The Mississippi Division of Medicaid will hold a public hearing on Mississippi Administrative Code Title 23, Part 223, Rules 1.3, 1.5, 1.8, 2.5, and 6.1-6.6. This code section involves the proposed policy to change the way the wraparound care coordination and services in Mississippi Youth Programs Around the Clock (MYPAC) are paid for. The policy eliminates the MYPAC program but proposes to deliver the same services and supports through a targeted case-management model.
The public hearing is at 10 a.m. on Friday, June 11, 2021, via teleconference. Teleconference number 888-822-7517, Access Code: 4282244. There will be an opportunity for public comment at the hearing. Anyone can attend the hearing. You can see who requested this hearing and read written comments from some of those individuals here. Some of the comments reference the history of MYPAC. To provide additional context and background, this is family feedback about what families wanted MYPAC to include. It was gathered in focus groups conducted by Families as Allies in 2005 and 2006.
Under the new policy, rather than being reimbursed a bundled rate for each day a child and family receive MYPAC services ($347.74 per day for up to 115 days per year), providers will be reimbursed for a targeted case-management fee to provide wraparound care coordination. Then the individual medically necessary services that are currently provided through the MYPAC bundled rate will be purchased separately, as part of the care coordination process. This change is proposed due to a provider payment freeze to Medicaid rates mandated by the state legislature and potential changes the federal Center for Medical Services may require in the way the Mississippi Division of Medicaid currently pays for MYPAC services. The proposed payment structure appears to be more consistent with that of other states.
One challenge with the current bundled rate is that providers may be incentivized to provide all of the services themselves rather than using any of the bundled payment to purchase services from outside of their organizations. If this is happening, it takes away from family voice and choice, one of the ten key principles of wraparound. Switching to a targeted case-management model would likely be one way to lessen this possible conflict of interest.
Targeted case management is currently used by the Mississippi Division of Medicaid for beneficiaries in these groups: very young children, people with intellectual disabilities and adults with serious mental illnesses. The Division’s definition of targeted case management for people with intellectual disabilities includes freedom of choice (page 535 of the Medicaid Administrative Code):
“The state assures that the provision of Targeted Case Management services to the target group will not restrict an individual’s freedom of choice of providers in violation of Section 1902(a)(23) of the Act.
1. Targeted Case Management services will be available at the option of the beneficiary.
2. A beneficiary who wishes to receive Targeted Case Management services will have freedom of choice to receive Targeted Case Management services from any qualified provider of these services.
3. Beneficiaries will have freedom of choice of the qualified Medicaid providers of other medical care as covered elsewhere in this Plan.”
This definition of freedom of choice appears consistent with family voice and choice in choosing who provides their care coordination (wraparound is a type of care coordination) and who provides their services, but only if the associated administrative processes (for example, prior authorization for services and determining medical necessity) are set up in such a way as to not be impediments to either the wraparound process or choice. It would also be important that the targeted case-management reimbursement is high enough to cover the intensity of support required by wraparound.
If you are a family member considering giving comments about wraparound, we encourage you to think about if you and your family have had freedom of choice in the current model of MYPAC. Were you given a choice about what organization provided the wraparound support and who provided the services? Were you included in the plan and did you help pick who you wanted on your team, including friends and family? Were services and supports delivered in the way and place and at the time you wanted them?
Your feedback, whether it is positive, negative or somewhere in between, will help the Division of Medicaid know how to make any changes in a way that makes sure families get to help choose their wraparound providers, their teams, the people who provide services and the ways in which services and supports are delivered.
Written comments prior to the hearing 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 June 4. Public comments will be published and available for review. If you do not want your name published with your comments, request that your comments be published anonymously when you send your comments in.
Additional background on this proposed policy:
This recently released national study compares outcomes for wraparound delivered through Care Management Entities and Community Mental Health Centers. Care Management Entities provide just wraparound facilitation and purchase services from other groups and providers. In this study, Care Management Entities were found to produce better wraparound outcomes. That does not mean that Care Management Entities always produce better outcomes. There is one Care Management Entity in Mississippi, Choices Coordinated Care Solutions. The other wraparound providers in the state are designated as community mental health centers.*
Ensuring that wraparound is provided the way it is supposed to be and that there are no conflicts of interest between wraparound facilitation and the provision of services requires well-planned external monitoring. In Mississippi, wraparound facilitation, but not MYPAC, is certified and monitored by the Department of Mental Health (see pages 277 and 278 of the Department’s Operational Standards). The Mississippi Wraparound Institute (MWI) coaches, trains and supports wraparound providers in collaboration with the Department of Mental Health.
Families as Allies recently conducted a webinar, What Is a System of Care and What Does Wraparound Mean?, for the Mississippi Parent Training and Information Center if you would like to review the recording and slides to learn more about Wraparound and this policy.