policy
ACAP Comments on Proposed IAP Measures
All-cause emergency department utilization rate for Medicaid beneficiaries who may benefit from integrated physical and behavioral health care
Submitted via email to PMHQualMeasures@mathematica-mpr.com
Date: February 13, 2018
Organization: Association for Community Affiliated Plans
1115 15th St NW, Suite 600
Washington, DC 20005
Deborah Kilstein at dkilstein@communityplans.net
Measure: All-cause emergency department utilization rate for Medicaid beneficiaries who may benefit from integrated physical and behavioral health care
Position: Do NOT support
Comment:
The Association for Community Affiliated Plans (ACAP) is pleased to submit comments in response to the proposed measure All-cause emergency department utilization rate for Medicaid beneficiaries who may benefit from integrated physical and behavioral health care. ACAP represents 61 not-for-profit, community-based Safety Net Health Plans located in 29 states. Our member plans provide coverage to 20 million individuals enrolled in Medicaid, Children’s Health Insurance Program (CHIP), and Medicare Advantage Dual Eligible SNPs, and qualified health plans in the individual Marketplace. Nationally, ACAP plans serve almost half of all Medicaid managed care enrollees.
ACAP does not support this measure. Calculating the number ER visits for a behavioral health condition is not an appropriate measure of the successful integration of physical and behavioral health. While the stratification that does look at co-occuring physical and behavioral health conditions and cooccuring mental health and substance abuse conditions does have some relationship to integration, focusing efforts exclusively on ER usage is not an appropriate measure of success.
Thank you for this opportunity to comment.
Follow-up after hospitalization or residential treatment for substance use disorder (SDU-18)
Submitted via email to SUDQualMeasures@mathematica-mpr.com.
Date: February 13, 2018
Organization: Association for Community Affiliated Plans
1115 15th St NW, Suite 600
Washington, DC 20005
Deborah Kilstein at dkilstein@communityplans.net
Measure: Follow-up after hospitalization or residential treatment for substance use disorder (SDU-18)
Position: Do NOT support
Comment:
The Association for Community Affiliated Plans (ACAP) is pleased to submit comments in response to the proposed measure Follow-up after hospitalization or residential treatment for substance use disorder (SDU-18). ACAP represents 61 not-for-profit, community-based Safety Net Health Plans located in 29 states. Our member plans provide coverage to 20 million individuals enrolled in Medicaid, Children’s Health Insurance Program (CHIP), and Medicare Advantage Dual Eligible SNPs, and qualified health plans in the individual Marketplace. Nationally, ACAP plans serve almost half of all Medicaid managed care enrollees.
From a health plan perspective, ACAP does not support the use of this measure. First, we believe there is a great deal of overlap with the existing HEDIS measure, Follow-Up After Hospitalization for Mental Illness (FUH). Therefore, given the need to support efforts to align measures, the addition of this measure is unwarranted and provides little added value. Second, we are concerned that the hospitalization could have been for multiple reasons and follow-up for the SUD should be limited to situations where that is the primacy diagnosis or is somehow indicated as being unresolved.
Thank you for this opportunity to comment.