Report 2018-122 Recommendation 4 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 #4 To: Health Care Services, Department of

To obtain assurance that health plans throughout the State exhaust all of their reasonable options to meet the access requirements before requesting alternative access standards, DHCS should immediately require health plans to report on their attempts to contract with providers when submitting their alternative access standard requests, including providing evidence of their efforts, such as the contact information for each provider with which they have attempted to contract.

1-Year Agency Response

DHCS issued APL 20-003 in February 2020, which supersedes APL 19-002. The policy guidance addressed in the APL include DHCS' AAS validation process wherein DHCS requests evidence of contracting efforts for approved AAS'. DHCS will compare the MCP's justification for the inability to contract with closer providers and review the supporting documentation requested. DHCS may rescind an approved AAS if the MCP cannot provide sufficient evidence of contracting efforts.

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

6-Month Agency Response

DHCS is finalizing stakeholder feedback on the APL 19-002 which will require MCPs to describe their contracting efforts as part of their AAS submission and will instruct MCPs to provide information regarding attempts to outreach to a minimum of two out of network providers when submitting AAS requests. MCPs must include their contracting efforts to support their AAS request, including the date(s) of contact. DHCS will publish the APL by February 2020.

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

60-Day Agency Response

DHCS is currently revising All Plan Letter (APL) 19-002 to require Managed Care Plans (MCP) to describe their contracting efforts as part of their AAS submission. MCPs must include their contracting efforts to support their AAS request, including the date(s) of contact. DHCS will also use a sampling methodology to validate the MCP's AAS request. The AAS validation has already been completed for the July 2019 annual network certification. In addition, APL 19-002 is also being revised to instruct MCPs to provide information regarding attempts to outreach to a minimum of two out-of-network providers when submitting AAS requests.

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

All Recommendations in 2018-122

Agency responses received are posted verbatim.