State reforms create aggressive deadline from DHCS to comply with CMS standards

Over the last decade, the Medi-Cal program has significantly expanded, due in large part to changes born out of the Affordable Care Act and federal and State statutes, regulations, politics, and policy agendas. DHCS has dramatically increased enrollment in and the scope of Medi-Cal managed care plans and, if their current blueprint for the future, CalAIM or, as was just announced, Medi-Cal Healthier California for All, comes to fruition, this trend will continue.

Change is here once more:

Under the Bipartisan Budget Act of 2018, states must maintain a State Medicaid Agency Contract (SMAC) by July 6, 2020 for their Medicare Advantage Dual Eligible Special Needs Plans (D-SNPs). Specifically, the SMAC requires Medicare Advantage D-SNPs to comply with more comprehensive models of integrated care coordination for dual eligibles by January 1, 2021.

As part of California’s attempt to comply with the SMAC requirement, DHCS will transition the Cal MediConnect (CMC) and the Coordinated Care Initiative (CCI) to a Medicare Advantage D-SNP and a state-wide Managed Long Term Services and Supports (MLTSS) model.

DHCS’s preliminary plans are to introduce mandatory enrollment for dual eligibles into MLTSS plans and increase the availability of plan choice, enabling consumers to enroll in a D-SNP that is aligned with their MLTSS plan.

An aggressive timeline has been proposed wherein between 2020 and 2023 the State will comply with CMS regulatory standards, phase-out the CMC and CCI programs, integrate long-term care into managed care, and require Medi-Cal Managed Care Plans to operate D-SNPs.

Navigating a changing landscape:

Mazars has several years of experience in guiding and strategizing Medicaid plans across the country in how best to meet these mandates. From contracting and network builds, to financial projections, to compliance and clinical requirements, if it is in the realm of managed care, we have you covered with a broad and deep bench of specialists, some of whom are former regulators and plan staff, along with a cadre of clinicians who have multiple successes in drafting Models of Care.

Should you need assistance in evaluating how your current plan design and membership will be impacted by these regulatory reforms or guidance in launching a Medicare Advantage D-SNP, Mazars is here to provide you with the strategic support in navigating the changing landscape.

Please contact your Mazars professional for additional information.

Published on February 25, 2020

The information provided here is for general guidance only, and does not constitute the provision of tax advice, accounting services, investment advice, legal advice, or professional consulting of any kind. The information provided herein should not be used as a substitute for consultation with professional tax, accounting, legal or other competent advisers.

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