BILL ANALYSIS                                                                                                                                                                                                    �



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          CONCURRENCE IN SENATE AMENDMENTS
          AB 1967 (Pan)
          As Amended July 1, 2014
          Majority vote
           
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          |ASSEMBLY:  |73-0 |(May 8, 2014)   |SENATE: |35-0 |(August 20,    |
          |           |     |                |        |     |2014)          |
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           Original Committee Reference:   HEALTH  

           SUMMARY  :  Requires the Department of Health Care Services  
          (DHCS), if it commences or concludes an investigation of a Drug  
          Medi-Cal provider, to notify counties that contract with the  
          provider.

           The Senate amendments  clarify that notification of an  
          investigation must occur when a preliminary criminal  
          investigation has commenced, define certain terms, and specify  
          what provider information can be included in the notifications.

           EXISTING LAW  :  

          1)Establishes the Medi-Cal program, administered by DHCS, under  
            which qualified low-income persons receive health care  
            benefits.  Medi-Cal is California's version of the federal  
            Medicaid program and is jointly funded by the state and  
            federal government.

          2)Establishes the Drug Medi-Cal program, which provides  
            substance use disorder services to Medi-Cal recipients.

          3)Allows DHCS to enter into contracts with counties for the  
            provision of Drug Medi-Cal services.  If a county declines to  
            contract with DHCS, existing law requires DHCS to contract for  
            services in the county to ensure beneficiary access.

          4)Requires each county to fund the nonfederal share for Drug  
            Medi-Cal services through realignment funds, as specified.

          5)Requires providers of Drug Medi-Cal services to obtain  
            certification from DHCS to provide those services.

          6)Requires DHCS to adopt emergency regulations governing the  








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            Drug Medi-Cal program by July 1, 2014.  

           AS PASSED BY THE ASSEMBLY  , this bill required DHCS, if it  
          commences or concludes an investigation of a Drug Medi-Cal  
          provider, to notify counties that contract with the provider.

           FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee, pursuant to Senate Rule 28.8, negligible state costs.

           COMMENTS  :  According to the author, 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.  The author writes, in  
          September 2013, the Assembly Health Committee and Assembly  
          Accountability and Administrative Review Committee held a joint  
          oversight hearing to examine fraud in the Drug Medi-Cal program.  
           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.  

          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: they are delivered by a specialized  
          system of providers certified by the state rather than through  
          participating physicians or health plans.  Drug Medi-Cal  
          services include outpatient drug free services, which consist  
          mostly of group counseling and some limited individual  
          counseling for persons in crisis; narcotic treatment programs,  
          which provide methadone replacement therapy; intensive  
          outpatient services; and residential services.  There are about  
          800 active Drug Medi-Cal providers in the state.

          Current regulations create requirements for oversight of Drug  
          Medi-Cal providers at both the state and county levels.  DHCS is  
          tasked with administrative and fiscal oversight, monitoring,  
          auditing, utilization review, and recovery of improper payments.  
           Counties that elect to contract with DHCS to provide Drug  
          Medi-Cal services are required to maintain a system of fiscal  
          disbursement and controls, monitor to ensure that billing is  
          within established rates, and process claims for reimbursement.   








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          Most counties choose to contract with DHCS; however, 13 counties  
          (Alpine, Amador, Calaveras, Colusa, Del Norte, Inyo, Modoc,  
          Mono, Plumas, Sierra, Siskiyou, Trinity, and Tuolumne) do not  
          participate in Drug Medi-Cal.  In addition, 15 providers  
          statewide currently operate without a county contract, instead  
          contracting directly with DHCS.

          Beginning in July 2013, the Center for Investigative Reporting  
          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.  The reports alleged that a number of clinics in  
          Southern California engaged in practices that included:

          1)Busing of teenagers without drug problems from group homes; 

          2)Fabricating patient treatment documents;

          3)Paying clients for showing up to counseling sessions; 

          4)Billing for patients who were incarcerated or dead; 

          5)Billing for group counseling for dozens of clients on a day  
            when clinic staff told reporters that no group counseling was  
            offered; and,

          6)Billing for counseling sessions that did not occur.

          The reports suggested that the state's oversight and enforcement  
          bodies were not working well in tandem: county audits of  
          providers identified a number of serious deficiencies, but  
          failed to terminate contracts or prevent the problems from  
          continuing.  

          In July 2013, DHCS began reviewing Drug Medi-Cal providers and  
          ordering temporary suspensions due to credible allegations of  
          fraud.  As of January of 2014, DHCS had suspended 68 providers  
          operating 177 facilities and referred the providers to the  
          Department of Justice for criminal prosecution.  After an  
          extensive internal review, DHCS announced a number of steps it  
          was taking to improve integrity in Drug Medi-Cal: 

          1)Requiring all 816 active Drug Medi-Cal providers to submit  








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            applications for recertification and decertifying providers  
            that have not billed Drug Medi-Cal in the last 12 months; 

          2)Requiring counties, through the state-county contract, to  
            increase monitoring of Drug Medi-Cal providers;

          3)Continuing targeted investigations of Drug Medi-Cal providers  
            by DHCS auditors, nurse evaluators and peace officers;

          4)Mining and analyzing of data to identify suspicious Drug  
            Medi-Cal providers for additional review, including onsite  
            visits, fingerprinting, and background checks; and,

          5)Developing emergency regulations to clarify the requirements  
            and responsibilities of providers, medical directors, and  
            other provider personnel.

          In September 2013, the Assembly Health Committee and Assembly  
          Accountability and Administrative Review Committee held a joint  
          oversight hearing on fraud in the Drug Medi-Cal program.  Among  
          the issues raised at the hearing was an indication that  
          communication between DHCS and counties could be improved.  In  
          particular, counties indicated that they were generally not  
          informed when providers were being investigated by DHCS.   
          Because counties are responsible for routine monitoring of  
          providers, this lack of communication served as an impediment to  
          the effective oversight of potentially fraudulent providers.  

          The County Alcohol and Drug Program Administrators Association  
          of California (CADPAAC), in support, writes 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, 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 will help the state and counties maintain  
          good providers in the DMC program and preserve the integrity of  
          these needed services.  


           Analysis Prepared by  :    Paula Villescaz / HEALTH / (916)  
          319-2097 










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          FN:  
          0004457