BILL ANALYSIS                                                                                                                                                                                                    �



                                                                            



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                                    THIRD READING


          Bill No:  AB 1967
          Author:   Pan (D)
          Amended:  7/1/14 in Senate
          Vote:     21

           
           SENATE HEALTH COMMITTEE  :  8-0, 6/25/14
          AYES:  Hernandez, Morrell, Beall, De Le�n, DeSaulnier, Evans,  
            Monning, Nielsen
          NO VOTE RECORDED:  Wolk
           
          SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8
           
          ASSEMBLY FLOOR  :  73-0, 5/8/14 (Consent) - See last page for vote


           SUBJECT  :    Drug Medi-Cal

           SOURCE  :     Author


           DIGEST  :    This bill requires the Department of Health Care  
          Services (DHCS) to promptly notify each county that currently  
          contracts with a Drug Medi-Cal provider that a preliminary  
          investigation has commenced, if DHCS commences a preliminary  
          investigation of a certified Drug Medi-Cal provider.

           ANALYSIS  :    

          Existing law:

           1. Establishes the Medi-Cal program, which is administered by  
             DHCS, under which qualified low-income individuals receive  
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             health care services.  Defines Drug Medi-Cal reimbursable  
             services for purposes of these provisions.

           2. Establishes the Drug Medi-Cal Treatment Program (Drug  
             Medi-Cal) under which DHCS is authorized to enter into  
             contracts with counties for various drug treatment services  
             to Medi-Cal recipients, or is required to directly arrange  
             for these services if a county elects not to do so. 

           3. Requires a county to negotiate contracts only with providers  
             certified to provide Drug Medi-Cal services. 

          This bill:

           1. Requires DHCS, if it commences a preliminary criminal  
             investigation of a certified Drug Medi-Cal provider, to  
             promptly notify each county that currently contracts with the  
             provider for Drug Medi-Cal services that a preliminary  
             criminal investigation has commenced. 

           2. Requires DHCS to promptly notify each county that currently  
             contracts with the provider for Drug Medi-Cal services that a  
             preliminary criminal investigation has concluded, if DHCS  
             concludes a preliminary criminal investigation of a certified  
             provider.

           3. Requires notice of the commencement and conclusion of a  
             preliminary criminal investigation to be made to the county  
             behavioral health director or his/her equivalent.

           4. Defines "commenced" to mean the time at which a complaint or  
             allegation is assigned to an investigator for a field  
             investigation.

           5. Defines "preliminary criminal investigation" to mean an  
             investigation to gather information to determine if criminal  
             law or statutes have been violated.

           6. Requires communication between DHCS and a county specific to  
             the commencement or conclusion of a preliminary criminal to  
             be deemed confidential and not be subject to any disclosure  
             request, including, but not limited to, the Information  
             Practices Act of 1997, the California Public Records Act,  
             requests pursuant to a subpoena, or for any other public  

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             purpose, including, but not limited to, court testimony.

           7. Requires information shared by DHCS with a county regarding  
             a preliminary criminal investigation to be maintained in a  
             manner to ensure protection of the confidentiality of the  
             criminal investigation.

           8. Specifies the information provided to a county to only  
             include the provider name, national provider identifier  
             number, address, and the notice that an investigation has  
             commenced or concluded.

           9. Prohibits a county from taking any adverse action against a  
             provider based solely upon the preliminary criminal  
             investigation information disclosed to the county. 

           10.Specifies that in the event of a preliminary criminal  
             investigation of a county-owned or operated program, DHCS has  
             the option to, but is not required to, notify the county when  
             DHCS commences or concludes a preliminary criminal  
             investigation.

           11.Clarifies these provisions do not limit the voluntary or  
             otherwise legally mandated or contractually mandated sharing  
             of information between DHCS and a county of information  
             regarding audits and investigations of Drug 
           Medi-Cal providers.

           12.Makes legislative findings and declarations related to  
             protecting the rights of Drug Medi-Cal providers during a  
             preliminary criminal investigation.

          Comments
           
          According to the author's office, in July 2013, an investigation  
          by the Center for Investigative Reporting (CIR) and CNN  
          uncovered allegations of widespread fraud in Drug Medi-Cal.  The  
          investigative report alleged that, over the past two fiscal  
          years, the Drug Medi-Cal paid $94 million to 56 drug and alcohol  
          rehabilitation clinics in Southern California that have shown  
          signs of deceptive or questionable billing.  In September 2013,  
          the Assembly Health Committee and Accountability and  
          Administrative Review Committee held a joint oversight hearing  
          to examine current oversight of the Drug Medi-Cal program by  

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          DHCS.  One issue highlighted at the hearing was the lack of  
          information sharing between the state and county entities that  
          are responsible for monitoring and auditing clinics.  In  
          particular, counties expressed a concern that individuals who  
          were being investigated in one county could simply move  
          operations to a new county in order to avoid further  
          investigation.  This bill is intended to improve oversight and  
          prevent fraud in the Drug Medi-Cal program by requiring the  
          state to share information with counties related to providers  
          under investigation.

