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| Stakeholder Representative | General Question | Answer |
|---|---|---|
| CW Contractor | Are juvenile offenders placed in residential facilities or group homes considered incarcerated? Second Paragraph: We realize the section is titled “criminal court referrals” but want to assure that “court ordered placement” does not extend to the CINC population. | Residential facilities or group homes are not appropriate placements for a juvenile offender in need of incarceration. This section relates to those individuals involved with the criminal justice system. It is not intended to relate to court ordered placements involved in a CINC proceeding. |
| CW Contractor | In the sense of continuing professional responsibility, what obligations does the PAHP have for providing at least “transitional” treatment to a person who moves from being eligible and covered in the plan to being not covered or enrolled? This would get at the issue of needing to avoid “abandonment of client” claims. | The PAHP's responsibilities are for the delivery and management of covered services, and related identified administrative functions, as well as coordinating care with other service systems. The PAHP is responsible for Medicaid services for Medicaid eligible people, and services outside of that will have to be funded by other state or local funds. |
| Parents | How does family involvement work as children transition between services—what agency is designated to facilitate this, to assure it happens? Some providers including some centers invite us and include us, others do not—how will you assure this is easy for us. | One of the responsibilities of the PAHP will be to provide service planning oversight, with the goal of administrative functions that will help assure members have prompt access to appropriate treatment, and integration in the planning and delivery of covered services. The PAHP will be responsible for work on-site in joint treatment planning conferences for individual Members and in community service planning, all designed to ease transition and access for members and their families. |
| CW Contractor |
Overall question –
If the PAHP is owned by the CMHC’s and the contractor is the directors of all the CMHC’s
the question is: How can the Managed Care Contractor be the Service
Provider? Is this not a huge conflict of interest not only at the state
level but at each geographical level?
|
While it is not uncommon for the entity managing the service delivery system to
also be responsible for ensuring services are delivered, the policy
decision made in this situation (after significant dialogue and input
from a wide array of stakholders) was the use this structure in order
to preserve the valued features of the existing public mental health
system and maximize efficiency. Certainly some inherent conflict of
interest is potential, and a variety of counter-weights to that are
embedded in the structure and oversight of the PAHP contract. |
| CW Contractor | Page 50 – Question: How can the party of interest not be a conflict with the CMHC’s owning the PAHP? | Page 50: Because CMHCs are a party in interest, their interactions with the PAHP will be closely monitored. |
| CW Contractor | Page 60 - Question: Is contact year one just a practice one? | Page 60: No - the first year is not a "practice" year. Significant duties and functions around operationalizing this CMS-approved service structure, developing the provider network, initiating new services, and gathering core baseline data are included in extensive first year responsibilities. |
| CW Contractor | Page 64 - Question: How will the PIP and PAHP work together on such things as the dually diagnosed? | Page 64: The PIHP and PAHP, in collaboration with SRS staff managing tho system protocol, some specifics of which are included at section 1.8.2 of the PAHP contract. |
| CW Contractor | Page 74 - Question: Is the March deadline realistic? | Page 74: SRS has negotiated with the PAHP a series of work plan features and timelines, all of which we hope will be both realistic and achievable; and the substance of which are incorporated into the PAHP contract. |
| CW Contractor | Page 96 – Hold harmless – Question: Are the private providers being asked to indemnify the state? | Page 96: This is standard hold harmless language included in State of Kansas contracts, designed to essentially require parties to be answerable for themselves. |
