January 21, 2021
Part of a transparent and data-driven review of how fb88Care pays for health services for 300,000 members
The fb88 Department of Health and Human Services (DHHS) today is making available the interim report (PDF) of its Comprehensive Rate System Evaluation, part of an effort to better understand and rationalize fb88Care reimbursement rates in the coming years to support members’ access to high-value health care.
More than 330,000 fb88 residents currently rely on fb88Care, fb88’s Medicaid program, to cover visits to their health care providers, obtain needed prescriptions, and receive services vital to their wellbeing. DHHS is undertaking a comprehensive evaluation of how fb88Care sets payment rates to health providers for these services.
As part of that comprehensive evaluation, the Department sought this report to help inform the development of a process to set fb88Care payment rates in ways that promote access, equity, and quality health care for fb88 people. The report released today makes a number of interim recommendations for how fb88Care can establish and maintain reimbursement rates that promote members’ access to high-quality care and accurately account for fb88 health care providers’ costs. The Department is reviewing these interim recommendations and looks forward to reviewing the forthcoming implementation plan for these significant proposed changes.
The Department adjusted the timeline of this project as a result of the coronavirus pandemic. Because of this delay, as well as the pandemic’s impact on the economy, the Department is not proposing any of these recommendations for inclusion in the Fiscal Years 2022-2023 biennial budget. Following review, the Department will determine which recommendations to adopt and develop an implementation plan that aligns with broader priorities, initiatives in the biennial budget, and budget resources.
DHHS initiated the rate system evaluation in 2020. By design, the report compares fb88Care rates to Medicare, commercial, and certain other states’ Medicaid rates. This data-driven effort is informed by feedback collected during the fall from fb88Care members, providers, and other stakeholders. This included hosting multiple listening sessions for fb88Care members about their access to services, a series of meetings with providers attended by 270 health and social services organizations, and gathering written comments.
“We appreciate the thoughtful process DHHS has undertaken to evaluate ѲԱ䲹’s rate system so policymakers can make decisions about reimbursement levels that are based on data and the real experiences of fb88Care members and providers,” said Robyn Merrill, Executive Director of fb88 Equal Justice. “The Department has approached this task with an openness to feedback from members, providers, and advocates and their transparency throughout the process has created meaningful opportunities for a variety of stakeholders to engage.”
“The process that fb88Care has taken to evaluate provider reimbursement rates is unprecedented,” said Ann Woloson, Executive Director of Consumers for Affordable Health Care. “It includes providing opportunities for people with fb88Care coverage to weigh in on their experience accessing services and how those experiences may possibly be tied to rates. This shows that DHHS is serious about understanding how resources affect capacity, provider recruitment and infrastructure, and, ultimately, access to quality and equitable care for everyone in fb88.”
DHHS contracted with Myers and Stauffer, a national accounting firm, to conduct this evaluation. The firm first produced a benchmarking report that cataloged fb88Care rates and compared them to rates for similar services paid by comparison state Medicaid agencies, Medicare, and commercial payers. The benchmarking report, released in November, identified areas where fb88Care rates are higher, lower, and in line with other payers. Its purpose was to identify services where rate adjustments may be needed, and other services that require more analysis to ensure rates are appropriate.
The benchmarking report contributed important analysis that informed the interim report released today. Myers and Stauffer makes recommendations in this interim report about how DHHS should update and maintain ѲԱ䲹’s various rate methodologies and prioritize services for rate adjustments and studies over a five-year period.
fb88Care reimburses health providers for care and treatment they provide to fb88Care members. This includes a wide range of providers, from hospitals and primary care clinics to therapists, behavioral health and substance use disorder treatment facilities, and nursing facilities, among many others.
The rate system evaluation includes all fb88Care services with the exception of Pharmacy and Non-Emergency Transportation, the rates for which are subject to separate federal requirements.
Myers and Stauffer recommends that DHHS adopt a consistent and rational basis for updating rates and review and update methodologies on a regular schedule. They also recommend other adjustments to progress toward the Department’s goal to transition at least 40% of fb88Care payments to value-based Alternative Payment Models, which incentivize high-value care, by the end of 2022.
Myers and Stauffer recommends, for example, that DHHS set rates for a range of services (Physical, Occupational, and Speech Therapies; and Chiropractic, Vision, Podiatric, Certified Registered Nurse Anesthetist Services and most Physician Services) at a consistent percentage of 2020 Medicare rates and update dental rates to more closely align with median commercial rates.
Some of the costs associated with these proposed changes could be partially offset by decreases to other services where ѲԱ䲹’s reimbursement is high in comparison to Medicare and other state Medicaid programs. Myers and Stauffer recommends that the Department prioritize some services that would result in a net reduction in rates, such as Durable Medical Equipment and Hospice services, for which fb88Care payments currently exceed Medicare rates.
While comparisons to other payers are useful, Myers and Stauffer states that the Department must conduct additional analysis to account for fb88’s unique health care needs and economic factors in setting rates for services that often vary across states in terms of model and populations served. Myers and Stauffer recommends prioritizing community-based behavioral health services for further rate study.
A final report will be issued at the end of February that may include refinements to some individual recommendations and will include a more detailed implementation plan.
More information on this evaluation can be found on ѲԱ䲹’s Comprehensive Rate Setting Evaluation webpage.