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Illinois Department of Human Services/Division of Mental Health Fiscal Year 2011 Utilization Management Program. Summary of Exploratory Data Analysis. Reasons for UM focus. Recovery focus, right services, right amounts, right time Duty to manage risk as well as scarce resources
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Illinois Department of Human Services/Division of Mental Health Fiscal Year 2011Utilization Management Program Summary of Exploratory Data Analysis January 2011
Reasons for UM focus • Recovery focus, right services, right amounts, right time • Duty to manage risk as well as scarce resources • With appropriate UM strategies, assure that people move thru the system to lesser levels of care as appropriate, assuring more intensive services are available to those in need January 2011
Process of development of UM program • Looked at criteria and models of authorization from other states and jurisdictions • Looked at other options • Absolute benefit limits embedded in Medicaid State Plan which do not allow for any extensions • Reduction of Medicaid benefits to more narrow benefit package • Cuts in Medicaid rates • 100% (pre)authorization of all services • The threshold model adopted seemed the best option among difficult choices January 2011
Guiding Principles of DMH UM Program • Utilization Management should focus on outliers • Much less administrative cost to the system since review is only required of individuals with unique use patterns • Review process is used not to limit benefits, but to make sure that those individuals with higher needs are appropriately getting their needs met • Approximately 75% of the individuals served in the mental health system may NEVER require any external authorizations January 2011
Guiding Principles of DMH UM Program UM is dynamic and evolutionary. As additional data, new research, and other new information occurs with experience, the UM Program will evolve and change. January 2011
Guiding Principles of DMH UM Program UM must be based on data. The UM Program must use data to identify patterns of utilization, work with clinicians to determine if the patterns and variations are desirable or not, and work with providers to make needed improvements. January 2011
Guiding Principles of DMH UM Program Individuals accessing services should have a consistent threshold of medical necessity statewide. The UM Program must provide clear guidance for medical necessity decisions so that all individuals accessing services have consistent and equitable access to specific services. January 2011
Guiding Principles of DMH UM Program Authorization must be clinically focused and conducted by qualified staff. Where authorization is determined to be necessary, it must be based on clinical information and reviewed by staff at the independent license level (LPHA). January 2011
Psychosocial Rehabilitation PSR is intended to be an intensive, time-limited, curriculum-based service focused on increasing specific skills to support an individual’s recovery The expectation is that as the person acquires skills, they will be assisted as needed in practicing those skills in natural settings through community support services January 2011
Psychosocial Rehabilitation While DMH acknowledges there may be activities that are NOT Medicaid services that are needed by some individuals, the continued provision of PSR to meet those needs which are outside the intended purpose of the service increases the risk to the mental health system in the event of federal audit for lack of active treatment and evidence of continued rehabilitation. January 2011
Psychosocial Rehabilitation • Spent on PSR FY09: 28 Million • Number of consumers: 9329 • Average amount per consumer: $3,000 • Average units per consumer: 600 • Range of units: 1 - 9,000 January 2011
Disproportionate Use of Services • 896 consumers or 10% of the population have usage patterns that are considered statistically “distant” from the normal usage pattern, i.e. are extreme values • Over the course of a year, • 10% of PSR consumers received 43% of PSR dollars in FY09 • For every 1 dollar spent on the larger group, 7 dollars was spent on the “high utilizer”. January 2011
Psychosocial Rehabilitation % of Consumers % of Cost January 2011
Therapy/Counseling • Spent on Therapy/Counseling FY09: • Adults - 29.2 Million • Children/Adolescents – 12.9 Million • Number of consumers: • Adults - 51,939 • Children/Adolescents – 22,865 • Average amount per consumer: • Adults - $561 • Children/Adolescents - $565 January 2011
Therapy/Counseling – Children & Adolescents Hours of Service % of Consumers % of Cost January 2011
Therapy/Counseling - Adults Hours of Service % of Consumers % of Cost January 2011
Frequently Asked Questions January 2011
Who the UM program covers: • Individuals enrolled in Medicaid whose services are reimbursed by DMH. • The UM program DOES NOT cover: • SASS • ICG • The HFS Integrated Care Pilot is also separate from DMH programs. January 2011
Who the UM program covers: • The Collaborative will continue to provide authorizations for services covered by the UM program after the conversion to HFS for claim submission. January 2011
What the UM Program Covers The UM program covers the following DISTINCT Rule 132 services: • Therapy/Counseling • PSR • PSR means PSR group and PSR individual • CSG • CSG means Community Support Group. • CSG does NOT include CSI, CSR individual or CSR group • ACT and CST authorizations will also continue. January 2011