| CW Contractor | Overall Question: How does a non risk bearing system interface with a risk bearing child welfare system. The non-risk bearing contract will be driving decisions for the risk bearing contract. | Overall: CMS always has a fear that a risk-bearing entity will shift costs to a non-risk bearing entity. CMS will require SRS to be especially vigilant to ensure that this does not occur. HHS will want to ensure that the child welfare system, conversely, does not shift costs inappropriately to the Medicaid system. SRS will work with all of our partners to keep an eye on this issue. |
| Overall Question: Why is the contract delegated to a specific entity rather than issued as an RFP? Overall Question: Each Executive Director of a CMHC functions under their individual Board of Directors. Does this not become a conflict of interest when they have to balance the PAHP needs vs. their individual Board of Directors? | See the "Background" section of the PAHP contract for a discussion of the policy values that went into this decision. There is a potential for conflict of interest that each CMHC will need to manage with its board. The PAHP likewise will have to address this issue with its Board of Managers. SRS will be watching for potential conflict issues across this and related service systems, and look for accountability to the contract outcomes. | |
| Diverse - Stakeholder Meeting | What is scope of contract? To Medicaid expenditure and Medicaid recipients? And other processes and touchpoints? | The PAHP's responsibilities are for the delivery and management of covered services, and related identified administrative functions, as well as coordinating care with other service systems. The PAHP is responsible for Medicaid services for Medicaid eligible people, and services outside of that will have to be funded by other state or local funds. |
| CW Contractor |
page 50 1.11.13.d.1 Will not there possibly be a conflict of interest related
to the Consortium if it or any other entity owned by the CMHCs act
as the PAHP? page 60 1.12.2.h Does the word “Departments” mean the same thing as PAHP/CMHC? |
See conflict of interest discussion above. This refers to SRS. |
| Stakeholder Representative | Administrative | Answer |
|---|---|---|
| CW Contractor | 1.8.2: What would be an example of a MH service that a CWCBSP would provide? Some IL services may overlap, but most MH services have been carved form the CWCBSP contracts. | Under the oversight of the PAHP, all mental health services will have to be medically necessary, and the PAHP will have to subcontract with the provider of the mental health service. Medicaid mental health services are specifically excluded from the CWCBSP contracts, and are exclusively the responsibility of the PAHPage |
| Parents | When and how will standards of care be developed; for the type of care required, accessing care, delivering services, evaluating services, monitoring services? Will families be involved in developing these standards and what are the standards for family involvement in developing these? When/how will you provide families time and space to provide input into this process, alternative ways to offer input. How will you make clear to parents the ways to get services, the contract says we think only manuals will be given to parents who request them —how will parents get all this information—in languages and forums they understand? Who is going to explain all this and how? In parent terms? Parent education in these changes is critical, what has changed, how it has changed, how to access, how to be part of designing, implementing, etc. | The structure guiding all of these issues are included in the PAHP contract. The implementation of them will be further developed by the PAHP, with ongoing stakeholder input. Yes, consumer and their families will continue to be involved at every important phase of this transition and implementation. Additional details about opportunities for involvement will be communicated in the coming weeks. The beneficiary handbooks (addressed in section 1.14 of the PAHP contract) will address this basic information, supplemented by ongoing training and information sessions hosted by the PAHP and website information developed by the PAHPage |
| CW Contractor | Page 22 – 1.5.10 – Questions: The area appears to make
some necessary services optional to provide. i.e. Sex Offender, services
for youth in the child welfare or juvenile justice system? Does this
area close the door for other than CMHC’s to provide such services
to therapeutic foster care?
