Report 2023-115 Recommendations

To better ensure appropriate and effective monitoring of timely access to behavioral health care for children, by November 2024 DHCS should make changes to its survey methodologies to do the following, and then implement those changes for the subsequent reporting period: Use its timely access surveys to monitor compliance with the 48 hour urgent appointment standard established in state law where applicable.

To better ensure appropriate and effective monitoring of timely access to behavioral health care for children, by November 2024 DHCS should make changes to its survey methodologies to do the following, and then implement those changes for the subsequent reporting period: Disclose the proportion of providers excluded from its survey results for each plan, the reasons for excluding those providers, and how such exclusions may affect the survey's conclusions about access to care.

To better ensure appropriate and effective monitoring of timely access to behavioral health care for children, by November 2024 DHCS should make changes to its survey methodologies to do the following, and then implement those changes for the subsequent reporting period: Use its timely access surveys to monitor compliance with the timely appointment standards for both new and existing patients.

To assess opportunities to help ensure unbiased timely access survey data, by November 2024, DHCS should determine the feasibility, costs, and likely benefits of adopting a "secret shopper" approach to its timely access surveys. If the department determines that adopting such an approach is reasonably feasible and beneficial, it should implement this methodology by the next reporting year.

To improve its ability to use timely access surveys as a tool to improve access to behavioral health services, by November 2024, DHCS should develop a compliance threshold for the percentage of appointments in each Medi-Cal managed care plan meeting timely access standards. For example, DHCS might consider how many calls a member should have to make before obtaining a timely appointment and calculate a threshold accordingly.

To help determine whether timely access to mental health services for children is improving, by November 2024, DHCS should report in each year's timely access survey results on the extent to which those results are comparable to previous years' results and, where data is comparable, discuss the extent to which timely access to care is improving or declining.

To improve Medi-Cal members' access to behavioral health services from county mental health plans and Drug Medi-Cal programs, by November 2024, DHCS should demonstrate that it has followed up with county mental health plans and Drug Medi-Cal programs on CAPs that continue to be deficient in timely access or other network adequacy standards. In doing so, it should assess whether the plans took the actions described in their CAPs and, if so, why those actions did not result in sufficient improvement.

To ensure that children in Medi-Cal have timely access to behavioral health services from county mental health plans and Drug Medi-Cal programs, by November 2024, DHCS should analyze county mental health plans' and Drug Medi-Cal programs' appointment data according to age group to determine if each county meets the compliance threshold for timely access for both adults and children. To the extent a plan does not meet timely access standards for either group, DHCS should require corrective action.

To ensure that Medi-Cal managed care plans have a sufficient number of providers to offer timely access and meet children's behavioral health care needs, by May 2024, DHCS should develop a new methodology for calculating non-specialty outpatient behavioral health provider-to-member ratios. At minimum, the methodology should consider the following factors:
-The expected demand for behavioral health services by children in Medi-Cal, based on factors including but not limited to past services.
-The estimated number of children likely to need those services.
-The number of full-time providers needed to provide that volume of services.
-The amount of time individual providers spend treating Medi-Cal members.
The methodology should also accommodate potential growth in the need for behavioral health services.

When determining the number of mental health providers a managed care plan has available to serve children in Medi-Cal, DHCS should consider whether providers serve multiple plans or multiple regions within a single plan. When providers do so, DHCS should account for that overlap, such as by reducing the expected contribution of a provider to a given plan when that provider serves multiple plans or regions within a plan.

To ensure that Medi-Cal managed care plan members do not have to travel unreasonable times or distances to receive care, DHCS should develop a definition of what times and distances are reasonable for members to travel. In doing so, DHCS should consider both the total time or distance a member needs to travel, as well as how those times and distances compare to other plans' times and distances for the same provider type and ZIP code. Thereafter, when DHCS determines that plans' requests for alternative time and distance standards are not reasonable, it should not approve those alternative access standards, thereby requiring those plans to offer members out-of-network access until such time as the plans can provide reasonable travel times and distances to care.

To ensure that Medi-Cal managed care plans make efforts to obtain additional providers to meet network adequacy standards, by May 2024, DHCS should revise its agreements with plans that do not meet time and distance standards to require them to demonstrate efforts to recruit new providers to underserved areas.

To more effectively encourage plans to comply with network adequacy standards, by May 2024, DHCS should develop and implement a policy outlining when noncompliance with network adequacy standards by a Medi-Cal managed care plan, county mental health plan, or county Drug Medi-Cal program justifies financial penalties.

To better ensure appropriate and effective monitoring of timely access to behavioral health care for children, by November 2024 Managed Health Care should make changes to its survey methodologies to do the following, and then implement those changes for the subsequent reporting period: Use its timely access surveys to monitor compliance with the 48 hour urgent appointment standard established in state law where applicable.

To better ensure appropriate and effective monitoring of timely access to behavioral health care for children, by November 2024 Managed Health Care should make changes to its survey methodologies to do the following, and then implement those changes for the subsequent reporting period: Disclose the proportion of providers excluded from its survey results for each plan, the reasons for excluding those providers, and how such exclusions may affect the survey's conclusions about access to care.

To better ensure appropriate and effective monitoring of timely access to behavioral health care for children, by November 2024 Managed Health Care should make changes to its survey methodologies to do the following, and then implement those changes for the subsequent reporting period: Use its timely access surveys to monitor compliance with the timely appointment standards for both new and existing patients.

To assess opportunities to help ensure unbiased timely access survey data, by November 2024, Managed Health Care should determine the feasibility, costs, and likely benefits of adopting a "secret shopper" approach to its timely access surveys. If the department determines that adopting such an approach is reasonably feasible and beneficial, it should implement this methodology by the next reporting year.

To identify and address timely access issues that affect children, by November 2024, Managed Health Care should update its survey methodology to assess compliance with timely access standards specifically for behavioral health care providers serving children.