Ensuring the continuity of child and youth access to expert, CCS dedicated case management and care coordination, provider referrals, and service authorizations through contracting with or the employment of county CCS staff to perform these functions. d) Improving the transition of youth from CCS to adult Medi-Cal managed care systems through better coordination of medical and nonmedical services and supports and improved access to appropriate adult providers for youth who age out of CCS; and, e) Identifying, tracking, and evaluating the transition of children and youth from CCS to the WCM program to inform future CCS program improvements. 4)Requires neonatology to be included in the CCS program and specifies that the specialty of neonatology is not excluded or restricted from reimbursement under the CCS program, subject to the program's existing or applicable prior authorization SB 586 Page 4 requirements or utilization review. DHCS and MCMC Requirements Prior to Implementation of WCM 5)Requires the director to provide notice to the Legislature, the federal Centers for Medicare and Medicaid Services (CMS), counties, CCS providers, and CCS families when each managed care plan, including a transition plan with the county CCS program, has been reviewed and certified as ready to enroll children based on specified criteria. 6)Requires DHCS, prior to the implementation of the WCM, to develop specific CCS program monitoring and oversight standards for managed care plans, including access monitoring, quality measures, and ongoing public data reporting, and establish a stakeholder process. 7)Requires DHCS, in order to aid the transition of CCS services into MCMC plans participating in the WCM program, commencing January 1, 2017, and continuing through the completion of the transition of CCS enrollees into the WCM program, to begin requesting and collecting from MCMC plans information about each health plan's provider network, and requires DHCS to analyze the existing MCMC delivery system network and the CCS fee-for-service (FFS) provider networks to determine the overlap of the provider networks in each county, and to furnish this information to the MCMC. 8)Prohibits a MCMC plan from being approved to participate in the WCM program unless certain conditions have been satisfied, as specified. 9)Requires a MCMC plan, prior to implementation of the WCM SB 586 Page 5 program, to review historical CCS FFS utilization data for CCS-eligible children and youth upon transition of CCS services to managed care plans so that the managed care plans are better able to assist CCS-eligible children and youth and prioritize assessment and care planning. 10)Requires DHCS to develop a memorandum of understanding (MOU) template, to be utilized by participating counties and health plans, and which includes, but is not limited to, the standards relating to the local administration of, and minimum services to be provided by, counties and MCMC plans in the administration of the WCM program. Requires DHCS to consult with counties and MCMC plans in the development of the WCM MOU template. 11)Requires DHCS to provide written notice to the appropriate county agency of the calculation for determining the administrative allocation to the county CCS program by means of county information notice and requires DHCS to consult with the WCM program counties in determining the calculation for determining the administrative allocation. 12)Requires each MCMC participating in the WCM program to establish an assessment process of CCS beneficiary risk level and care needs, as specified. Plan of Care and Care Coordination Requirements 13)Requires MCMC plans participating in the WCM program to meet all of the following requirements: a) Ensure that each CCS-eligible child or youth receives case management, care coordination, provider referral, and SB 586 Page 6 service authorization services from an employee of the plan who has knowledge of and clinical experience with the CCS program. b) Work with the state or county CCS program, as appropriate, to ensure that, at a minimum, and in addition to other statutory and contractual requirements, care coordination and care management activities do all of the following: i) Reflect an outcome-based approach to care planning; ii) Ensure families have access to ongoing information, education, and support so that they understand the care plan for their child or youth and their role in the individual care process, the benefits of mental health services, what self-determination means, and what services might be available; iii) Adhere to the CCS beneficiary's or their family's determination about the appropriate involvement of medical providers and caregivers; iv) Are developed across CCS specialty services, Medi-Cal primary care services, mental health and behavioral health benefits, regional center services, medical therapy units (MTUs), and in-home supportive services (IHSS), including transitions among levels of care and between service locations; v) Include individual care plans for beneficiaries based on the results of