Waiver Public Comment Open

We are submitting the following feedback regarding the pilot portion of the current draft of the NC Section 1115 Demonstration Waiver application.

1. RETAIN: Impact Health strongly supports the following items in the state’s draft application:

• Whole-person integrated approach to care supported by a care management model.
• Expansion of geographic eligibility to include all 100 counties.
• Expansion of pilot eligibility to include all pregnant and postpartum women, justice-involved individuals, those who are “at risk of” a chronic condition, individuals with only one chronic health condition, individuals recently impacted by natural disasters, children/youth who receive adoption assistance and all Tailored plan members and Tailored Care Management eligibles in prepaid inpatient health plan (PIHP).
• Expansion of meal services to three meals per day.
• Availability of capacity building funds throughout the demonstration waiver period.
• Central role of NLs in ensuring the pilot’s success.

2. MODIFY: Impact Health believes the following items could be improved upon:

• Refine language around rental assistance to include:
  
  • up to six months of rental assistance including payment of arrears
  • for all enrollees who demonstrate need (not just high-needs enrollees).
• Prioritize investments in community-based organizations and local service delivery models.
• Increase capacity building budget allocation and/or significantly increase fee schedule payments to ensure there are sufficient and sustainable resources for human service organizations (HSOs) and NLs to scale pilot services across all 100 NC counties.

3. CLARIFY/ADD: Impact Health requests the following clarifications and additions:

• Expand eligibility to include all NC Medicaid members—regardless of coverage type—who screen positive for a pilot-supported social health need.
• Clarify HOP eligibility of Medicare/Medicaid dual enrollees.
• Include all HOP services in pre-release Medicaid services available to justice involved individuals.
• Allow continuous access to HOP services for justice-involved individuals for 1-year post-release.
• Clarify that current NLs and HSOs do not need to reapply under the new waiver.

Additional Recommended Pilot Enhancements

Fee Schedule Improvements

• Standardize fee schedule statewide to reduce the potential for confusion, referral delays and rejections.
• Approve additional evidence-based parenting curricula in alignment with NC Partnership for Children to allow HSOs to leverage existing resources to meet regional needs.
• Review all services to ensure a coordination or admin fee is included.

Network Development

• Give contracting preference and/or incentives to local, community embedded HSOs to promote equity and improve pilot enrollment, member satisfaction, expansion of services/geography and culturally inclusive service delivery.
• Prioritize and incentivize local health and social service agencies to participate in the pilot.
• Provide ongoing capacity building funding to support NLs who play a critical role in developing and maintaining network diversity, capacity and sustainability.
• Strengthen and expand NL’s role to ensure pilot success by:
  
  • providing NLs with access to detailed member eligibility lists to allow NLs to build enrollment penetration maps by zip code, county, domain and/or attributed practice,
  • funding existing NLs to onboard and provide training and technical assistance to new NLs and new and existing PHPs, CINs and other stakeholders,
  • engaging NLs as primary regional representatives in state-level decision-making, and
  • partnering with NLs to create and implement a comprehensive communications and public relations strategy.

Digital Platform & Billing Process Improvements

• Develop a clear pathway and process to support data sharing between pilot stakeholders to ensure NLs can make data-driven decisions and conduct continuous quality improvements.
• Improve the accuracy and efficiency of the pilot’s digital billing processes by implementing technical solutions that
  
  • standardize billing practices using 837 and 835 data sets,
  • integrate benefits inquiries and responses (270/271 data sets) to provide HSOs with real-time access to client eligibility data, and
  • improve the user experience by providing functionality for data searches, claims management, and elimination of duplicate claims.

Compliance and Quality Assurance

• Require HSOs who directly contract with PHPs to participate in NL compliance activities to ensure network adequacy and service delivery quality.
• Increase accountability and transparency around PHP responsibilities regarding care management network adequacy, quality improvement, and payment processes.