|
All
covered services are addressed in Section 1.5 of the contract (and
Appendix F). This section deals with potential additional services
developed over time, with perhaps some specialized focus. There is
no prohibition against other licensed practitioners providing services
under the scope of their license (consistent with provider network
standards in the PAHP contract). |
| CW Contractor | Page 27-b Question: It reads as though the physician can over rule the finding of the screen team, is this so? | Page 27b - Yes. |
| CW Contractor | Page 27 – Question: Will consumers and providers have a place on the utilization management teams? If not, this is a large concern. | Page 27 - Any person who is adequately trained and competent to perform UM functions can be employed to do that work. |
| CW Contractor | Page 30 – f-g Notifying the physician of changes in medication may be difficult if the primary provider is at a distance – i.e. foster care youth/PRTF youth. Question: Will physicians be willing to be engaged at this level? | Page 30 - CMS requires coordination with primary care providers. |
| CW Contractor | Page 32 – Question: Need clarification on who the “contractor” responsible for transportation, etc. is? | Page 32 - "Contractor" refers to the PAHPage And the PAHP is not responsible for transportation, but for coordinating with HealthWave or KHPA for transportation for TXIX members. |
| CW Contractor | Page 8 1.3.2 Does this mean that the Contractor must also provide services for sexually aggressive youth? | Page 8 - The Contractor may not discriminate against individuals on the basis of health status, including sexually aggressive youth. The covered services are designed to treat diagnosed mental health conditions. |
| CW Contractor | Page 9 1.5.1.d Is there any provision for other entities to provide input or guidance on how Community Reinvestment Funds are used to establish additional service for beneficiaries. | Page 9 - SRS would welcome, and would expect the PAHP to welcome, suggestions on the use of community reinvestment funds. |
| CW Contractor | Page 22 1.5.10 In proposing new services … such services and programs may include … sex offenders/misuser/abuser treatment programs for youth and services for youth in the child welfare or juvenile justice system. Does this mean that services are not otherwise required for these populations? | Page 22 - See response above. |
| CW Contractor | Page 26 1.5.12.1 The staffing ratios are not clear … particularly the supervisor ratio. All the rest appear to be based on beneficiaries, and the supervisor on staff, but it is not clear. | Page 26 - these guidelines regarding supervisor ratio are based on supervisor to staff. |
| CW Contractor | Page 28 1.7 How will membership in the State Quality Committee be determined? Who will be eligible to participate? | Page 28 - SRS actively seeks volunteers to participate in, and suggestions about the makeup of, the State Quality Committee. |
| CW Contractor | Page 37
1.10.4 Service Authorization Denial…Contractor shall give notice
as expeditiously as… Please
define expeditiously. Denials of authorizations may take up to 14 days
for new requests and 28 days for renewal requests. Why the long delay
while the member is waiting for services? |
Page 37 - the federal requirement
is that service authorization decisions occur as expeditiously as the
member's health condition requires. There is no specific hour or day
requirement, but good practice must take into account the person's
current health condition and needs. There is no distinction between
initial and renewal requests in the timing. The requirements of this
contract actually shorten and specify current decision requirements. |
| CW Contractor | Page 50 1.11.14 The Contractor is to write the provider manual. Is this the same or different from the current K-MAP manual? The provider manual is to be distributed at least 30 days prior to the effective date of the contract. Please see 45: 1.11.6 above. Are the providers to sign agreements to provide services to the beneficiaries prior to seeing or knowing the content of the manual? Will that manual be a part of the subcontracting agreement? | Page 50: This manual will be different from (and take the place of) the existing KMAP manual. We anticipate that provider manuals will be available for subcontractors to review, but entering those agreements will be voluntary. The PAHP is going to develop the terms and processes of associating (sub-contracting) agreements in collaboration with independent practitioners. |
