September 20, 2012 to

September 20, 2012
Due to [email protected] and
[email protected]
Re: Comments on the Draft Strategic Plan for HF Transition
To Whom It May Concern:
I write on behalf of the California Children’s Hospital Association to provide
comments on the State’s draft strategic plan for the transition of Healthy
Families children into Medi-Cal managed care. I appreciate the opportunity to
provide comments on this important topic.
I am pleased that Charity Bracy of my staff has been asked to join the small
planning group of legislative staff and advocates that has been formed to meet
regularly and provide feedback on the policy issues related to the transition. The
perspective added by the Children’s Hospitals, as the key provider of specialty
care in the State, is critical to these important discussions around transitioning
and maintaining access to medically necessary care. I believe this planning
group and additional stakeholder meetings are necessary in order to get
necessary input on transition and implementation issues, and think that the State
should be convening these groups regularly. Also, during the transition, it
would be critical to have a dedicated staff person at the State who is available to
work with providers to answer questions and offer assistance.
Children’s Hospitals provide the majority of the care to the State’s sickest and
most medically fragile children. On average, the hospitals are 55% Medi-Cal.
Transitioning children from Healthy Families to Medi-Cal will further increase
our commitment to low-income children as the volume of children in the MediCal program will rise. Given the low-reimbursement and high cost of living in
California, we are concerned that there will not be enough pediatric-focused
providers available to the growing number of Medi-Cal children who will
require access to health care. Staying focused on ensuring a strong network of
providers for children under Medi-Cal is critical and must be the focus when
implementing this transition. Additional consideration by the State must also be
given to providing adequate reimbursement for services.
We are especially concerned that children are able to maintain access to both
their specialty and primary providers while transitioning from one program to
another. For many children with special health care needs, the specialist is their
primary care doctor. Continuity of care must be provided for all children,
regardless of whether or not they require access to specialists or a primary care
physician. For example, a child with diabetes may spend more time with his/her
endocrinologist than his/her primary care doctor. The transition plans and
networks must recognize this fact, and strong language ensuring continuity of care
(including maintenance of all current physicians) must be implemented.
The sections of the draft strategic plan that I would like to be provide detailed
comments on is below:

Summary Provider Data on Network Adequacy: I am pleased to hear that
DHCS and DMHC are tasked with assessing health plan provider network
adequacy and continuity of care. This information is critical to ensuring
that there are an adequate number of providers available to the number of
transitioning children for both primary and specialty care services. In the
draft strategic plan document, it states: “The departments will use this
data to estimate the increase in demand for provider services after the
transition and to evaluate whether each plan’s provider network will be
sufficient to accommodate that demand.” I think it’s critical for the
strategic plan to outline how the Departments will address issues that arise
from this data. How will problems identified from this work be resolved?
What are the specific evaluation criteria that will be used to determine
network adequacy? It would also be critical for the State to reach beyond
the information provided by the plans and to get input from other
pediatric-specific providers about network adequacy.

Detailed Provider Network Lists: In the draft strategic plan, it states: “For
specialists, the plans must also indicate each provider’s specialty type and
whether that provider operates a pediatric practice. This data will allow the
departments to take a more detailed look at the geographic availability of
providers and the capacity of individual providers to take on additional
patients.” It would also be useful to understanding access if the plans had
to indicate which hospitals each specialty provider currently has privileges
at. This will also help the Department understand geographic availability.
Additionally, once this information has been collected, identifying which
specialty types are missing or under-represented (e.g. psychiatry) and how
the Department will address these deficiencies is critical. Also, how will
the Department certify that access to care is adequate both for what must
be submitted to the Legislature and to CMS?

1115 Waiver Amended and CMS Review: For the purposes of this draft
strategic plan, it would be useful for the Agency/Department to provide
more detailed information on how it is envisioned that the 1115 waiver
would have to be changed. Specifically, what impact this will have on
budget neutrality and other aspects of the waiver. Since this wavier expires
in 2015, should it be assumed that this issue will then need to be integrated
in the next 5-year waiver that will need to be developed? Lastly, any
additional information you can provide about the process and timing for
CMS review would be important.
Thank you for the opportunity to provide feedback on the draft strategic plan and
for inviting Children’s Hospitals to have a representative join the Agency’s
planning group. I look forward to continuing to collaborate with you on issues
impacting children.
Sincerely,
Lucinda Ehnes
President & CEO