Title
Health and Human Services Agency (HHSA) recommending the Board:
1) Make findings that the provision of Psychiatric Inpatient Concurrent Review services provided by California Mental Health Services Authority are in the public's best interest and that the work is with or among another governmental entities or agencies in accordance with El Dorado County Ordinance Code, Chapter 3.13.030(B), El Dorado County Charter, Section 210(b)(6), and/or Government Code Section 31000;
2) Approve and authorize the Chair to sign Participation Agreement 6422 with California Mental Health Services Authority, with a not-to-exceed amount of $99,025.92, and for a term effective upon final execution through December 31, 2024; and
3) Authorize the HHSA Director, or Director of Behavioral Health, to execute further documents relating to Agreement 6422, contingent upon approval by County Counsel and Risk Management, including amendments which do not increase the maximum dollar amount or term of the Agreement.
FUNDING: 100% 1991 State Realignment.
Body
DISCUSSION / BACKGROUND:
The El Dorado County Health and Human Services Agency (HHSA) contracts with the State of California Department of Health Care Services (DHCS) as the Mental Health Plan (MHP) for the County of El Dorado. As the MHP, HHSA is required to conduct concurrent review and treatment authorizations for all psychiatric inpatient hospital services and psychiatric health facility services.
On May 31, 2019, DHCS issued Mental Health Substance Used Disorder Services Information Notice (IN) No. 19-026. This Information Notice mandates that county MHPs conduct concurrent review and treatment authorizations for all psychiatric inpatient hospital services and psychiatric health facility services, following the first day of admission. For Medi-Cal reimbursement of psychiatric inpatient hospital services, the beneficiary must meet medical necessity criteria set forth in Title 9 of the California Code of Regulations, Section 1820.205. MHPs maintain responsibility to ensure that services furnished to beneficiaries are medically necessary and must ensure compliance with all requirements necessary for Medi-Cal reimbursement. Decisions to approve, modify, or deny provider requests for authorization concurrent with the provision of Specialty Mental Health Services (SMHS) to beneficiaries shall be communicated in writing to the treating providers, including both the hospital and the treating physician, within hours of the decision. If the MHP denies or modifies the request for authorization, the MHP must notify the beneficiary in writing, of the adverse benefit determination.
Subsequently, on April 15, 2022, DHCS issued Behavioral Health Information Notice (BHIN) No. 22-017. This BHIN established the option for MHPs to manage authorizations of psychiatric inpatient hospital services directly or to delegate authorization functions to an administrative entity, consistent with federal law and the MHP’s contract for SMHS. As a result of this guidance, HHSA Behavioral Health Division (BHD) Quality Assurance and Utilization Management staff is currently required to review and authorize psychiatric inpatient hospital and psychiatric health facility services daily. This creates a significant time burden on limited staff resources and inhibits the ability to conduct other quality assurance and quality improvement activities.
HHSA has determined that California Mental Health Services Authority (CalMHSA) offers the background, experience, and expertise for coordinating and conducting psychiatric inpatient concurrent reviews. CalMHSA is responsible for administering the Psychiatric Inpatient Concurrent Review project with the primary purpose of conducting concurrent review and authorization for all psychiatric inpatient hospital and psychiatric health facility services on behalf of participating California county MHPs. To ensure the quality provision of services, CalMHSA has subcontracted with Keystone Peer Review Organization, Inc., also known as Kepro, to conduct concurrent review and authorization of inpatient psychiatric hospital services. Kepro will provide CalMHSA contracted MHPs with a web-enabled utilization review platform and clinical services to carry out psychiatric inpatient concurrent review and authorization services and to provide other such related services.
Approval of this Participation Agreement 6422 with CalMHSA will allow HHSA BHD to utilize a technology-assisted concurrent review process, to ensure a consistent and efficient review process which will support MHP compliance with DHCS IN 19-026 and BHIN No 22-017, and the Parity in Mental Health and Substance Use Disorder Services Final Rule (Parity Rule; Title 42 of the CFR, part 438.910).
ALTERNATIVES:
Should the Board decline to approve this recommendation, HHSA would continue to provide services utilizing internal personnel. This would create a significant time burden on limited staff resources and inhibits the ability to conduct other quality assurance and quality improvement activities.
PRIOR BOARD ACTION:
N/A
OTHER DEPARTMENT / AGENCY INVOLVEMENT:
Approved by County Counsel, Risk Management, and Information Technologies.
CAO RECOMMENDATION:
Approve as recommended.
FINANCIAL IMPACT:
There is no Net County Cost associated with this Agenda item. The Agreement is funded by 1991 State Realignment. Sufficient appropriations were included in the Fiscal Year 2022-23 Budget and will be included in future budgets for the term of the Agreement.
CLERK OF THE BOARD FOLLOW UP ACTIONS
1) Clerk of the Board to obtain signature of Chair on Participation Agreement 6422.
STRATEGIC PLAN COMPONENT:
Goal 5: “Healthy Communities: Improved health, well-being, and self-sufficiency of El Dorado County communities, residents, and visitors.”
CONTACT
Daniel Del Monte, Interim Director, Health and Human Services Agency