Report 2018-122 Recommendation 15 Responses

Report 2018-122: Department of Health Care Services: It Has Not Ensured That Medi-Cal Beneficiaries in Some Rural Counties Have Reasonable Access to Care (Release Date: August 2019)

Recommendation #15 To: Health Care Services, Department of

To ensure that beneficiaries in the Regional Model counties have reasonable access to care, DHCS should provide these counties by June 2020 with reasonable opportunities to decide whether to change their managed care models after the expiration of the Regional Model health plan contracts. DHCS should provide counties that choose to do so sufficient time to establish their new models. DHCS should also include language in its 2020 RFP to allow Regional Model counties that can demonstrate their ability to implement a COHS Model in their county by 2023 to opt out of the RFP process.

Annual Follow-Up Agency Response From October 2021

Based on activities that DHCS has engaged in during 2020-2021, we have updated our response to Recommendation 15 to now show as Fully Implemented. Since the previous annual response was provided, DHCS has engaged in multiple discussions with various counties who have requested technical assistance related to changing their Plan model type, In addition, DHCS has engaged with Centers for Medicare and Medicaid Services (CMS) related to opportunities and steps for DHCS to take if counties request to change the Plan Model type in their county, and in February 2021, DHCS released Letter of Intent Instructions to the County Health Executives Association of California to communicate an opportunity for potential County Plan Model changes. The Letter of Intent Instructions provided counties with instructions on how to submit information to the DHCS by April 30th, 2021 in order to possibly change the MCP model type that operates in their county. The requested change, if approved by the DHCS, would take effect January 1, 2024 giving the counties sufficient time to establish their new models.

DHCS also included language in the DRAFT RFP that was released June 1, 2021, indicating potential County Plan Model changes that would occur effective January 1, 2024. The Final RFP will only include those counties that are part of the RFP process.

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

Annual Follow-Up Agency Response From November 2020

DHCS will provide all counties with reasonable opportunities to decide whether to change managed care models and intends to reach out to counties regarding important decision points related to the RFP timeline. Over the last year, DHCS has participated in discussions with various counties who have requested technical assistance related to changing their Plan model type. In addition, DHCS has engaged with Centers for Medicare and Medicaid Services (CMS) to determine the definition and parameters around the federal statute that identifies a 16% threshold for County Organized Health Plans. Lastly, DHCS has provided extensive technical assistance to the Legislature around Senate Bill (SB) 1029, which is a bill that seeks to provide Sacramento County the authority to establish a public health authority that will be allowed to put forward Plan recommendations as part of the RFP process.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

1-Year Agency Response

DHCS will provide all counties with reasonable opportunities to decide whether to change managed care models and intends to reach out to counties regarding important decision points related to the RFP timeline. Over the last year, DHCS has participated in discussions with various counties who have requested technical assistance related to changing their Plan model type. In addition, DHCS has engaged with Centers for Medicare and Medicaid Services (CMS) to determine the definition and parameters around the federal statute that identifies a 16% threshold for County Organized Health Plans. Lastly, DHCS has provided extensive technical assistance to the Legislature around Senate Bill (SB) 1029, which is a bill that seeks to provide Sacramento County the authority to establish a public health authority that will be allowed to put forward Plan recommendations as part of the RFP process.

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

Although DHCS indicates that it will not implement our recommendation, its response describes activity that partially addresses the recommendation. However, DHCS did not provide documentation to substantiate its efforts. Accordingly, we evaluated the implementation status of this recommendation as pending.

6-Month Agency Response

DHCS continues to disagree with this recommendation. DHCS will not be including a provision in its RFP regarding the allowance for a county or plan to change the model type operating in their county because the RFP is specific to the model type. We would expect that counties and plans interested in switching to another managed care model in any of the RFP counties to make DHCS aware between now and/or during the RFP process. It is not reasonable to include language in the actual RFP considering that the legislative process to change the plan model type in a county is lengthy and requires possible statutory changes. With that said, the DHCS would need to know prior to the RFP being posted if a county or plan is interested in changing the plan model type operating in that county. Once DHCS is made aware of such request, DHCS will work with the necessary parties on next steps.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

We disagree with DHCS' response that it is not reasonable to include language in its RFP to allow counties to opt out of the RFP process if they can demonstrate their ability to implement a COHS model in their county by 2023. In particular, we are concerned that DHCS' approach will preclude counties that want to create a COHS from doing so. Requiring counties to notify DHCS of their intent prior to DHCS issuing the RFP does not allow the counties sufficient opportunities to decide whether to change their managed care models as we recommended.

60-Day Agency Response

DHCS will not be including a provision in its RFP regarding the allowance for a county or Plan to change the model type operating in their county because that RFP is specific to the model type. We would expect that counties and plans interested in switching to a COHS model in any of the RFP counties to make DHCS between now and/or during the RFP process. Once DHCS is made aware of such request, DHCS will work with the necessary parties on next steps.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

DHCS states that it will work with parties when it is made aware of their desire to switch to a COHS model. However, by implementing our recommendation to include language in the 2020 RFP to allow counties to opt out of the Regional Model if they can demonstrate their ability to implement a COHS Model, DHCS would demonstrate its commitment to helping small and rural counties improve the access to care for their beneficiaries.

All Recommendations in 2018-122

Agency responses received are posted verbatim.