the risk assessment process with a particular focus on CCS specialty care; SB 586 Page 7 vi) Consider behavioral health needs of beneficiaries and coordinate those services with the county mental health department as part of the CCS beneficiary's individual care plan, when appropriate, and facilitate access to appropriate community resources and other agencies, including referrals, as necessary and appropriate, for behavioral services, such as mental health services; and, vii) Ensure access to transportation and other support services necessary to receive treatment. c) Incorporate all of the following into the CCS beneficiary's plan of care patterns and processes: i) Access for families so that they know where to go for ongoing information, education, and support to understand the goals, treatment plan, and course of care for their child or youth and their role in the process, what it means to have primary or specialty care for their child or youth, when it is time to call a specialist, primary care provider, urgent care, or emergency room, what an interdisciplinary team is, and what the community resources are; ii) A primary or specialty care physician who is the primary clinician and who provides core clinical management functions; iii) Care management and care coordination across the health care system, including transitions among levels of care and interdisciplinary care teams; SB 586 Page 8 iv) Provision of referrals to qualified professionals, community resources, or other agencies for services or items outside the scope of responsibility of the managed care health plan; v) Use of clinical data to identify beneficiaries with chronic illness or other significant health issues; and, vi) Timely preventive, acute, and chronic illness treatment of CCS-eligible children or youth in the appropriate setting. 14)Establishes on-going requirements for MCMC plans that ensure appropriate coordination with regional care centers and MTUs, access to necessary information for families, timely access to care, communication in culturally appropriate formats, access to information about grievance and appeals procedures, compliance with Medi-Cal due process requirements coordination as appropriate and other information as specified. CCS Provider Continuity of Care 15)Requires each MCMC plan to establish and maintain a process by which a CCS-eligible child or youth may maintain access to CCS providers that the child or youth has an existing relationship with for treatment of the child's or youth's CCS condition for three years, under the following conditions: a) The CCS-eligible child or youth has seen the out-of-network CCS provider for a nonemergency visit at least once during the 12 months immediately preceding the SB 586 Page 9 date the MCMC plan assumed responsibility for the child's or youth's CCS care under the WCM program; b) The provider must accept the health plan's rate for the service offered or the applicable Medi-Cal or CCS FFS rate, whichever is higher, unless the CCS provider enters into an agreement on an alternative payment methodology mutually agreed to by the CCS provider and the MCMC plan; c) The managed care plan confirms that the provider meets applicable CCS standards and has no disqualifying quality of care issues; and, d) The CCS provider provides treatment information to the MCMC plan, to the extent authorized by the state and federal patient privacy provisions. DME Continuity of Care 16)Requires each MCMC to establish and maintain a process by which a CCS-eligible beneficiary can maintain access to specialized or customized durable medical equipment (DME) providers for up to 12 months under the following conditions: a) The CCS-eligible beneficiary has an ongoing relationship with a DME provider who has previously provided specialized or customized equipment, such as power wheelchairs, repairs, and replacement parts; prosthetic limbs; customized orthotic devices; and individualized assistive technology. This does not include generally available or noncustomized DME; SB 586 Page 10 b) Requires the DME provider to accept the health plan's rate for the service offered or the applicable Medi-Cal or CCS FFS rate, whichever is higher, unless the DME provider enters into an agreement on an alternative payment methodology mutually agreed upon by the DME provider and the MCMC plan; and, c) The DME provider provides information to the MCMC plan as requested by the plan, to the extent authorized by state and federal patient privacy provisions. 17)Defines "specialized or customized durable medical equipment" as DME that meets all of the following criteria: a) Is uniquely constructed from raw materials or substantially modified from the base material solely for the full-time use of the specific beneficiary according to a physician's description and orders; b) Is made to order or adapted to meet the specific needs of the beneficiary; and, c) Is uniquely constructed, adapted, or modified to permanently preclude the use of the equipment by another individual, and is so different from another item used for the same purpose that the two items cannot be grouped together for pricing purposes. 