A Tight Timeline for CCO Development Worries Policy Board Members, Advocates

But Dr. Bruce Goldberg said it was critical to get CCOs up and running and for the state to receive additional federal funds

March 19, 2012—The Oregon Health Authority is racing against the clock in order to have coordinated care organizations (CCOs) certified and providing care to Oregon Health Plan patients by August 1st amid growing concern that the tight timeline doesn’t leave enough time for a thorough vetting public process.

The passage of Senate Bill 1580 gave the OHA the green light to proceed with seeking waivers from the Centers for Medicare and Medicaid Services (CMS), the federal agency overseeing Medicare and Medicaid programs, to create CCOs and their risk-based global budgets. These CCOs will replace the state’s managed care organizations, and integrate the physical, mental and dental healthcare for the 650,000 patients on the Oregon Health Plan.

At the same time, the OHA is developing the specific rules and regulations that will govern CCOs. Temporary rules have been drafted, and a public comment period ended last Monday. The formal rule-making process gets under way this week, with the final version expected within the next month.

“We’re intending on making some pretty substantive changes based on the comments we’ve already received,” said Judy Mohr Peterson, the authority’s Medicaid director.

April 2 is the deadline for organizations that want to become CCOs to submit a letter of intent, while their technical applications are due April 30 and financial applications, May 14. The first wave of CCOs will be certified on May 28, and the new CCOs must sign Medicaid contracts by June 29 and begin providing care on August 1.

“This is a very, very tight timeline,” said Felisa Hagins, the political director of the SEIU 503 who sits on the Health Policy Board, at its meeting last week.

Hagins was concerned there wouldn’t be enough time for feedback from the public during the rule-making process and the ability to review the applications of potential CCOs and make potential changes.

Before these CCOs are certified, the CCOs are expected to have a public process in their local communities, responded Tina Edlund, the Authority’s policy chief.

Nita Werner, president of Ornelas Enterprises Inc., who also sits on the board, also was concerned about the impact of the timeline for certification on the development of a CCO, and warned that a rushed process might lead to loopholes for CCOs and a lack of “due diligence.”

“We’re concerned about the timelines as well,” responded Peterson, who emphasized the need to “get [CCOs] up and going as quickly as we can.”

Hagins also suggested that CCO applicants appear before the Policy Board before being certified.

But Dr. Joe Robertson, president of Oregon Health & Science University didn’t feel that was necessary, saying that meeting with each CCO applicant would be a “level of detail the board shouldn’t be involved in.” Whether applicants meet the requirements should be left up to the staff of the Authority, he added.

Eric Parsons, who chairs the Policy Board, agreed. “The important process is the community process. We’re going to make sure that we’re well informed and up to date.”

Short Timeline Concerns Advocates

Advocates also are concerned that the Authority is moving too quickly. A coalition representing consumers, minority and low-income groups and progressive political organizations sent a letter on March 9 to the Oregon Health Authority, Policy Board and Sen. Alan Bates (D-Medford), and Reps. Tim Freeman (R-Roseburg) and Tina Kotek (D-Portland), the three legislators who negotiated Senate Bill 1580, saying the timeline for public comment on the temporary rules, CMS waiver request, and request for applications was too short.

“The three combined documents total 345 pages of text, and [the authority] has given community groups and the public at large roughly a week to read and analyze them, and then provide substantive comments,” their letter read. “Given that the documents also use complex policy-specific language, the time frame proves simply insurmountable for much of the public.”

The letter requested that the public comment period for certification be extended to 30 days, rather than two weeks. But given the pressure that exists to have CCOs running by this summer—the state’s budget assumes that CCOs will save approximately $238 million between this summer and June 2013—that request was turned down.

Dr. Bruce Goldberg, director of the Authority, told Andrew Riley, the Center for Intercultural Organizing's policy director, that the timeline would not change because it was important to get CCOs up and running, and for the state to start receiving additional federal funding.

"His take was that there had been a lot of public input," Riley said, referencing the four Governor-appointed workgroups and multiple opportunities for public comment last year.

But Riley said discussions about CCOs at that time were "untangible"--no one knew what CCOs really would be, or if the Legislature would approve the implementation plan for CCOs. "There is a difference between those intangible questions," he said, and the "concrete" administrative rules and request for applications.

Image for this story appears courtesy of The Oregonian.

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In looking at the Appendix F of the Draft Medicare/Medicaid CMS waiver, it is clear that the State intends to go well beyond limiting the transfer of behavioral health services to Oregon Health Plan funds. All services, including residential are slated to move to CCOs. Essentially leaving only State Hospital services with the State and PSRB supervision only with community mental health programs.