Report 2023-115 Recommendation 8 Responses

Report 2023-115: Department of Health Care Services and Department of Managed Health Care: Children Enrolled in Medi-Cal Face Challenges in Accessing Behavioral Health Care (Release Date: November 2023)

Recommendation #8 To: Managed Health Care, Department of

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.

6-Month Agency Response

On February 8, 2024, the DMHC submitted a memo to CSA setting forth its concerns with the feasibility and limitations of a secret shopper methodology. Based on the considerations set forth in the memo, the DMHC has determined that adopting a secret shopper approach is not reasonably feasible or more beneficial than the current survey approach. Thus, the DMHC will not implement a secret shopper survey methodology at this time.

As previously indicated in the 60 day response, the DMHC may explore other options to address the potential bias concerns if an extension of the APA exemption and additional funding for staffing and statistical services is provided to DMHC to implement and refine these changes in future regulatory amendments to the survey methodology.

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

DMHC provided documentation demonstrating that it considered the feasibility, costs, and likely benefits of adopting a "secret shopper" approach to its timely access surveys. The memo indicates that DMHC did not find that adopting such an approach is reasonably feasible. Thus, it has appropriately implemented our recommendation.

60-Day Agency Response

The DMHC has significant concerns regarding the feasibility and utility of a secret shopper survey. In addition, the DMHC would need consulting funding to conduct an independent evaluation of the feasibility, costs, and benefits of adopting a "secret shopper" survey. A secret shopper survey would not allow for collection of mental health follow-up appointment wait times, because it can only assess appointment wait times for new patients and cannot measure access for existing patients. (Nor would it allow the DMHC to implement Recommendation 3.) Further, it would not allow for meaningful measurement of specialist physicians and ancillary provider appointment wait times, because these providers often require a referral from a physician and/or prior authorization prior to scheduling an appointment. While a secret shopper survey is unlikely to adequately capture these appointment types, all three classes of appointment wait times are required to be measured by H&S section 1367.03, sub. (f)(3). Given these and other concerns, the DMHC may explore other options to address the potential bias concerns.

Based on the DMHC's five years of experience in developing a survey methodology and the complexities involved with a secret shopper survey, it is estimated to take four to five years to successfully develop and implement this recommendation. Thus, the DMHC cannot implement a secret shopper survey prior to the expiration of the APA exemption on December 31, 2025. (H&S section 1367.03, sub. (f)(3).) In addition to an extension of this APA exemption, the DMHC would also need additional staffing and statistical funding to implement this change.

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

Managed Health Care indicates that it will not implement this recommendation.

All Recommendations in 2023-115

Agency responses received are posted verbatim.