18)Permits DHCS to extend the continuity of care duration for highly specialized or customized DME that is under warranty. Prescription Drug Continuity of Care SB 586 Page 11 19)Requires each MCMC plan to permit a CCS-eligible child or youth enrolled as part of the WCM program to continue use of any prescription drug that is part of a prescribed therapy for the enrollee's CCS-eligible condition or conditions immediately prior to the date of enrollment, whether or not the prescription drug is covered by the plan, until the prescription drug is no longer prescribed by the enrollee's plan-contracting CCS provider. Case Manager Continuity of Care 20)Requires each MCMC plan participating in the WCM program to ensure that children and youth are provided expert case management, care coordination, service authorization, and provider referral. Requires each MCMC plan to meet this requirement by, at the request of the child, youth, or his or her parent or guardian, allowing the child or youth to continue to receive case management, care coordination, provider referrals and service authorizations from his or her public health nurse. Requires this election to be made within 90 days of the transition of CCS services into the MCMC plan. Requires a MCMC to meet this requirement by either or both of the following: a) By entering into a MOU with the county for case management, care coordination, provider referral, and service authorization services to the child; or, b) By collocating county public health nurses who provide case management and coordination within the MCMC plan. 21)Permits the MCMC plan, in the event the county public health SB 586 Page 12 nurse leaves the CCS program, to transition the care coordination and case management of a child or youth to an employee of the plan who has education, knowledge, and experience with the CCS program and pediatric patients or who has knowledge and experience treating CCS-eligible conditions in pediatric patients. MCMC Plan Care Guidelines Regarding Credentialed Providers 22)Requires a MCMC plan to meet all of the following requirements: a) Use all current and applicable CCS program guidelines, including CCS program regulations, CCS numbered letters, and CCS program information notices in developing criteria for use by the plan's chief medical officer or the equivalent and other care management staff; b) In cases in which CCS program guidelines do not exist, use evidence-based guidelines or treatment protocols that are medically appropriate given the child's CCS-eligible condition; c) Utilize only CCS providers to treat CCS conditions; and, d) Utilize a provider dispute resolution process that includes the following requirements: i) Includes health plan contracts with providers that contain provisions requiring a fast, fair, and cost-effective dispute resolution mechanism under which providers may submit disputes to the plan, and require SB 586 Page 13 the plan to inform its providers upon contracting with the plan, or upon change to these provisions, of the procedures for processing and resolving disputes, including the location and telephone number where information regarding disputes may be submitted; ii) Is accessible to non-contracting providers for the purpose of resolving billing and claims disputes; and, iii) A health care service plan to annually submit a report to DHCS regarding its dispute resolution mechanism that includes information on the number of providers who utilized the dispute resolution mechanism and a summary of the disposition of those disputes. Rates Paid to MCMC Plans and Rates Paid to Providers 23)Requires DHCS to pay any managed care plan participating in the WCM program a separate, actuarially sound rate specifically for CCS children and youth, as long as an actuarially sound rate can be developed for the managed care plan's CCS population. Permits DHCS, when contracting with managed care plans, to allow the use of risk corridors or other methods to appropriately mitigate a plan's risk for this population. 24)Requires MCMC plans to pay physician and surgeon provider services at rates that are equal to or exceed the applicable CCS FFS rates, unless the physician and surgeon enters into an agreement on an alternative payment methodology mutually agreed to by the physician and surgeon and the MCMC plan. State and MCMC Plan Advisory Committees SB 586 Page 14 25)Requires a MCMC plan participating in the WCM program to create and maintain a clinical advisory committee composed of the managed care contractor's chief medical officer or the equivalent, the county CCS medical director, and at least four CCS-paneled providers to advise on clinical issues relating to CCS conditions, including treatment authorization guidelines, and serve as clinical advisers on other clinical issues relating to CCS conditions. 26)Requires each MCMC plan participating in the WCM program to establish a family advisory group for CCS families and requires family representatives who serve on this advisory group to receive a reasonable per diem payment to enable in-person participation in the advisory group. 