What the UM Program Covers • Medical Necessity Criteria were also provided for Community Support Individual, but this service DOES NOT require external authorization for FY11. January 2011
Thresholds for UM program • The threshold for therapy/counseling is 40 units. • This 40 units includes all three modalities (individual, group, family) • All units of therapy/counseling billed for an individual by a provider will count towards the 40 unit threshold. • PSR and CSG have a threshold of 800 units combined. • Units are in 15 minute increments. January 2011
Tracking of Thresholds • The tracking of thresholds must be done at the provider level. • Because providers have up to one year to submit claims, DMH and the Collaborative cannot produce real-time reports for providers on claims submissions. January 2011
Submission of Authorization Requests Providers should submit requests for authorization in advance of meeting the threshold for individuals, if they believe the individual is going to need continued service beyond the threshold of units The turn-around time for the initial decision is 7 business days, and this should be included in the timing of submission for authorization decisions January 2011
Electronic Authorization Request Form The electronic authorization form contains both REQUIRED fields and OPTIONAL fields The optional fields are meant to give the Collaborative Clinical Care Manager additional information which is commonly considered helpful in providing a more complete clinical picture. • Medications are an OPTIONAL field January 2011
Electronic Authorization Request Form • The LPHA is not required to be the person making the authorization request • Providers may request as many user names/passwords as they would like for using the ProviderConnect system. • If a provider wants to limit access for claims submission to only select staff, then they can indicate that on the form when requesting the access for submitting authorizations. January 2011
Supporting Documentation Providers should submit sufficient documentation of: • Medical Necessity for the continued service • Progress in Treatment January 2011
Supporting Documentation • Mental Health Assessment and current Treatment Plans MUST be submitted • Additional documents providers MAY submit would include progress notes, treatment summaries or other clinical documentation • Additional documentation may include clinical documents completed by any clinical staff, not just the LPHA January 2011
Supporting Documentation • Supporting Documentation may be attached electronically to the request, or may be faxed to the Collaborative at (866-928-7177). • Faxed documents need to be sent under separate cover sheets for each individual, clearly indicating the individual’s name and the service(s) being requested for authorization. • All documents must be sent within 1 business day of completion of the electronic form to be considered as part of the initial determination decision. January 2011
Authorization Determinations • Collaborative Clinical Care Managers will • Consider all the clinical evidence submitted in the documents • Use the published Medical Necessity Criteria and Guidance • Authorize services demonstrated to be medically necessary • In situations where the CCM believes medical necessity is not indicated, the CCM will then consult with a Collaborative psychiatrist, to determine whether to authorize the request. • A determination to deny authorization can only be made by a psychiatrist. January 2011
Medical Necessity • The guidelines were written with the intention of being broad enough to allow for the exercise of clinical judgment and flexibility as new treatment practices emerge • Nothing within them is meant to preclude the provision of medically necessary services to any particular group of individuals who do have a diagnosis of a mental illness January 2011
Medical Necessity • Collaborative CCMs WILL NOT deny authorization of any specific service based solely on an individual’s diagnosis January 2011
Medical Necessity • Diagnosis of mental illness is and has always been required for reimbursement under Rule 132. • Persons with dual diagnoses will continue to be eligible for services reimbursed by DMH. • Consistent with Federal Medicaid requirements, services billed to Medicaid must be to address the symptoms related to the diagnosed mental illness. • The list of diagnoses eligible for reimbursement from DMH is extensive and has not been changed. January 2011
Notification of Authorization Decision • The Collaborative will make the decision within 7 business days. • Decisions will be posted to ProviderConnect when made • Letters will also be mailed to the provider’s postal address • Notices will not be sent via e-mail January 2011
Request for Reconsideration • If an initial determination is made to deny authorization, the provider may request a reconsideration • Additional supporting documentation may be sent to be considered by the Collaborative Physician Advisor during this review • PA will be Board Certified in Psychiatry and licensed to practice in IL • The turn-around time for this review is 14 days • Services provided during this time will be eligible for reimbursement January 2011
Appeals • If the Collaborative PA upholds the initial denial determination, there is an appeal process through the Director and finally through administrative law through HFS. January 2011
Questions? January 2011