We have been keeping you updated on changes related to Mississippi Youth Programs Around the Clock (MYPAC).
In May of this year, the Division of Medicaid proposed to discontinue Mississippi Youth Programs Around the Clock (MYPAC) in response to a legislative funding freeze and federal feedback on how the Centers for Medicaid Services will reimburse for the service. The proposed policy was open for comments for 25 days and a public hearing was held on June 11. At the time of this writing, the transcript of the hearing was not yet published on Medicaid’s website. We have requested a copy of it or to be notified when it will be posted.
MYPAC was discontinued July 1 and replaced with a broader approach to wraparound with medically necessary services billed separately, as explained in this update from the Mississippi Division of Medicaid. The Division is now proposing to bring back a version of MYPAC. This proposed policy is open for comment through this Friday, July 30.
Sorting through any policy can be confusing. One basic confusion is the difference between wraparound and MYPAC. Sometimes people think that wraparound and MYPAC are the same thing. They are not. Wraparound is a process, not a service, focused on partnering with families to bring together and coordinate services. MYPAC is a program that provides services through a wraparound process.
In order for wraparound to work as well as possible, wraparound facilitators need to be free to help families choose services from wherever works best for them without any pressure for services to be from the same agencies that employ families’ wraparound facilitators. Agencies should have firewalls in place to ensure that this happens, and the State itself should have policies in place to monitor and enforce that these firewalls exist. These approaches are consistent with fidelity monitoring instruments from the National Wraparound Initiative.
One way to keep wraparound separate from services is for it to be delivered through care management entities, agencies that provide only wraparound and no services. The National Wraparound Initiative recently published a study that found that implementation was consistently better when wraparound was administered through Care Management Entities (CMEs) as compared to more traditional Community Mental Health Centers (CMHCs). A follow-up blog describes how CMHCs can structure themselves to function more as CMEs. One problem with the current proposed policy is that it appears to require that agencies providing wraparound also provide mental health services, in contrast to what the research indicates brings about the best outcomes for families and children.
In examining this policy and how to respond, it is helpful to consider the original intention of MYPAC. The application for the waiver to start MYPAC (the writing on this copy is from Tessie Schweitzer, the founder of Families as Allies) describes a program that is part of Mississippi’s system of care, coordinated with Making a Plan teams and is monitored by the Interagency System of Care Council and the Interagency Coordinating Council for Children and Youth. Families and family-run organizations are embedded into all aspects of the project and there is independent monitoring and evaluation of it. Services and supports are individualized to each family and include both traditional and informal approaches. Care coordinators help families obtain services from a variety of places.
Currently, it appears common that families in MYPAC receive their wraparound coordination and all of their services from one place and families are automatically seen three times a week with peer support, care coordination and therapy being the services offered. It is not clear if this approach is consistent with the original intent of MYPAC or the principles of wraparound. Any time a policy is open for comment is an opportunity to think through how things that are currently happening can be improved. We encourage all of you reading this to make the most of this opportunity and share your comments with Medicaid in this regard.
We especially encourage families to submit comments. If your family has participated in MYPAC, please share your comments about what did and did not work for you. Families are the only ones who have that information and it is vital for Medicaid to know what did and did not work for families in deciding if and/or how to move ahead with this proposed policy.
Written comments should be sent to the Division of Medicaid, Office of the Governor, Office of Policy, Walter Sillers Building, Suite 1000, 550 High Street, Jackson, Mississippi 39201, or emailed to Margaret.Wilson@medicaid.ms.gov by this Friday, July 30. All submitted comments will be compiled and available under the appropriate public notice posting.
You do not need a special form to submit comments. You can begin your comments by writing “These are my public comments on MYPAC” and then share your thoughts. You can request that your comments not be published if that is your preference.