| CW Contractor | Page
51 1.11.14.b Provider specific profile reports. Will the methodologies
for monitoring provider performance be clarified and available to
the providers? The Contractor is to share the results with SRS. Are
the results also to be shared with the providers? If so, in what
format and how often? Will the base date be available? Satisfaction
surveys are to be developed for member feedback on the performance
of subcontracted providers. Will there be similar satisfaction surveys
for the CMHCs/PAHP? |
Page
51: Yes - they will be clarified. Yes - it is SRS's
intent that the results get shared with providers. The specific format
and informing data will be developed during the initial phase of
the contract. And yes - satisfaction surveys will relate to CMHCs
as all other subcontractors. |
| CW Contractor | Page 52 1.12 Quality assurance/performance improvement…will each CMHC be required to develop their own programs or will one program be shared across all CMHCs? If the PAHP is a different entity form the CMHCs, will it also have a parallel program? | Page 52 - The terms of the PAHP's QA and PI programs will apply to all services and providers covered in this contract. |
| CW Contractor | Page 23- ii Question with how the eligibility determination is made? | Page 23 - The PAHP will be responsible for this. |
| CW Contractor | Page 38 1.10.6 If for a service decision isn’t made timely why would that constitute a denial? Doesn’t make sense | Page 38 - This is a federal requirement. A denial decision gives a specific, appealable answer to the consumer, and brings the issue to SRS's attention. |
| Stakeholder Representative | PAHP Organization | Answer |
|---|---|---|
| CW Contractor | 1.1.3: This section states that the CMHCs have been selected as the PAHP: is this as each CMCH individually or as the “conglomerate” as in earlier discussions? 1.11.12.c.: How do we define a “sufficient” network and how do we measure such? | 1.1.3 - The conglomerate is the PAHPage 1.11.12.c - Between 1.11.12.e, describing choice; and the liquidated damages associated with provider network requirements; and the anticipated responsiveness to the grievance and appeal process -- it is our intention over time that the network will be well sufficient and gaps will be responded to. |
| CW Contractor | Page 52 1.12 Previously many Medicaid providers other than the CMHCs have been required to be accredited by a national accrediting body. Why is accreditation not required in this contract? It would address many of the QI/PM issues. | Page 52 - Accreditation for a health plan is different from accreditation for a service provider. We do not believe the services covered by and administrative functions required by this contract warrant accreditation. |
| Stakeholder Representative | Provider Network | Answer |
|---|---|---|
| CW Contractor | Page
45 – 1.11.6a. Time frames for approval of independent providers
are unclear. (c) What is an open panel approach to deciding on the
number of independent providers needed? Under adequacy of network – timeliness
of service provision should be one of the factors evaluated. Page 51 ii - Thirty calendar days is not much. Question: Are they also going to share this with the providers? |
Page 45: All applications have to be process within 90 days; and 90% must be processed within 30 days. ~ the open panel approach requires the contractor to offer any willing, qualified licensed practitioner a sub-contract. ~ timeliness of service provision is one of the factors evaluated. Page 51: In light of the implementation timeline for this contract, we concluded 30 days was generous. In addition, the "guts" of the provider manual are included as a broadly-published attachment to the contract. |
| There have been statements made that the CMHC’s would only have to associate for therapy services and not for rehabilitation services such as community psychiatric support and treatment, psychosocial rehabilitation, peer support and crisis intervention. Overall Question: How about other services such as Targeted Case Management, HCBS SED Services etc. Which services can be contracted for by any willing provider and which cannot? | See Section 1.11.6.c - the only services the PAHP will be required to subcontract with any willing provider for are licensed outpatient therapy/other practitioner services. | |
| Diverse | Will an adequate and effective Provider Network be in place by July 1st? | Yes - that is our work plan. |
| CW Contractor | Page
9 1.5 Does this mean that psychiatrists are not required to have an