27)Requires DHCS to establish a statewide WCM program stakeholder advisory group (SAG), or modify an existing Whole Child Model program stakeholder advisory group, comprised of representatives of CCS providers, county CCS program administrators, health plans, family resource centers, regional centers, labor organizations, CCS case managers, CCS MTUs, and representatives from family advisory groups. 28)Sunsets the statewide WCM program SAG on December 31, 2021. Evaluation 29)Requires DHCS to contract with an independent entity that has experience in performing robust program evaluations to conduct an evaluation to assess MCMC plan performance and the outcomes and the experience of CCS-eligible children and youth participating in the WCM program, including access to primary SB 586 Page 15 and specialty care, and youth transitions from WCM program to adult Medi-Cal coverage. 30)Requires DHCS to provide a report on the results of this evaluation to the Legislature by no later than January 1, 2021. 31)Requires the evaluation to evaluate the performance of the plans participating in the WCM program as compared to the performance of the CCS program prior to the implementation of the WCM in those same counties and whether the inclusion of CCS services in a managed care delivery system improves access to care, quality of care, and the patient experience, as specified. 32)Requires the evaluation to also evaluate the performance of managed care plans participating in the WCM program as compared to the performance of the CCS program in counties where CCS services are not incorporated into managed care, and collect appropriate data to evaluate whether inclusion of CCS services in a managed care delivery system improves access to care, quality of care, and the patient experience, by analyzing all of the following: a) The rate of new CCS enrollment in each county; b) The percentage of CCS-eligible children and youth with a diagnosis requiring a referral to a CCS special care center who have been at a CCS special care center; and, c) The percentage of CCS children and youth discharged from a hospital who had at least one followup contact or visit within 20 days after discharge. SB 586 Page 16 Regulations and Use of Contract Authority 33)Requires DHCS, without taking regulatory action, to implement, or interpret any applicable federal waivers and state plan amendments by means of all-county letters, plan letters, CCS numbered letters, plan or provider bulletins, or similar instructions until the time regulations are adopted. 34)Requires DHCS, by July 1, 2019, to adopt regulations. Requires DHCS, commencing July 1, 2017, to provide a status report to the Legislature on a semiannual basis, until regulations have been adopted and permits the Director to enter into exclusive or nonexclusive contracts on a bid, nonbid, or negotiated basis and to amend existing managed care plan contracts to provide or arrange for services, as specified. EXISTING LAW: 1)Prohibits CCS covered services from being incorporated into any MCMC contract entered into after August 1, 1994 until January 1, 2017, with the exception of contracts entered into by a COHS or RHA in the Counties of San Mateo, Santa Barbara, Solano, Yolo, Marin, and Napa. 2)Specifies that CCS covered services means any or all of the following, regardless of the funding sources: a) Expert diagnosis; SB 586 Page 17 b) Medical treatment; c) Surgical treatment; d) Hospital care; e) Physical therapy; f) Occupational therapy; g) Special treatment; h) Materials; i) Appliances and their upkeep, maintenance, care and transportation; and, j) Maintenance, transportation, or care incidental to any other form of "services." 3)Requires managed care contractors serving CCS-eligible children to maintain and follow standards of care established by the program, including the use of paneled providers and CCS-approved special care centers and to follow treatment plans approved by the program, including specified services and providers of services. . FISCAL EFFECT: According to the Assembly Appropriations Committee: SB 586 Page 18 1)This bill largely aligns with existing administrative plans to implement a WCM program. However, there are several required activities that will result in costs (General Fund/federal): a) Monitoring and oversight standards: $500,000 per year. b) Stakeholder advisory group: $50,000 per year. c) Independent evaluation: $300,000-$500,000 one-time. 2)The requirements for managed care plans to pay providers at existing rates results in unknown fiscal impact. To the extent access to care could be maintained with lower payment rates, this may lead to potential unrealized savings. 