BILL ANALYSIS                                                                                                                                                                                                    �



                                                                      



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          |SENATE RULES COMMITTEE            |                  AB 1297|
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                                 THIRD READING


          Bill No:  AB 1297
          Author:   Chesbro (D)
          Amended:  8/31/11 in Senate
          Vote:     21

           
           SENATE HEALTH COMMITTEE  :  9-0, 7/6/11
          AYES:  Hernandez, Strickland, Alquist, Anderson, Blakeslee, 
            De Le�n, DeSaulnier, Rubio, Wolk
           
          SENATE APPROPRIATIONS COMMITTEE  :  9-0, 8/25/11
          AYES:  Kehoe, Walters, Alquist, Emmerson, Lieu, Pavley, 
            Price, Runner, Steinberg
           
          ASSEMBLY FLOOR  :  70-0, 5/12/11 - See last page for vote


           SUBJECT  :    Medi-Cal:  mental health

           SOURCE  :     County Mental Health Directors Association


           DIGEST  :    This bill requires provider reimbursement for 
          specialty mental health services to be consistent with 
          federal Medicaid requirements for calculating federal upper 
          payment limits, removes statewide maximum allowances, 
          extend the period for claims submission, and requires the 
          reimbursement methodology to be based on certified public 
          expenditures and to conform to federal Medicaid 
          requirements.

           ANALYSIS  :    Existing law:

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          1. Provides for the Medi-Cal program, administered by the 
             Department of Health Care Services (DHCS), under which 
             qualified low-income persons are provided with health 
             care services, including mental health services.  The 
             Medi-Cal program is partially governed and funded under 
             federal Medicaid provisions.  Under existing law, the 
             Department of Mental Health (DMH) is required to provide 
             specialty mental health services for Medi-Cal recipients 
             through fee-for-service or capitated contracts with 
             mental health plans (MHPs).  The DMH establishes 
             standards, guidelines, and reimbursement amounts for 
             specialty mental health services based on the federal 
             Medicaid requirements. 

          2. Requires counties to certify that required matching 
             funds are available prior to the reimbursement of 
             federal funds.

          3. Establishes procedures, including reimbursement and 
             claiming procedures, reviews and oversight, and appeal 
             processes for MHPs and MHP subcontractors.

          4. Requires the DHCS and the DMH to jointly develop a new 
             rate setting methodology for reimbursements for direct 
             client services that meets specified requirements, 
             including that administrative costs be claimed 
             separately and limited to 15 percent of the total cost 
             of direct client services.

          This bill:

          1. Requires provider reimbursement for specialty mental 
             health services to be consistent with federal Medicaid 
             requirements for calculating federal upper payment 
             limits (UPL). 

          2. Requires claims for reimbursement to be submitted within 
             the longer timeframe permitted by federal law rather 
             than the shorter timeframes set forth in state 
             regulation. 

          3. Requires the reimbursement methodology to be based on 
             certified public expenditures (CPEs) and to conform to 
             federal Medicaid requirements. 

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          4. Requires standards and guidelines for the administration 
             of mental health services to Medi-Cal eligible 
             individuals to be consistent with federal Medicaid 
             requirements, as specified in the approved Medicaid 
             state plan and waivers to ensure full and timely federal 
             reimbursement to counties. 

          5. Requires DMH and DHCS to consult with the California 
             Mental Health Directors Association (CMHDA) when 
             developing a reimbursement methodology and that 
             reimbursement amounts and administrative costs be 
             claimed in a manner consistent with federal Medicaid 
             requirements and the approved Medicaid state plan and 
             waivers.

          6. Clarifies that any county claiming reimbursement up to 
             the federal UPL could not use state funds to pay the 
             non-federal share of the CPE, and delays implementation 
             until July 1, 2012.

           Background
           
          Specialty mental health services are "carved out" in the 
          Medi-Cal Program and provided by MHPs.  Specialty mental 
          health services are services that are provided by mental 
          health specialists, such as psychiatrists, psychologists, 
          licensed clinical social workers, licensed marriage and 
          family therapists, or psychiatric technicians, rather than 
          by a primary care physician or other physical health care 
          provider.  Individuals are entitled to specialty mental 
          health services if the service is both covered under the 
          Medi-Cal program and deemed medically necessary.  Services 
          include mental health assessments, group or individual 
          therapy, medication support services, intensive day 
          treatment, crisis intervention and stabilization, and 
          residential treatment services.

          Each county MHP is responsible for maintaining a provider 
          network, authorizing services, determining provider payment 
          rates, and paying most providers.  Providers bill on a 
          fee-for-service basis and are paid directly by each MHP.  
          MHPs submit claims to DMH for processing.  A MHP submits a 
          form to DMH certifying that it incurred the expenditures 

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          associated with submitted claims.  DMH compares the claimed 
          amount to a schedule called the State Maximum Allowance 
          (SMA) that describes the maximum amount a county may be 
          reimbursed for each specialty mental health service 
          function described above, and approves the lower of what is 
          billed or the SMA.

          DMH then submits the batch of edited claims to DHCS for 
          further processing.  DHCS processes the claims to determine 
          whether the services provided meet federal and state 
          requirements.  DHCS determines whether the claims are 
          approved, denied, or suspended. Once determination is made, 
          DHCS electronically returns the entire batch of claims to 
          DMH with a determination of how much federal reimbursement 
          is due to the MHPs.  DHCS then submits an invoice to the 
          State Controller for federal funds.  Once federal 
          reimbursement funds are received by DHCS, it passes them 
          through DMH back to the MHPs.

