Expansion of Services for Transition Age Youth
In October 2018, the MPS and several other mental health advocacy groups, signed onto the Children’s Behavioral Health Coalition’s letter to Governor Hogan asking for the expansion of services for transition age youth (TAY). TAYs are individuals between the ages of 18-26 who mature into the adult system but may need to continue within the rehabilitative framework of a children’s behavioral health model. TAY-specific programs prepare them for independent living by providing supervised housing and wraparound services, including medication management, counseling, coordination of services, and training in life skills. However, unless TAY meet limited, adult-oriented diagnostic criteria, they are ineligible for these programs.
The letter stated that an increase in funding focused on the needs of this population would do much to address a major component of the 2017 Maryland Children’s Cabinet Three-Year Plan – reducing youth homelessness – which is recognized in the plan as a “historically unfunded or underfunded” population. The plan calls for targeting “vulnerable homeless youth who are not in the physical custody of a parent or guardian and who are under the age of 25,” and clearly states that these “unaccompanied homeless youth have unique needs that cannot be addressed by the same housing and supportive services offered to adults.”
The Coalition urges an expansion of the diagnostic criteria and an increase in funding targeted specifically to TAY to ensure these young adults with behavioral health needs have access to the services necessary to facilitate an early intervention and recovery.
Strategy to Improve Behavioral and Somatic Health Integration in the Maryland Medicaid Program (2017)
Over 100 organizations, including the Maryland Psychiatric Society, signed on to a letter to Secretary Schrader outlining a strategy to improve behavioral and somatic health integration in the Maryland Medicaid Program. The Maryland Behavioral Health Coalition recommendations are intended to help the Maryland Department of Health prepare reports on integration to be submitted to CMS and the Maryland General Assembly. Following are highlights of the coalition’s suggestions. Click here to view the complete letter.
- Enhance the Medicaid Chronic Health Home Program.
- Implement Comprehensive Primary Care Model for People Dually Eligible for Medicare/Medicaid.
- Require Primary Care Providers and Managed Care Organizations (MCO) to Implement Collaborative Care Practice Protocols for Individuals with Mild to Moderate Behavioral Health Conditions.
Strategies to Improve the Sharing of Health Information
- Implement Strategy for Using Health Information Exchange (HIE) to Share Both Behavioral and Somatic Health Data.
- Require MCOs to Provide Relevant Somatic Health Data to the Administrative Services Organization (ASO) and Implement Performance-based Standards for MCOs to Share this Clinical Data.
- Address MCO Concerns about Behavioral Health Data.
Additional Strategies to Improve Integration
- Implement Shared-savings and/or Performance-Based Payments for Providers of Behavioral Health and Somatic Health Services that Further Incentivize Clinical Integration.
- Implement Incentives for Providers to Co-locate Primary Care Services in Behavioral Health Facilities.
Comments on Telehealth Services Regs
On August 7, 2017 the MPS submitted comments [telehealth svcs regs comments] to the Maryland Department of Health (MDH) on the proposed amendments to 10.09.49 Telehealth Services regulations. The changes would expand Medicaid coverage of mental health and substance use disorder treatment delivered remotely via telehealth services. Although we support most of the proposed changes, the MPS expressed concern about the reference to clinical appropriateness and requested that the proposed language in .05.A(3) “Clinically appropriate to be delivered via telehealth;” be removed. The rationale is that the proposed language already addresses the standard of care (.05.B) and licensing board standards (.05.D). Furthermore, retaining the language in A(3) would add confusion. What is and is not “clinically appropriate” is not spelled out, and does not lend itself to definition through regulation. The requirement would predispose coverage decisions to unnecessary debate and could be used to arbitrarily exclude some services from coverage, which could lead to adverse consequences for patients.The MPS reached out to three other organizations whose members would be affected by this regulatory change, asking for support of our position. The Maryland-DC Society of Addiction Medicine and the Maryland Psychological Association both sent letters to MDH echoing these concerns.