3)Extending the carve-out result in non-COHS counties results in an unknown, potentially significant fiscal impact to the extent it reduces flexibility to provide care in a more cost-efficient manner. However, there are no plans to "carve in" CCS services for non-COHS counties. COMMENTS: According to the author, this bill authorizes the creation of a WCM in counties served by a Medi-Cal COHS. CCS has been carved out of MCMC since 1994 because the Legislature recognized this population required a unique approach. In over two decades since that time, the CCS carve-out has been extended numerous times, and the state has engaged in periodic efforts to pilot CCS alternative arrangements. The current carve out ends December 31, 2016, and the Administration has signaled that they will support an extension of the carve-out only if it is accompanied by a plan for an organized delivery system that combines CCS-services in a WCM. This bill responds to that call by establishing a WCM in COHS MCMC plans. This bill extends the carve-out in non-COHS counties, ensures there is an incentive to continue to identify CCS-eligible children and adequately funds their care by requiring a stand-alone capitation payment paid to MCMC plans, ensures access to physician specialists by requiring SB 586 Page 19 a payment floor for CCS physician services, provides extended continuity of care so that children can continue to see their current providers, ensures continuity and consistency of CCS program expertise in care coordination and service authorization, requires an evaluation of the WCM, and ensures family involvement in the WCM at both the state and local level. Originally established in 1927, the CCS program provides diagnostic and treatment services, medical case management, and physical and occupational therapy services to children under age 21 with CCS-eligible medical conditions. Some examples of CCS-eligible conditions include chronic medical conditions such as cystic fibrosis, hemophilia, cerebral palsy, heart disease, cancer, traumatic injuries, and certain infectious diseases. CCS also provides medical therapy services that are delivered at public schools. As of January 2012, there were 190,507 children enrolled in CCS. According to DHCS, 90% of CCS enrollees are also eligible for Medi-Cal and 10% were CCS-only or were covered by other insurance. The Medi-Cal program reimburses providers for Medi-Cal eligible beneficiaries. In 1994, legislation was enacted to provide that CCS-covered services for CCS-eligible children would not be incorporated into managed care, termed a "carve out" and would be provided and paid for on a FFS basis through the CCS program. The carve-out was approved for three years and authorized pilot projects to test alternative managed care models tailored to the special health care needs of CCS program, including using different payment and incentive models. No pilot projects were ever approved. The carve out has been extended repeatedly since then, usually for three or four year periods. The first extension allowed the COHS in the counties of San Mateo, Santa Barbara, Solano, and Napa to include CCS services. Later extensions allowed Yolo and Marin counties to include CCS services SB 586 Page 20 1)MCMC. MCMC contracts for health care services through established networks of organized systems of care, which emphasize primary and preventive care. Managed care plans are intended to be a cost-effective use of health care resources that improve health care access and assure quality of care. According to DHCS, approximately 10.3 million Medi-Cal beneficiaries in all 58 California counties receive their health care through six main models of managed care: Two-Plan, COHS, Geographic Managed Care, Regional Model, Imperial, and San Benito. Medi-Cal providers who wish to provide services to managed care enrollees must participate in the managed care plan's provider network. 2)COHS. This bill permits DHCS, beginning July 1, 2017, to establish a WCM program for Medi-Cal eligible CCS children enrolled in a managed care plan under a COHS, one of the six models of managed care, as discussed above. Each COHS is created by a county board of supervisors and governed by an independent commission. In COHS counties, a single plan serves all Medi-Cal beneficiaries who are enrolled in managed care. There are currently six COHS, operating in 22 counties, as follows: SB 586 Page 21 ---------------------------------------------------------- | COHS | Counties | Number of | | | | enrollees | | | | as of May | | | | 2015 | |---------------------+---------------------+--------------| | CalOptima | Orange | 746,767 | |---------------------+---------------------+--------------| | CenCal Health | Santa Barbara | 163,264 | | | San Luis Obispo | | |---------------------+---------------------+--------------| | Central California | Santa Cruz, | 331,148 | | Alliance for Health | Monterey, Merced | | |---------------------+---------------------+--------------| | Gold Coast Health | Ventura | 190,750 | | Plan | | | |---------------------+---------------------+--------------| | Health Plan of San | San Mateo | 106,080 | | Mateo | | | |---------------------+---------------------+--------------| | Partnership Health |Del Norte, Humboldt, | 542,890 | | Plan of California |Lake, Lassen, Marin, | | | | Mendocino, Modoc, | | | | Napa, Shasta, | | | | Siskiyou, Solano, | | SB 