associate agreement with a CMHC in order to serve members? |
Page
9 - Psychiatrists ARE required to associate with the PAHP in order
to provide Medicaid mental health services. From the contract, Section
1.4(b): Mental health services provided in a medical (physical health)
MCO member’s PCP or medical office (i.e., DO, MD,) shall not
be the responsibility of the PAHP, other than services provided by
a psychiatrist. |
| CW Contractor | Page 13 1.5.2 Please define “network of providers”. Is a “provider” different from a “subcontractor”? If so, how?Please define “full array of mental health services”. Are these the services listed in section 1.5? 1.5.3.2 Please clarify what constitutes “reasonable efforts” in subcontracting with Rural Clinics and FQHCs. | Page 13 - "Providers" is essentially the same as "subcontractors." There can be additional subconstractors for administrative functions as well. Yes - the full array is as noted in section 1.5, and as further defined in Attachment F. As to FQHCs: This language has been clarified; please see Section 1.5.3.2 of the final PAHP contract. |
| CW Contractor | Page 42 1.11.1.h In no instance shall an enrollee be required to drive more than 60 miles to receive outpatient services. In western Kansas? Network adequacy…after a consumer’s first appointment, the PAHP shall begin providing any necessary and appropriate services to that consumer within a timely period. Will or has been “timely period” been defined? | Page 42 - The access standards will be finalized in the PAHP contract, and will be applicable statewide. Timely period was defined in section 24.24.4.b |
| What happens to the providers that hold subcontracting agreements but are not part of the panel? Will the PAHP/CMHCs be providing physician/psychiatric oversight for the provider network or will each provider need to have their own physician on staff? | All providers holding subcontracting agreements are part of the panel. LMHP services do not uniformly require physician oversight; the practitioner will have to act within the scope of his/her license. The physician oversight for specialty services will be governed by the state plan and enforced by the PAHPage | |
| Page 48
1.12.12 Enrollees will be give the choice between at least two providers
in the network. Will there be any mechanism to assure that subcontracted
providers are ever offered or how frequently they are offered in that
choice? |
Yes - beneficiary information requirements in Section 1.14 dictate that all beneficiaries be offered information and choice about all providers, and a process to make their selection. | |
| Page 86 13.0.d Subcontracted physician…is this subcontracted physician or subcontractor’s physicians? Providers…maintain all applicable insurance. What types of insurance and in what amounts? This provider discrimination section may not be construed to require to contractor to subcontract with providers beyond the number necessary to meet the needs of its members. How does this work with the concept of “any willing provider”? And, how does it mesh with item (d)? Contractor will be required to utilize on the SRS-approved fee schedule for all provider reimbursement. Does this mean that the entire amount on the fee schedule will be paid to the provider? Will payments/rates/fees be negotiable provider to provider? | Page 86 - 13.0.d - both. As defined by practitioner licensure standards, and as required by PAHP (with SRS approval) This is language ONLY to satisfy federal requirement. The provisions of part (o)(iv)(a, b and c) apply ONLY to (o)(i, ii and iii). Part (o)(iv)(d) clarifies the SRS policy requirement for any willing provider. Only a fee schedule approved by SRS will be used. |
| Stakeholder Representative | Institutional
Interface/Concurrent Utilization Review |
Answer |
|---|---|---|
| CW Contractor | 1.5.3.6:
PRTFs are included with other institutions—dose this imply that
“emergent” protocol with 1-3 hour response time is in effect? |
1.5.3.6
- No. |
| CW Contractor | 1.5.4.i/j.: Can a youth in crisis be taken to the ER and receive immediate MH services? | 1.5.4.i/j - Yes. |
| CW Contractor | 1.5.5.c.i.: What does respond mean? Is acknowledging the receipt of such request count or does this mean approve/deny the actual pre-authorization? | 1.5.5.c.i - must approve or deny. Acknowledging receipt is not adequate. |
| CW Contractor | 1.5.5.e.: The references to a physician oversight is unclear—will this section be amenable for negotiation as was done for the IFBT agreements just recently begun? | 1.5.5.e - this is federally required language, and will not be netogiated. |
