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HomeMy WebLinkAboutAgenda - 11-05-20; 6-e - Initiating the Process to Disengage from Cardinal Innovations Healthcare and to Seek Realignment with Alliance Health ORANGE COUNTY BOARD OF COMMISSIONERS ACTION AGENDA ITEM ABSTRACT Meeting Date: November 5, 2020 Action Agenda Item No. 6-e SUBJECT: Initiating the Process to Disengage from Cardinal Innovations Healthcare and to Seek Realignment with Alliance Health DEPARTMENT: County Manager’s Office ATTACHMENT(S): 1. Administrative Rules Governing Disengagement 2. Tailored Plan Preference Letter INFORMATION CONTACT: Travis Myren, Deputy County Manager 919-245-2308 PURPOSE: To authorize the County Manager to initiate the formal disengagement process from the County’s current Local Management Entity-Managed Care Organization, Cardinal Innovations Healthcare, and to seek realignment with Alliance Health to administer mental and behavioral health services for Orange County residents. BACKGROUND: Local Management Entities – Managed Care Organizations (LME-MCOs) are public managed care organizations that administer behavioral health services for residents in need of mental health, developmental disability, or substance use services. The State of North Carolina is currently served by seven different LME-MCOs divided into regions. Cardinal Innovations Healthcare currently serves Alamance, Cabarrus, Caswell, Chatham, Davidson, Davie, Forsyth, Franklin, Granville, Halifax, Mecklenburg, Orange, Rockingham, Person, Rowan, Stanly, Stokes, Union, Vance and Warren counties. Alliance Health currently serves Cumberland, Durham, Johnston, and Wake counties. North Carolina General Statutes and the North Carolina Administrative Code authorize and prescribe the process through which a County may seek permission to disengage from one LME-MCO and realign with another. The final decision making authority rests with the Secretary of the Department of Health and Human Services. The applicable administrative code is attached as Attachment 1. The first step in initiating disengagement is providing written notice of the County’s intent to disengage to the Secretary of Health and Human Services, the Co-Chairs of the Joint Legislative Oversight Committee on Health and Human Services, and the affected counties a minimum of nine months prior to the proposed effective date of disengagement. This abstract would authorize the County Manager to send the disengagement notice letter and begin the formal disengagement process. 1 Once the disengagement notice is sent, the County is required to create a plan for disengagement. This plan must be approved by the Board of Commissioners and must be made available for public comment for a minimum of 60 calendar days. During the comment period, the County is required to solicit comments from consumers, advocates, self- advocates, and State and Local Consumer and Family Advisory Committees. These public comments must be posted for a minimum of 30 calendar days. The Board of Commissioners must also approve a written plan to ensure continuity of services during the transition and a plan which provides for distribution of real property if applicable. In April of 2019, the Board of Commissioners approved a letter to the North Carolina Association of County Commissioners expressing its preference to become part of a Tailored Plan region that included Durham and Wake County. The Tailored Plan letter is attached as Attachment 2. While that action did not initiate the formal disengagement process, the same justifications for realigning with other counties in the Triangle Region are applicable. This prior action was also similar in terms of timing. The County was asked to express its preference for Tailored Plan regions prior to the implementation of Medicaid Transformation. At that time, Medicaid Transformation was scheduled to be implemented in February 2020. Implementation has since been delayed until July 2021. FINANCIAL IMPACT: No financial impact is associated with authorizing the County Manager to initiate the LME-MCO disengagement process. SOCIAL JUSTICE IMPACT: • FOSTER A COMMUNITY CULTURE THAT REJECTS OPPRESSION AND INEQUITY The fair treatment and meaningful involvement of all people regardless of race or color; religious or philosophical beliefs; sex, gender or sexual orientation; national origin or ethnic background; age; military service; disability; and familial, residential or economic status. • ENSURE ECONOMIC SELF-SUFFICIENCY The creation and preservation of infrastructure, policies, programs and funding necessary for residents to provide shelter, food, clothing and medical care for themselves and their dependents. RECOMMENDATION(S): The Manager recommends the Board consider authorizing the County Manager to initiate the formal disengagement process from the County’s current Local Management Entity-Managed Care Organization, Cardinal Innovations Healthcare, and to seek realignment with Alliance Health to administer mental and behavioral health services for Orange County residents. 