           Statewide Maximum Allowance (SMA)  .  SMAs are published 
          annually by DMH to provide the maximum amount a county may 
          be reimbursed for each specialty mental health service 
          function.  Counties are alerted to the SMAs through 
          information notices sent by DMH.  For example, DMH's most 
          recent information notice reflects that counties' current 
          federal reimbursement for 24-hour hospital inpatient 
          services is set at a maximum of $1,172.71 per day.  
          According to CMHDA, this amount may not reflect the actual 
          costs to counties to provide this service, and it does not 
          take into consideration that Centers for Medicare and 
          Medicaid Services (CMS), does not set a maximum dollar 
          amount for this service or any other type of Medi-Cal 
          service mode.  
           
          CMHDA notes that the SMAs for all services (except 
          inpatient, psychiatric health facility, and adult crisis 
          residential) have been frozen since fiscal year 2006-07 in 
          order to limit state General Fund (GF) payments for the 
          Early and Periodic Screening, Diagnosis, and Treatment 
          Program, which provides physical and mental health services 
          to Medi-Cal beneficiaries under the age of 21.  

          This bill seeks to eliminate the use of SMAs in determining 
          the federal reimbursement due to counties.  Instead, this 

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          bill requires reimbursement amounts to be consistent with 
          federal Medicaid requirements for calculating federal UPLs. 
           Federal UPLs are the maximum amount a provider can be paid 
          under Medicare payment principles.  In addition, this bill 
          requires the reimbursement methodology for MHPs to be based 
          on CPEs and to conform to Medicaid requirements.  CPEs 
          enable government providers to certify and receive federal 
          reimbursement for costs that they incur that above the 
          amounts the provider receives from Medicaid reimbursement.

           Claims submission timelines  .  DMH regulations specify that 
          counties must submit claims for specialty mental health 
          services within six months, except when there is good 
          cause.  However, federal regulations require Medi-Cal 
          claims to be submitted no later than 12 months from the 
          date of service.  This bill eliminates DMH's use of the 
          state's administratively-established submission deadline of 
          six months for these claims and, instead, requires counties 
          to submit claims within the 12-month timeframe specified in 
          federal Medicaid requirements.

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes   
          Local:  No

          According to the Senate Appropriations Committee:

                         Fiscal Impact (in thousands)

           Major Provisions      2011-12     2012-13     2013-14   Fund  

          Removal of SMA limits                   potentially 
          significant                                  Federal*

          Start-up administrative       $75       $150      
          $100General/**
          expenditures                                      Federal
          *Increased federal financial participation
          **50 percent General Fund, 50 percent federal funds

           SUPPORT  :   (Verified  8/30/11)

          County Mental Health Directors Association (source)
          Advanced Medical Technology Association
          California Alliance of Child and Family Services

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          California Council of Community Mental Health Agencies
          California Psychiatric Association
          California State Association of Counties
          County Alcohol and Drug Program Administrators Association 
          of California
          Los Angeles County Board of Supervisors
          National Association of Social Workers, California
          Regional Council of Rural Counties
          Sacramento County Board of Supervisors
          San Mateo County Board of Supervisors

           ARGUMENTS IN SUPPORT  :    The California State Association 
          of Counties (CSAC) writes that this bill will ensure timely 
          federal reimbursement to counties for their provision of 
          specialty mental health services by aligning state 
          requirements with existing federal requirements to help 
          maximize federal funds for these services, all without 
          impacting the state's GF.  CSAC adds that expanding the 
          timeframe for counties to submit specialty mental health 
          claims from the state's six month limit to the federal 
          standard of 12 months will give counties the flexibility in 
          submitting claims that complex health care scenarios 
          demand.     


           ASSEMBLY FLOOR  :  70-0, 5/12/11
          AYES:  Achadjian, Allen, Ammiano, Atkins, Beall, Bill 
            Berryhill, Block, Blumenfield, Bonilla, Bradford, 
            Brownley, Buchanan, Butler, Charles Calderon, Campos, 
            Carter, Chesbro, Cook, Davis, Dickinson, Donnelly, Eng, 
            Feuer, Fletcher, Fong, Fuentes, Furutani, Beth Gaines, 
            Galgiani, Gatto, Gordon, Grove, Hagman, Halderman, Hall, 
            Harkey, Hayashi, Hill, Huber, Hueso, Huffman, Jeffries, 
            Jones, Knight, Lara, Logue, Ma, Mansoor, Mendoza, Miller, 
            Monning, Morrell, Nestande, Nielsen, Norby, Olsen, Pan, 
            Perea, V. Manuel P�rez, Silva, Skinner, Smyth, Solorio, 
            Swanson, Valadao, Wagner, Wieckowski, Williams, Yamada, 
            John A. P�rez
          NO VOTE RECORDED:  Alejo, Cedillo, Conway, Garrick, Gorell, 
            Roger Hern�ndez, Bonnie Lowenthal, Mitchell, Portantino, 
            Torres


          CTW:kc  8/30/11   Senate Floor Analyses 

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                         SUPPORT/OPPOSITION:  SEE ABOVE

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