| CW Contractor | 1.5.7.b: Referral within 24 hours too long unless community based wrap around alternatives are in place—we suggest 3 hours. | 1.5.7.b - if the situation is an emergency, 3 hours will be the requirement; that is not required for the urgent situations addressed here. |
| CW Contractor | 1.5.8 Certification of Need: request clarification that the CBST be “lead” by the CMHC. We also assume that the “subcontractor” noted in the last paragraph on page 19 is referencing the CMHC not the CWCBSPage 1.5.8 PRTF Certification of Need: Who determines if a child is in a place of safety? What are time frames to act if their placement is NOT safe? | 1.5.8 - The PAHP is responsible to ensure the certification of need occurs. The PAHP, in collaboration with the referring party and knowledgeable others. If they are not in a place of safety, they bump into the emergency time frames. |
| CW Contractor | 1.5.9, second bullet at bottom of page 21: We assume that the community based provider for continuing MH services is the CMHC and not the CWCBSPage | Yes. |
| CW Contractor | Page
15 – Admissions and Discharges Question: Is the contractor the
entity that becomes the PAHP? Is the contractor not simply the directors
of each CMHC? If so, will they have such a large technical infrastructure
set up that quickly? Overall question- The document refers to many
standards regarding PRTFs. However, in the definition section, it states
that the PAHP will not provide for, arrange for, or is not otherwise
responsible for the provision of any inpatient hospital or institutional
services for its enrollees. Question: Why would the contract address
anything beyond the duties of the CMHC’s to screen and arrange
CBST meetings? |
Page15
- The contractor is the PAHP, and is a different functioning entity
than "the directors of each CMHC." In order to meeting the
contract, the required infrastructure will be in place. The Contractor
has both screening and ongoing assessment responsibilities for members
accessing PRTF services, and also has system management responsibilties
more broadly. |
| CW Contractor | Page 15 – 1.5.8 Questions: What about an emergency admission process for PRTFs? Does it not need to line up with the new SRS policy on emergency admissions? Should the team include the physician as it could make the certification unrealistic? What is the difference between an LMHP and a QMHP? To be consistent, should it not just be LMHP? Please clarify the youth’s county of residence relative to service provided by the local CMHC. Who is the subcontractor referred to in this section? | 1.5.8.a and 1.5.8.c both
address the emergency related PRTF access processes. The updated language about emergency exceptions has been added into the final contract. Physician involvement is a federal requirement. QMHP is statutorially defined, with the substantive differences being the QMHP's employment in a CMHC and the specific responsibilities associated with gatekeeping for psychiatric inpatient services. Whomever is contracted with the PAHP for this responsibility. |
| Page 20 – PRTF Certification of Need – Question – Would not all PRTF admissions be, at minimum, emergent if the youth are headed for a PRTF? Does the emergency screen need to be updated to fit the SRS definition/process? What does the phrase “subcontractor” mean? | Page 20 - No. The screen will need to fit the policy ongoing. See above. | |
| Page 21(c) Question – If a non certification is notified immediately, why does it take two days to make a notification of certification? | Page 21 - Written notice is required for either decision within 48 hours. Notice of a denial is required immediately so that the Member can pursue other options. If the decision is approval, the services will commence. | |
| Page 21 Question – Is it true that the PAHP does not determine eligibility, the screener does? There is confusion between the use of the terms PAHP and the CMHC’s? | Page 21 - The PAHP is responsible for certification of need. | |
| Page 22 Comment/Question – 30 days is way too long on medication evaluations after D/C from inpatient. The PRTFs are required to give some medication and a prescription. If the child is on a controlled substance, 30 days will not meet the need. Should the appointment not occur more quickly for success of the discharge? | Page 22 - The intention is that action takes place more promptly, and we will clarify that in the contract. | |
| Page
32 1.8.3 – Question: Why is this section the role of the PAHP?
