Over the past two weeks, we have shared information with you about the Division of Medicaid’s proposed policy change regarding Mississippi Youth Programs Around The Clock (MYPAC). The Division has several other policies out for review and public comment, including its proposed policy changes for community mental health services. Proposed additions to the policy are underlined and deletions have lines through them. We encourage you to look through the proposed changes as well as the existing policies and consider making public comments.
As explained on its website, “Medicaid provides health coverage for eligible, low-income populations in Mississippi. These populations include children, low-income families, pregnant women, the aged and disabled.” Medicaid pays for the services it covers but relies on licensing and certification authorities to determine what services should be covered. In the case of community mental health services, the certifying authority is the Department of Mental Health (DMH). That means that Medicaid’s proposed policies mirror the certification standards of the DMH.
Families as Allies provided public comments to the DMH when its standards were open for public comment in June 2020. We continue to have some of the same concerns about the proposed Medicaid policy changes, including:
- A remedy will soon be imposed on the state’s mental health system by Judge Carlton Reeves due to the system being found in violation of the Americans with Disabilities Act in September 2019. This remedy is likely to have implications for how Medicaid is used and how the DMH will coordinate with the Division of Medicaid. It would seem wise to see what coordination, services and supports this remedy requires and then update the policies accordingly.
- Both sides in the lawsuit (the State of Mississippi and the United States) were ordered by Judge Reeves to submit proposed remedial plans, The remedial plan that the US Justice Department proposes relies only on the nationally recognized, evidence-based practices that the DMH currently certifies. If the judge chooses to accept the Justice Department’s proposed remedial plan, it would make some of the services (for example, Intensive Community Outreach and Recovery Teams) referenced by both the DMH and the Division of Medicaid irrelevant, unless they could be shown to be evidence-based.
- The goal of a responsive system of care for mental health is for people with mental illness to be able to live and work (and for children to go to school) in the community. There is evidence that when housing and employment are the first areas of focus, adults with mental illnesses do better overall, including managing their symptoms. The proposed policies focus heavily on therapy and treatment and do not explain how providers will be accountable for approaches such as supported employment and supported housing that have been shown to help people live in the community.
- The Employment Specialist is removed from PACT teams.
- According to its website, “in FY19, DMH piloted an Intensive Community Outreach and Recovery Team (ICORT), with the Region 2 CMHC, Communicare. In FY20, DMH provided four grants for ICORTs in regions that did not have a PACT Team. ICORTs are able to target more rural areas where there may be staffing issues or clients are spread out over a large geographical area.” This is somewhat confusing given that there are models for rural PACT teams.
- These policies appear to propose that ICORT teams could be used for children, possibly in place of Wraparound. This would mean that children would receive a service that is a yet unproven adaptation of an intervention meant for adults rather than wraparound, a nationally accepted best practice for children with agreed upon standards of fidelity.
- These proposed policies eliminate language that includes families and other caretakers in the care of their loved one.
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 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.
[Photo By /\ \/\/ /\ from Jackson Mississippi, USA – Judicial and Executive, CC BY-SA 2.0]