586 Page 22 | |Sonoma, Trinity, and | | | | Yolo Counties | | ---------------------------------------------------------- ----------------------------------------------------------- | Total COHS Enrollment |2,080,899 | | | | | | | | | | | | | ----------------------------------------------------------- MCMC plans are generally subject to: a) consumer protections provided by the California Knox-Keene Health Care Service Plan Act of 1975 (Knox-Keene) and overseen by the Department of Managed Health Care (DMHC); b) federal and state rules and regulations for Medi-Cal; and, c) terms set forth and agreed upon in contracts between the plans and DHCS. However, unlike other MCMC plans, COHS plans are not required to obtain Knox Keene licensure for their Medi-Cal lines of business, and unless they choose to obtain a Knox-Keene license, they are not directly regulated by the DMHC. Rather than operating under specific statutory mandates, the county is bound by the rules, terms, and conditions negotiated by the contract. Despite the exemption, one COHS, the Health Plan of San Mateo, voluntarily obtained a Knox-Keene license. Additionally, all other COHS, except for Gold Coast Health Plan, have obtained a Knox-Keene license for other, non-Medi-Cal lines of business. 3)DHCS Proposal. In September of 2014, DHCS implemented a stakeholder process to investigate potential improvements or changes to the CCS program, in partnership with the University of California, Los Angeles Center for Health Policy Research. The CCS Redesign Stakeholder Advisory Board (RSAB) is composed of individuals from various organizations and backgrounds with SB 586 Page 23 expertise in both the CCS program and care for children and youth with special health care needs, and meets on a bi-monthly bases. In August of 2015, DHCS released proposed bill language, based in part on feedback received by the RSAB. This language was the starting point for extensive negotiations between DHCS, stakeholders, and legislative staff on the future of the CCS program. Some of the key issues on which there is still disagreement include whether or not sign-off from affected entities prior to implementation of WCM should be required, the relationship between the plans and the counties regarding case management, care coordination, provider referral and service authorization, the role and responsibilities of county CCS workers regarding care coordination and management services they currently provide, the duration of continuity of care provisions, standards for care, whether there should be a stand-alone rate paid to plans for children enrolled in CCS, and tracking outcomes and health for CCS children for 10 years. The California Children's Hospital Association (CCHA), the California Chronic Care Coalition, Children Now, Hemophilia Council of California and other supporters state that the WCM has the potential to improve the coordination of services for children along the whole continuum of medical care, but as with any major health care transition, it also has the potential to cause disruptions to care delivery. CCHA is particularly concerned that the transition could jeopardize long-standing relationships between CCS-eligible children and the providers who currently treat them, and upset the State's high quality pediatric specialty network. In addition, integrating the CCS program with managed care does not necessarily guarantee that coordination will occur. CCHA states that this bill sets forth a comprehensive framework for implementing the WCM that will help ensure a smoother transition and preserve the positive aspects of the CCS program while creating an integrated delivery system tailored to the needs of children with complex medical conditions and their families. In particular, CCHA believes several components of this bill are particularly critical to ensuring CCS-eligible children and youth continue to receive the highest quality of care through the WCM. SB 586 Page 24 Disability Rights California (DRC) states that the CCS program is critically important to their clients and constituents. It is the means by which disabled individuals receive the health care services that enable them to live and to progress to realize their potential including progressing towards greater independence and quality of life. Access to CCS program paneled physicians and the hospitals in which they work as well as registered nurse case management is critical. Because a number of DRC clients and constituents have low incidence disabilities, access to CCS program paneled providers who are out of county is important in order to ensure access to CCS program providers with experience and expertise to address their particular medical condition. Of particular importance for DRC clients and constituents with the most severe and complex disabilities have access to special care centers. DRC also stresses the importance of due process procedures and access to the Medicaid EPSDT medical necessity standard. Analysis Prepared by: Paula Villescaz / HEALTH / (916) 319-2097 FN: 0004071