Why would the CMHC get the courts involved? Is this section saying
the PRTF provider or the CMHC provider is in charge of discharge planning? Why do the CMHC make decisions related to shelters? Seems entire section needs clarification. |
These value-based requirements are designed to give attention to effective discharge arrangements that will enhance the durability and success of this important transition point. | |
| Page 33 – Question – Why would the CMHC’s have a say in the discharge planning for 24 hour care programs if they are not paying for them? | The PAHP is responsible for managing the system of care related to all mental health services, including those which are "substitutable" and part of the overall system cost caPage | |
| Diverse - Stakeholder Meeting | Why is PAHP responsible for getting discharged from state hospital? Most majority is not Medicaid. Questioning the unilateral decision of the state hospital. Spell it out, don’t form a battleground. Don’t leave provider out. | The PAHP is responsible for managing the system of care related to all mental health services, including those which are "substitutable" and part of the overall system cost caPage Good discharge planning will involve including others, and this has been addressed more clearly in the final contract. See also section 1.8.3 and 1.8.4 of the contract. |
| CW Contractor | Beneficiaries
are not eligible for services under this contract while they are in
treatment at a PRTF. How then can the Contractor provide re-screens,
discharge planning, etc. for a youth who is receiving care in a PRTF? |
The
PAHP's responsibilities are for the delivery and management of covered
services, and related identified administrative functions, as well
as coordinating care with other service systems. This includes the
screening and ongoing assessment responsibilities for members accessing
PRTF services, and also broader system management responsibilties. |
| CW Contractor | Page 15 1.5.3.6 Whose responsibility will it be to track admissions and discharges? Each CMCH or will there be a centralized process? | Page 15 The PAHP will be responsible for tracking and trending required data elements. |
| CW Contractor |
Page 19 1.5.8 Again, how can the Contractor bill for recertification for PRTFs when children in PRTFs are excluded from this contract? Are the CMHCs recouping costs via their administrative fee? Individuals personally presenting at PRTFs…does this mean that a PRTF provider will not be paid for beneficiary care if a youth is admitted prior to Certification of Need? Is this clearly spelled out in the PRTF standards also? Are the terms “LMHP” and “QMHP” used interchangeably in this document or is there a distinction between them? Please clarify the meaning of “subcontractor” in the last paragraph on this page and throughout the document.The certification team must include a physician. This has not happened frequently in the past. Will it be a requirement for this contract? QMHP is statutorially defined, with the substantive differences being the QMHP's employment in a CMHC and the specific responsibilities associated with gatekeeping for psychiatric inpatient services. subcontractor refers to any party that the PAHP as the contractor chooses to contract with. Physician involvement is a federal requirement and will therefore be a requirement of the contract. |
Page 19 Certification of Need and Recertification of need in addition to ongoing coordination of community based care for individuals residing in an institution are administrative functions and will be reimbursed accordingly. Certification of Need is required to establish the medical necessity of PRTF services. Medicaid reimbursement for PRTF services cannot occur until the medical necessity of the services has been established. |
| CW Contractor | Page
20 1.5.8.Will the Contractor be assuming responsibility for the convening
of CBSTs? The Contractor will notify the responsible subcontractor … Who
would this subcontractor be? The CMHC? It is understood that a different
approach to the Emergency Exception Screening Procedure was developed
through committee work. Will that revised approach be incorporated
into the contract? Why will notice of denial be given immediately but
notice of approval take 48 hours? The Contractor shall…perform
PRTF-specific eligibility functions. What eligibility, and what functions? |
Page 20 The PAHP will be responsible for convening the CBST team as specified in the contract. Subcontractor refers to any party that the PAHP as the contractor chooses to contract with. See prior answers. |
| CW Contractor | Page 21 1.5.9 Coordinating and facilitating the Community Based Services Team and implementing the Community Based Service Plan appears to now be the responsibility of the Contractor, and the Contractor will be reimbursed for those services out of the administrative fee. Is this correct? The Contractor is to “schedule” necessary Med evals and treatment for post PRTF services within 30 days of discharge. There is no timeframe for when the actual services are to be received…just scheduled. This will NOT meet the needs of youth who are discharged. | page 21 Yes, see previous answer. |
