Report 2018-111 Recommendation 16 Responses

Report 2018-111: Department of Health Care Services: Millions of Children in Medi-Cal Are Not Receiving Preventive Health Services (Release Date: March 2019)

Recommendation #16 To: Health Care Services, Department of

To help increase utilization rates, DHCS should begin by September 2019 to monitor and identify effective incentive programs at the plan level and share the results with all plans.

Annual Follow-Up Agency Response From September 2022

There is no agency response for this update. Government Code section 8546.1(d) authorizes the California State Auditor to conduct follow-up audit work on statutorily mandated or legislatively required financial and performance audits. Our office followed up on this March 2019 audit to assess DHCS's status regarding implementation of the eight outstanding recommendations from this report. Below is our assessment of the status of this recommendation based on work we performed during the follow-up audit. All future updates for this recommendation will be posted under the follow-up audit (2022-502).

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

DHCS shared some incentive program information with health plans. However, the information it shared lacked sufficient detail about the identified best practices for incentive programs to be useful. DHCS plans to share additional information with the health plans in October 2022 and to launch a new incentive program in 2023.

Annual Follow-Up Agency Response From October 2021

In April 2021, DHCS implemented a Primary Care Incentive Tracking Report with its contracted health plans/managed care organizations (MCOs), focused on members less than 21 years of age. The report solicited information on all provider incentives and other value-based payment (VBP) arrangements MCOs are utilizing to incentivize wellness and preventive care for child and adolescent members and any best practices the MCOs have identified. The report gathered information on HEDIS or other quality metrics used within the payment arrangements or incentives and any member incentives the MCOs have implemented, such as gift cards or other rewards that members earn when they access wellness or preventative care services.

The MCO submissions demonstrated an array of VBP approaches in use from 2018-2019 designed to improve wellness and preventive care with the majority being pay-for-performance type incentives. There was at least one VBP model in place during the reporting period in all 58 California counties. More than half of MCOs reported using child and adolescent wellness and preventive care measures from the Eternal MCAS of quality measures, now known as the MCAS, in their payment arrangements. Seventeen MCOs reported using member incentives for child and adolescent preventative care.

Moving forward, this report will collect information on primary care incentives annually and information will be shared with Medi-Cal health plans through the quarterly Chief Medical Officer meetings and quarterly quality improvement collaborative meetings to disseminate best practices across plans.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

We will review the Primary Care Incentive tracking report and related policies once DHCS provides them and indicates it has begun sharing the information with all plans.

Annual Follow-Up Agency Response From November 2020

Work efforts were interrupted due to the COVID-19 pandemic and related reprioritization of workload. As such, DHCS was unable to finalize the policy and reporting requirements to share with a Medi-Cal MCP workgroup for feedback. Since the COVID 19 pandemic was declared, DHCS' discussions with the workgroup have focused almost exclusively on COVID-19 pandemic-related impacts. The new implementation date for the recommendation is expected to be April 2021.

For next steps, DHCS still intends to share the high-level policy and reporting requirements with a Medi-Cal MCP workgroup for feedback. In addition, implementing the recommendation will require DHCS establish a new ongoing reporting obligation not currently outlined in DHCS' contracts with the plans. Therefore, in order to formally require plans to comply with the new reporting obligation, DHCS will be implementing the recommendation via APL guidance. DHCS will develop, finalize, and release the APL required to implement the recommendation following receipt of the MCP workgroup's feedback.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

1-Year Agency Response

Work efforts to implement this recommendation commenced in late 2019 and are currently ongoing. To date, DHCS has drafted the internal policy and project plan that will guide work activities necessary for implementing this recommendation and once finalized, DHCS anticipates sharing the high-level policy and reporting requirements with a Medi-Cal MCP workgroup for technical feedback and suggestions.

Implementing this recommendation will require DHCS establish a new ongoing reporting obligation not currently outlined in DHCS' contracts with the plans. Therefore, in order to formally require plans to comply with this new reporting obligation, DHCS will be implementing this recommendation via APL guidance. DHCS will develop, finalize, and release the APL required to implement this recommendation following receipt of the plan workgroup's technical feedback.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

DHCS anticipates efforts in the summer of 2019 to establish a go forward practice to collect and share plan-identified effective incentive programs that are reported to DHCS as contractually required. At the time of the 60-day response, the estimated implementation of September 30, 2019, was indicated assuming work efforts would commence in early summer. Due to significant workload in June and July related to meeting federal rate and claiming-related deadlines, work efforts have been slightly delayed to October 31, 2019.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

DHCS anticipates efforts in the Summer of 2019 to establish a go forward practice to collect and share plan-identified effective incentive programs that are reported to DHCS as contractually required.

California State Auditor's Assessment of 60-Day Status: Pending

We look forward to reviewing DHCS' progress in implementing this recommendation in its 6-month response.

All Recommendations in 2018-111

Agency responses received are posted verbatim.