2 County Disengagement Rules Page 1 of 2 SECTION .0700 – COUNTY DISENGAGEMENT FROM A LOCAL MANAGEMENT ENTITY- MANAGED CARE ORGANIZATION 10A NCAC 26C .0701 SCOPE A county seeking to disengage from a Local Management Entity-Managed Care Organization (LME-MCO) and align with another LME-MCO operating under a Medicaid waiver shall first obtain the approval of the Secretary of the Department of Health and Human Services (DHHS) in accordance with the rules of this Section. History Note: Authority G.S. 122C-115; Eff. February 1, 2017. 10A NCAC 26C .0702 COUNTY REQUEST TO DISENGAGE FROM A LOCAL MANAGEMENT ENTITY-MANAGED CARE ORGANIZATION (a) A county seeking to disengage from an LME-MCO shall provide written notice of its intent to disengage from an LME-MCO to the Secretary, the Co-Chairs of the Joint Legislative Oversight Committee on Health and Human Services, and affected counties a minimum of nine months prior to the proposed effective date of disengagement. (b) A county seeking to disengage from an LME-MCO shall publish its plan for disengagement on its website, and the website of the LME-MCO with which it seeks to align. (c) The county seeking to disengage from an LME-MCO shall accept public comments on its disengagement plan for a minimum of 60 calendar days. The county shall solicit comments from consumers, advocates, self-advocates, and State and Local Consumer and Family Advisory Committees (CFACs) using locally established communication methods, such as mailings, routine stakeholder meetings, press releases, and social media messages, and shall post the public comments on its website for a minimum of 30 calendar days. (d) A county seeking to disengage from an LME-MCO and realign with a different LME-MCO operating a Medicaid waiver shall provide written documentation of the following to the Secretary, which shall constitute its written request to disengage: (1) Approval of its disengagement plan by its Board of County Commissioners which reflects the date of the approval and that the approval was by majority vote; (2) A written plan, approved by its Board of County Commissioners, to ensure continuity of services during the transition which includes written notice to the provider agencies with which the LME- MCO contracts; (3) A written plan, approved by its Board of County Commissioners, which provides for distribution of real property, where appropriate, and reflects title to the same; (4) Approval of the Area Board, by majority vote, of the LME-MCO with which it is seeking to realign; (5) Evidence of written notice to the other counties who are also members of the LME-MCO from which the county is seeking disengagement; (6) Evidence of its written notice to the providers impacted by its decision to disengage; (7) Evidence of its compliance with the population requirements of G.S. 122C-115(a); (8) Evidence of its financial liabilities to the LME-MCO from which it is seeking to disengage within 30 calendar days of the request to disengage; and (9) Documentation of its compliance with Paragraphs (a) through (c) of this Rule. History Note: Authority G.S. 122C-115; Eff. February 1, 2017. 10A NCAC 26C .0703 SECRETARY RESPONSE TO COUNTY REQUESTS TO DISENGAGE FROM A LOCAL MANAGEMENT ENTITY-MANAGED CARE ORGANIZATION (a) Upon written request by a county seeking to disengage from an LME-MCO, the Secretary may waive the nine month requirement set forth in Rule .0702(a) of this Section upon consideration of the following factors: (1) the impact of delay upon consumers currently served in the county seeking to disengage; (2) the financial vulnerability of the LME-MCO from which disengagement is sought; and (3) any substantiated evidence of criminal activity or malfeasance on the part of the LME-MCO from which disengagement is sought. (b) The Secretary shall consider the following in deciding whether to approve a county request to disengage from an LME-MCO and realign with a different LME-MCO operating under a Medicaid waiver: 3 County