Medicaid Managed Care - U.S. Senate Special Committee on Aging
Medicaid Managed Care - U.S. Senate Special Committee on Aging Medicaid Managed Care - U.S. Senate Special Committee on Aging
Accessibility, Availability, Referral and Triage 786 f) Program Effectiveness (QI 10) NCQA fails to require that information from the plan's assessment of its overall effectiveness be shared on a regular basis with the public payor and made available to the public. a) Accessibility of Services (ARI 1) The standards regarding accessibility are very limited and generally do not address accessibility issues as understood in the public sector. NCQA standards focus on measures of availability suitable for a work- ing population (e.g., how quickly telephone queries are answered and whether members get appointments when they should). While these are useful, public payors will want to consider issues such as outreach, ser- vices to homeless persons, cultural barriers to access, language barriers, the need for assertive follow-up for members who have not kept ap- pointments, etc. Public purchasers should consider setting their own de- tailed standards regarding the availability and effectiveness of critical services for special populations. NCQA does not require the information collected about plan per- formance on measures of access to be made available to the payor or to the public. However, stakeholders should have the opportunity to re- view how well a plan is doing in reaching the covered population, in- cluding hard-to-serve groups. b) Referral and Triage (AR 3) In public-sector systems, referral and triage should include considera- tion of the need for various services furnished through various systems, such as health care, social services, housing and education. The NCQA standards address only referral to behavioral health services within the managed care plan and do not address the need for referrals to external agencies and programs providing related services. A definition of what is meant by referral and triage would be beneficial, along with specific standards with respect to referral for various support services. Utilization Management a) Utilization Management (UM 1) NCQA requires that there be a written description of the utilization- management program outlining its structure and accountability. This de- scription should be made available to the public payor and the public. NCQA Accreditation Standards for
787 b) Utilization-Review Criteria Utilization-munagement standards are required to be based on 'reasonable scientific evidence.' However, it is also appropriate and, in the public sector, often necessary that services be provided if they are considered 'best practice.' Waiting for the publication of 'reasonable scientific evidence' can stifle the service system's capacity to provide the most promising interventions. NCQA does not require utilization-management criteria to be made available to the payor or to the public, yet these criteria will determine what services are provided to members, under what circumstances and for how long. c) rne'liness of Utilization Managemnent Decisions (LTM 4) NCQA requires that the plan establish standards for timeliness of its utilization-management decisionmaking. In the case of public systems, the payor may wish to establish its own requirements as to what those standards should be in (1) emergency. (2) urgent and (3) routine situations. d) Medical Necessity (UM 5) NCQA requires that the plan 'consult' with the treating professional. However, the role of treating professionals and the weight to-be accorded their recommendations should be more clearly spelled out. NCQA makes no references to the member's choice. Yet in determining whether a service is necessary, a member's preferences should be taken into account. This is particularly true if the member has rejected one form of treatment but seeks an alternative that is also an effective intervention. NCQAkappropriately makes no specifications in the accreditation standards regarding what is an acceptable definition of ffledical necessity. Public purchasers should insist on creating this standard themselves. For more information on derisionmaking regarding when a servire is medically necessary, see the Bazelon Center issue paper, Defining 'Medi- cally Necessary' Services to Protect Plan Members (see resource list). e) Utilization-Management System: Inceitixgs NCQA standards do not address several areas of concern regarding managed care plans' relationships with providers in their network, through which the plans may encourage, or even force, practitioners to NCQA Accreditation Standards for
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787<br />
b) Utilizati<strong>on</strong>-Review Criteria<br />
Utilizati<strong>on</strong>-munagement standards are required to be based <strong>on</strong> 'reas<strong>on</strong>able<br />
scientific evidence.' However, it is also appropriate and, in the<br />
public sector, often necessary that services be provided if they are c<strong>on</strong>sidered<br />
'best practice.' Waiting for the publicati<strong>on</strong> of 'reas<strong>on</strong>able scientific<br />
evidence' can stifle the service system's capacity to provide the<br />
most promising interventi<strong>on</strong>s.<br />
NCQA does not require utilizati<strong>on</strong>-management criteria to be made<br />
available to the payor or to the public, yet these criteria will determine<br />
what services are provided to members, under what circumstances and<br />
for how l<strong>on</strong>g.<br />
c) rne'liness of Utilizati<strong>on</strong> Managemnent Decisi<strong>on</strong>s (LTM 4)<br />
NCQA requires that the plan establish standards for timeliness of<br />
its utilizati<strong>on</strong>-management decisi<strong>on</strong>making. In the case of public systems,<br />
the payor may wish to establish its own requirements as to what<br />
those standards should be in (1) emergency. (2) urgent and (3) routine<br />
situati<strong>on</strong>s.<br />
d) Medical Necessity (UM 5)<br />
NCQA requires that the plan 'c<strong>on</strong>sult' with the treating professi<strong>on</strong>al.<br />
However, the role of treating professi<strong>on</strong>als and the weight to-be<br />
accorded their recommendati<strong>on</strong>s should be more clearly spelled out.<br />
NCQA makes no references to the member's choice. Yet in determining<br />
whether a service is necessary, a member's preferences should be<br />
taken into account. This is particularly true if the member has rejected<br />
<strong>on</strong>e form of treatment but seeks an alternative that is also an effective interventi<strong>on</strong>.<br />
NCQAkappropriately makes no specificati<strong>on</strong>s in the accreditati<strong>on</strong><br />
standards regarding what is an acceptable definiti<strong>on</strong> of ffledical necessity.<br />
Public purchasers should insist <strong>on</strong> creating this standard themselves.<br />
For more informati<strong>on</strong> <strong>on</strong> derisi<strong>on</strong>making regarding when a servire is<br />
medically necessary, see the Bazel<strong>on</strong> Center issue paper, Defining 'Medi-<br />
cally Necessary' Services to Protect Plan Members (see resource list).<br />
e) Utilizati<strong>on</strong>-Management System: Inceitixgs<br />
NCQA standards do not address several areas of c<strong>on</strong>cern regarding<br />
managed care plans' relati<strong>on</strong>ships with providers in their network,<br />
through which the plans may encourage, or even force, practiti<strong>on</strong>ers to<br />
NCQA Accreditati<strong>on</strong> Standards for <str<strong>on</strong>g>Managed</str<strong>on</strong>g> Behavioral Healthcare Organiati<strong>on</strong>s 7<br />
POLICY ANALYSIS BY THE BAZELON CENTER FOR MENTAL HEALTH LAW 7