| Is the PAHP the CMHCs are the subcontractors CMHCs? What constitutes “regular” on-site presence and “regular” face to face contact with beneficiaries/members who are in institutional/facility based settings? | CMHCs will become subcontractors to the PAHPage The needs of the people receiving services, and the issues related to effective transition and aftercare planning will dictate what constitutes effective on-site and face to face contact. | |
| Page 32 1.8.3 The PAHP shall initiate and enforce policies that require providers to initiate discharge planning [from inpatient mental health treatment]…. What providers: the PRTF providers? What authority would the PAHP have over the PRTFs? Who will they require to do what? The contract indicates that SRS does not want youth being discharged from PRTFs to shelters. Will the PAHP/CMHC be responsible for location and/or funding other preferred discharge placement? The PAHP shall be involved in and support the discharge planning of any member who is receiving twenty-four hour care, whether or not that care is being funded in whole, or in part, by the service funded in the Contract. Does this mean that the PAHP will be involve in discharge planning from JDF or the Youth Residential Centers? | Page 32 Providers refers to those providers subcontracted with the PAHPage It is SRS's value-based expectation that the PAHP will be involved in assisting all members who are in need of mental health treatment with transition planning, aftercare services, and accessing community resources. This includes, for example, that the PAHP will be responsible for work on-site in joint treatment planning conferences for individual Members and in community service planning, all designed to ease transition and access for members and their families. |
| Stakeholder Representative | Institutional
Interface/Concurrent Utilization Review |
Answer |
|---|---|---|
| CW Contractor | Page 61 1.12.2.h No incentives until year 3, no penalties until year 2…how can penalties be assessed in a “no-risk” contract? This section lists the penalties but not the incentives. What are the incentives? | Penalties can be assessed in any contract where there is a failure to perform the required scope of work. Incentives will be developed by SRS prior to year 3. |
| Stakeholder Representative | Grievances and Appeals | Answer |
| CW Contractor | Page
37 – Question: Should this section reflect the emergency definition
for a service decision? |
Page 37 - both standard and expedited timelines here reflect federal rquirements. |
| CW Contractor | Page 40 – Designee or “guardian” should be added under grievance. The guardian should be able to initiate a grievance. | Page 40 - Designee is a broader term that certainly includes guardian. |
| Stakeholder Representative | Consumer Involvement | Answer |
| Parents | How do families get invited to participate in planning and work groups? Where do we get training and background information to do this work? How do we know the families picked represent the rest of us—how do you know? What is the plan for wide involvement from parents from all over the state especially poor parents, minority parents and non English speaking parents—how are they going to learn about this but more advise you about what they need—who is advising you about what they need? How are you providing updates to families so we know what is happening? We don’t know what is happening? Until we got this invitation only one of us had heard this was even happening. | The structure guiding all of these issues are included in the PAHP contract. The implementation of them will be further developed by the PAHP, with consumers and their families continuing to be involved at every important phase of this transition and implementation. Additional details about opportunities for education, training, and involvement will be communicated in the coming weeks. |
| Stakeholder Representative | Service Descriptions (provider qualifications, limitations, exclusions, etc.) | Answer |
| Diverse - Stakeholder Meeting | Clarification around rates and co-pay. 90806 – Individual Therapy – is Medicaid going to get the full $60? What about co-pay? | The PAHP will be paid on a per-member-per-month basis, the foundation for which is a combination of service utilization and payments based on SRS approved fee for service Medicaid fee schedule. Co-pays should NOT be charged by the PAHPage |
| Stakeholder Representative | HCBS SED Waiver | Answer |
| CW Contractor | Page 23 – ii – Question: How will the eligibility determination be made? Who will make it? | The PAHP or their subcontractor will determine clinical eligibility. Clinical eligibility must be established by a QMHP utilizing SRS approved protocols. |
| CW Contractor | HCBS SED Waiver Services: * Will children in the foster care system receive SED Waiver Services? | Any youth meeting clinical eligibility and financial eligibilty has access to HCBS SED waiver services (and other services) consistent with the service descriptions, locations and limitations. |
| Diverse - Stakeholder Meeting | Explain – provider, contractor, subcontractor, PAHP, associates (could not track throughout document) Affiliate vs. Associate – what is the difference? | These definitions were clarified in the final contract. |
