It’s been almost two years since the state agreed to the Terms and Conditions with the Centers for Medicare & Medicaid Services (CMS) for the 1115 Waiver, which allows $1.2B to be earned over a five year period for the state to transform the Medicaid delivery system. That set in motion foundational planning efforts by BHT. First we undertook some governance work and created our Technical Councils to ensure that the Board had enough provider and community feedback coming to them to inform decisions.
The first opportunity to earn funds came in 2017 via Phase 1 and Phase 2 certification, where we had to demonstrate active engagement across both traditional and non-traditional Medicaid providers, in addition to developing a robust set of communication and feedback mechanisms for the region. We were successful in meeting all of the HCA’s criteria, earning the region $6M. Then, at the end of 2017, BHT submitted our Transformation Plan for the region—which outlined the Collaborative structure—and earned an additional $11.3M.
As we move forward with Medicaid Transformation, BHT must meet specific Pay-for-Reporting milestones set by the HCA to continue to earn the 1115 Waiver funds for our region. Once BHT has earned these dollars, they are allocated into different pots by the BHT Board and earned by Partnering Providers as they meet requirements.
2018 (Transformation Year 2) Reporting
This summer, we submitted our first Semi-Annual Report (SAR) to the HCA for the reporting period of January 1-June 30, 2018. In the SAR, we gave an update to the HCA on any completed activities or changes we’ve made to meet the milestones laid out in our Project Portfolio, as well as narrative updates specific to Domain 1 activities, Integrated Managed Care (IMC), and Health Equity. BHT will complete this process twice a year for the rest of the Transformation period, each time earning a portion of Waiver dollars for meeting Pay-for-Reporting requirements. On October 1, we received notification that we had received a 100% on our report, earning the region $8.9M! You can read the SAR here.
More recently, BHT submitted the Regional Implementation Plan to the HCA. This regional Plan is a compilation of the six county-based Collaborative Transformation Plans, in addition to being informed by the individual behavioral health and primary care Partnering Provider Transformation Plans. This document included very specific milestones which will drive our earnings for Pay-for-Reporting metrics in Transformation Years 3-5. If we are 100% successful with our submission, we will earn the region another $8.9M. You can read the Implementation Plan narrative here and the workbook here.
By late spring, BHT received MOUs from 80 organizations, spanning a wide range of settings, to create our six county-based Community Health Transformation Collaboratives. The Collaboratives continue to work to develop Plans to support locally identified priorities and Medicaid Transformation, including integration with approved primary care and behavioral health Partnering Provider Transformation Plans. It is expected that each Collaborative will focus on further development of county-based plans for community-based care coordination.
This summer, Partnering Providers from the behavioral health and primary care settings created individual Partnering Provider Transformation Plans. The individual Plans specify the changes each Partnering Provider intends to make to their clinical delivery system; detailing their strategies/activities, goals, timeline, and budget for activities within the project areas of bi-directional integration, chronic disease, and opioids.
BHT received 55 Partnering Provider Transformation Plans from 44 unique organizations, totaling roughly 4,000 pages of content. In addition to a clinical and organizational review by Health Management Associates, the BHT staff and volunteers from Technical Councils also provided feedback. Plans were reviewed to determine readiness to contract in Q1 2019 or Q3 2019.
Based on readiness categories, Partnering Providers are divided into two Learning Cohorts, January and August. This structure supports BHT’s intent to meaningfully transform the Medicaid Delivery system, while recognizing the current capacity of all of our providers.
Members of the January Cohort are Partnering Providers whose Transformation Plans were close enough to being ready that, with some refinement, their Plans would be ready to contract with BHT by Q1 2019 and begin Implementation.
Members of the August Cohort are Partnering Providers whose Transformation Plans need more development and increases to their foundational capacity. Partners will receive monthly technical assistance in 2019 to support them in their Plan development, and be ready to contract with BHT in Q3 2019.
Over the next two months, BHT will conduct one-on-one feedback sessions with each of the 45 organizations that submitted a Partnering Provider Transformation Plan. In this session we will provide specific feedback for what is needed in Plans to reach a level of readiness to contract with BHT for implementing program elements in the Toolkit and meeting 1115 Waiver requirements.
2019 (Transformation Year 3) Funds Flow
BHT will approve 2019 Funds Flow in November 2018. It is expected that Partnering Providers will be eligible for payments based on achievement of Transformation Plan milestones (Pay-for-Reporting) and Pay-for-Performance incentive measures. The Waiver Finance Work group will recommend the approach to the BHT Board for a vote in November.