FISCAL NOTE
Date Requested: January 12, 2022
Time Requested: 05:18 PM |
| Agency: |
Health and Human Resources, WV Department of |
|---|
| CBD Number: |
Version: |
Bill Number: |
Resolution Number: |
| 1287 |
Introduced |
SB247 |
|
|---|
| CBD Subject: |
Health |
|---|
|
FUND(S):
0403 - Human Services General Revenue; 8722 - Human Services Federal Funding; 8793 - Substance Abuse Block Grant; 8794 Mental Health Block Grant; 8723 - Cons Fed Funds Consolidated Medical Services Fund
Sources of Revenue:
Other Fund General & Federal
Legislation creates:
Creates New Program
Fiscal Note Summary
Effect this measure will have on costs and revenues of state government.
The purpose of this bill is to provide that the state Medicaid agency shall develop, seek approval of, and implement a Medicaid state plan amendment as necessary and appropriate to effectuate a system of certified community behavioral health clinics (CCBHCs); provide that the state Medicaid agency, in partnership with the Department of Health and Human Resources’ Bureau for Behavioral Health, shall establish a state certification system for CCBHCs; provide that all nonprofit comprehensive community mental health centers and comprehensive intellectual disability facilities shall be eligible to apply for certification as a CCBHC.
The Department's Bureau for Behavioral Health (BBH) has received and subsequently awarded funding that would tie to the implementation of this bill. Specifically, BBH awarded a grant to Quality Insights to allow for Comprehensive providers to develop the capacity needed to qualify for CCBHC status to include administering Advisory Work Groups; developing and implementing plans for sustainability; technical assistance and trainings. While the available funding does not support the ongoing operational costs like the Federally Funded CCBHC expansion grants, the Department believes that the work currently being done could provide a reasonable base for implementation of this legislation should additional funding be available at a later date.
The Federal Substance Abuse and Mental Health Services Administration (SAMHSA) has provided two previous rounds of grant funding to organizations through Federal Certified Community Behavioral Health Clinic Expansion Grants. Five of West Virginia's Community Behavioral Health Centers were direct recipients of those Federal Grant funds. (FMRS, Prestera, Seneca, Westbrook, Southern Highlands)
At this time, the Bureau for Medical Services cannot calculate the cost increase without the actuarial prospective payment system (PPS) rate, however, it is anticipated that the net change from the current environment where individual services are billed to a "bundled rate" will be minimal. An increase in Behavioral Health spend is anticipated. The concept of CCBHC is that those increased costs would be offset by decreases in emergency costs for behavioral health crisis. If that does not occur the bill could inhibit departments flexibility to make changes to the CCBHC system when needed for budget purposes. Implementation is contingent upon approval of a state plan amendment (SPA) from the Centers for Medicare and Medicaid (CMS).
This legislation potentially could have a positive fiscal impact the Department's Office of Health Facilities and Office of Drug Control Policy (less need for commitments/services) but the Department is unable to determine the impact at this time.
Fiscal Note Detail
| Effect of Proposal |
Fiscal Year |
2022
Increase/Decrease
(use"-") |
2023
Increase/Decrease
(use"-") |
Fiscal Year
(Upon Full
Implementation) |
| 1. Estmated Total Cost |
0 |
1,125,000 |
0 |
| Personal Services |
0 |
1,125,000 |
0 |
| Current Expenses |
0 |
0 |
0 |
| Repairs and Alterations |
0 |
0 |
0 |
| Assets |
0 |
0 |
0 |
| Other |
0 |
0 |
0 |
| 2. Estimated Total Revenues |
0 |
0 |
0 |
Explanation of above estimates (including long-range effect):
As written the bill does not require any financial commitment from the Bureau for Behavioral Health other than administrative costs that would be needed to assist in the establishment of a state certification system for CCBHCs which would fall under the Bureau's current duties. The Bureau did receive $1,125,000 in Federal funding from SAMHSA as part of the two COVID related appropriations for which we intend to use in furtherance of the development of statewide CCBHC's. Additionally, the Bureau is committed to working with our sister agencies and partners to administer and distribute any subsequent funding that may be made available for this purpose.
At this time, the Bureau for Medical Services cannot calculate the cost increase without the actuarial prospective payment system (PPS) rate. However, an increase in Behavioral Health spend is anticipated. The concept of CCBHC is that those increased costs would be offset by decreases in emergency costs for behavioral health crisis. If that does not occur the bill could inhibit departments flexibility to make changes to the CCBHC system when needed for budget purposes. Implementation is contingent upon approval of a state plan amendment (SPA) from the Centers for Medicare and Medicaid (CMS).
Memorandum
Research suggests that improved Behavioral Health Service delivery could help the state achieve positive financial impacts through reductions to commitments, children's services and the criminal justice system; however, it is difficult to provide accurate cost projections. Research continues to evolve based on the results being reported in relation to the Federal Certified Community Behavioral Health Clinic Expansion Grants.
The bill as currently written allows only Comprehensive providers as identified in West Virginia Code §27-2A-1 to be eligible which would allow for statewide availability only if every provider in code seeks to achieve certification. Should any provider in code not seek to obtain certification the overall impacts of the program would be impacted and possibly leave new gaps in the state's system.
In order to implement a CCHC, the Department would need to do the following 1) determine the desired number of CCHBC sites to certify, 2) estimate anticipated increase in number of clients served (if any), 3) estimate clients enrolled in Medicaid (distinguishing between expansion and non-expansion enrollees), 4) crosswalk CCBHC criteria with existing state plan to identify where any gaps exist that affect state expenditures on CCBHCs, 5) estimate the degree to which (if at all) current Medicaid reimbursement falls short of costs that will be included in the PPS, 6) assess whether there are any existing state-funded programs that can be included in the CCBHC scope of services or activities 7) Determine expectations for CCBHCs regarding reduced hospital/ED utilization or other high-cost health care services, Ensure the appropriate activities designed to achieve these outcomes are included within CCBHC criteria; consider quality bonus payments to further incentivize, Determine expectations for CCBHCs regarding collaborations with external partners and the degree to which activities designed to reduce costs by improving care will be built into CCBHC criteria.
Currently community mental health centers are reimbursed through managed care organizations (MCO) or through fee for services (FFS). The CCBHC would require the development of a prospective payment system that accounts for the total cost of providing comprehensive services to all individuals who seek care. There are a couple of different PPS models developed by the U.S. Department of Health and Human Services (HHS) Centers for Medicare & Medicaid Services (CMS). The first model (PPS-1) provides CCHBCs with a fixed daily payment for each day that a Medicaid beneficiary receives services from the clinic (similar to the PPS model used by Federally Qualified Health Centers). The PPS-1 model also includes a state option to provide quality bonus payments (QBP) to CCBHSs that meet state-specified performance requirements on quality measures. The second model (PPS-2) provides CCBHCs with a fixed monthly payment for each month in a Medicaid beneficiary receives services from the clinic. PPS-2 rates have multiple rate categories – a standard rate and separate rates for special populations that are defined by the state. PPS-2 also required states to make QBP’S based on quality measure performance, and outlier payments for costs above and beyond a specific threshold (that is, payment adjustments for extremely costly Medicaid beneficiaries).
Person submitting Fiscal Note: Bill J. Crouch
Email Address: dhhrbudgetoffice@wv.gov