           Drug Medi-Cal  .  Per the state's Medicaid State Plan, substance  
          use disorder services are to stabilize and rehabilitate Medi-Cal  
          beneficiaries diagnosed as having a substance-related disorder.   
          Drug Medi-Cal services are reimbursed on a fee-for-service basis  
          at rates set by the state, and are not provided through 
          Medi-Cal managed care plans.  These services are carved out from  
          the regular Medi-Cal program and are delivered by providers  
          certified by the state rather than through participating health  
          plans.  Funding for pre-2014 Drug Medi-Cal services was  
          realigned to the counties as part of 2011 Public Safety  
          Realignment, with counties putting up the state match to draw  
          down federal Medicaid matching funds.  Counties can choose to  
          contract with DHCS and administer the program directly.  13  
          smaller counties (Alpine, Amador, Calaveras, Colusa, Del Norte,  
          Inyo, Modoc, Mono, Plumas, Sierra, Siskiyou, Trinity, and  
          Tuolumne) do not participate in Drug Medi-Cal.

           Fraud in Drug Medi-Cal  .  Beginning in July 2013, CIR published a  
          series of reports on fraud in the Drug Medi-Cal program in  
          conjunction with a three-part series on CNN entitled "Rehab  
          Racket."  The reports alleged that Drug Medi-Cal paid $94  
          million over the prior two fiscal years to 56 Southern  
          California providers with histories of questionable billing  
          practices and inadequate program oversight.  These include:

           1. The state failing to inform counties of providers who had  
             been convicted of Medi-Cal fraud;

           2. Drug Medi-Cal providers billing for patients who did not go  
             to therapy, including teens from foster care homes who did  
             not have addictions;

           3. Drug Medi-Cal providers fabricating counseling notes;

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           4. Drug Medi-Cal providers paying kickbacks for patients from  
             board and care homes, and paying patients to attend therapy  
             sessions;

           5. The state failing to require criminal background checks for  
             clinic leaders; and

           6. Drug Medi-Cal providers falsifying patient charts and  
             billing for care by counselors who were not working.

           DHCS action in response to Drug Medi-Cal fraud  .  In July 2013,  
          DHCS began reviewing Drug Medi-Cal providers and ordering  
          temporary suspensions due to credible allegations of fraud.  In  
          January 2014, DHCS announced it had suspended payments to 68  
          providers operating 177 drug treatment facilities.  DHCS  
          indicated all 68 of these cases have been referred to the  
          Department of Justice (DOJ) for criminal prosecution based on  
          the credible allegations of fraud.  DHCS also completed an  
          assessment of the Drug Medi-Cal program, which included a  
          program audit conducted by its Audits and Investigations  
          Division, and DHCS' plan for implementing the recommended  
          changes to ensure integrity in the Drug Medi-Cal program.

           Related Legislation
           
          AB 1644 (Medina) requires Drug Medi-Cal providers to be  
          designated as a "high" categorical risk, and be subject to  
          criminal background checks as a condition of Drug Medi-Cal  
          certification.

          SB 1339 (Cannella) requires a certified Drug Medi-Cal provider's  
          owner and medical director to submit to the DOJ fingerprint  
          images and related information required by the DOJ for the  
          purpose of obtaining information as to the existence and content  
          of a record of state and federal convictions and arrests.

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

           SUPPORT  :   (Verified  8/6/14)

          County Alcohol and Drug Program Administrators Association of  
          California

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          Los Angeles County Board of Supervisors

           ARGUMENTS IN SUPPORT  :    The County Alcohol and Drug Program  
          Administrators Association of California (CADPAAC) writes in  
          support that this bill improves oversight and prevents fraud in  
          Drug Medi-Cal by requiring the state to share information with  
          counties related to providers under investigation.  CADPAAC  
          states that, with the expansion of substance use disorder  
          treatment benefits in the state's Medi-Cal program, there will  
          be upwards of 116,000 beneficiaries that are newly-eligible for  
          substance use disorder treatment by 2019.  Given the importance  
          of these services, CADPAAC states it is crucial that the  
          integrity of the program be preserved and that vital services  
          not be jeopardized by bad actors.  CADPAAC writes that this bill  
          helps the state and counties maintain good providers in the Drug  
          Medi-Cal program and preserve the integrity of these needed  
          services.

           ASSEMBLY FLOOR  :  73-0, 5/8/14
          AYES:  Achadjian, Alejo, Allen, Ammiano, Atkins, Bigelow, Bloom,  
            Bocanegra, Bonilla, Bonta, Bradford, Brown, Buchanan, Ian  
            Calderon, Campos, Chau, Ch�vez, Chesbro, Conway, Cooley,  
            Dababneh, Dahle, Daly, Dickinson, Donnelly, Fong, Fox,  
            Frazier, Beth Gaines, Garcia, Gatto, Gomez, Gonzalez, Gordon,  
            Grove, Hagman, Harkey, Roger Hern�ndez, Holden, Jones,  
            Jones-Sawyer, Levine, Linder, Logue, Lowenthal, Maienschein,  
            Medina, Melendez, Mullin, Muratsuchi, Nazarian, Nestande,  
            Olsen, Pan, Patterson, Perea, Quirk, Quirk-Silva, Rendon,  
            Ridley-Thomas, Rodriguez, Salas, Skinner, Stone, Ting, Wagner,  
            Waldron, Weber, Wieckowski, Wilk, Williams, Yamada, John A.  
            P�rez
          NO VOTE RECORDED:  Eggman, Gorell, Gray, Hall, Mansoor, V.  
            Manuel P�rez, Vacancy


          JL:k  8/6/14   Senate Floor Analyses 

                           SUPPORT/OPPOSITION:  SEE ABOVE

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