Disengagement Rules Page 2 of 2 (1) the impact to and public comments received from consumers, advocates, self-advocates, and State and Local CFACs within the county in response to Rule .0702(c) of this Section; (2) the county's plan for disengagement from one LME-MCO and realignment with a different LME- MCO; (3) the county's plan to ensure continuity of services during the disengagement and realignment phase; (4) whether the county has complied with the requirements of Rule .0702 of this Section; (5) whether the county is contiguous to the catchment area of the LME-MCO with which it is requesting to align; (6) the timing of the request and whether the disengagement will conflict with setting capitation rates; (7) whether the disengagement will impact the financial viability of the LME-MCO from which the county is seeking to disengage; (8) whether the disengagement and realignment will ensure compliance with the population requirements of G.S. 122C-115(a); (9) whether the disengagement and realignment will impact the stability, as a whole, of the State's healthcare system; (10) how the disengagement and realignment will affect the quality, variety, and amount of services for the clients, as defined in G.S. 122C-3, in the subject county; and (11) the operational alignment of the county within the context of the LME-MCO disengagement related to geography, service delivery, and demonstrated provision of whole-person centered care. (c) The Secretary shall issue a written decision to approve or deny the request for disengagement and realignment within 90 calendar days of receipt. (d) The Secretary may approve the request as submitted or set conditions upon its issuance based upon consideration of the factors set forth in Paragraph (b) this Rule. (e) The Secretary shall notify the following of the decision to approve or deny a county request for disengagement and realignment: (1) The Board of County Commissioners of the county seeking to disengage; (2) The Boards of County Commissioners of the counties of the LME-MCO with which realignment is requested; (3) The LME-MCO from which disengagement is sought; (4) The LME-MCO with which realignment is requested; and (5) The Co-Chairs of the Joint Legislative Oversight Committee on Health and Human Services. History Note: Authority G.S. 122C-115; Eff. February 1, 2017. 4 www.orangecountync.gov Orange County, North Carolina (919) 245-2130 Orange County Board of Commissioners Post Office Box 8181 200 South Cameron Street Hillsborough, North Carolina 27278 May 3, 2019 TO: Commissioners Beale and Graham Co-Chairs of Tailored Plan Region Development Committee FROM: Orange County Board of Commissioners RE: Preference for Tailored Plan Region Thank you for the opportunity to provide input into the Phase II of Medicaid Transformation and the process to recommend the composition of regions for Tailored Plans. The Board of Orange County Commissioners has considered its preference for a Tailored Plan region, and we believe the most effective system would connect Orange County with the other counties in the Research Triangle, namely Durham and Wake Counties. From a service perspective, Orange County shares a regional transportation system, a regional workforce, and a network of providers with Durham and Wake Counties. Orange County conducted a study of the provider network available to residents with behavioral health needs, and many providers used by Orange County residents are located in Durham County. Other non-profit providers also serve residents from Orange, Durham, and Wake Counties. A good example of that is CASA which operates in Durham, Wake and Orange counties to provide housing for people with mental illness. Their operations and client access would be more efficient if Orange County were grouped with Durham and Wake counties. In the interest of the residents we serve, the Board of Orange County Commissioners is requesting to become a part of a Tailored Plan region that includes Durham and Wake Counties. Connecting these counties would provide greater access, more varied services, and better public transportation opportunities than any other alignment. Thank you again for this opportunity to provide input into the Tailored Plan regions. If we can provide any additional information, please contact our County Manager’s Office at 919-245-2300. Best regards, Penny Rich, Chair Orange County Board of Commissioners Penny Rich, Chair Renee Price, Vice Chair Jamezetta Bedford Mark Dorosin Sally Greene Mark Marcoplos Earl McKee 5