PUBLIC INFORMATION & COMMUNICATIONS

Request for Comments

The Human Services Department, Medical Assistance Division (MAD), welcomed comments from the public about the Medicaid health care program known as Centennial Care and changes to the program being considered as part of the renewal of the Centennial Care federal waiver that will be effective on January 1, 2019. Comments were accepted until 5:00 pm MST on Monday, November 6, 2017. Read below to learn more about the Centennial Care waiver renewal.

The Department also held four public hearings in different regions of the state to receive comments about the draft waiver. Please see below for the locations and times of the hearings.

All comments were reviewed and evaluated to inform additional modifications prior to submission of the final application to CMS.

Public Hearings

Public Hearing Presentation

Las Cruces – Thursday, October 12, 2017

About Centennial Care 2.0

The New Mexico Human Services Department (HSD) is looking at improvements to the Centennial Care (NM Medicaid managed care) program that can be implemented in the “second generation” of that program, which we call “Centennial Care 2.0”. Those changes will be proposed with the input from – and following a thorough review by — stakeholders throughout New Mexico, and they must be approved through a waiver issued by the federal government (CMS).

HSD has released its draft Section 1115 Demonstration Waiver renewal application for Centennial Care 2.0.  The draft application outlines how the Department will modify and improve the program for its next iteration that begins in January 2019.  The draft application can be reviewed at this link.  1115 Waiver Renewal – Draft Application (revised October 6, 2017)

The public will have several opportunities to provide feedback to the Department about the changes outlined in the draft application during four public hearings in October 2017.  After the hearings, the Department will develop its final waiver renewal application for submission to CMS in November 2017.  CMS requires states to submit 1115 waiver applications at least one year in advance to allow for sufficient time to negotiate the final terms of the waiver.

The state released a revised draft waiver application on October 6, 2017. A summary of revisions can be found below.

Draft Waiver Application Summary of Revisions – October 6, 2017

(Original Draft Released on September 5, 2017)

The Centennial Care waiver renewal provides opportunities for HSD to build upon the accomplishments achieved since implementation of Centennial Care. At the same time, HSD has identified opportunities for continued progress in transforming its Medicaid program into an integrated, person-centered, value-based delivery system. Based on feedback received over the past three years at the annual Centennial Care public forums and through recent input sessions with advocacy groups and stakeholders, HSD has identified key areas of refinement for Centennial Care 2.0.

The following list is a summary of program modifications for Centennial Care 2.0 that leverage successful elements of the existing program design, expand initiatives that directly benefit members, and ensure the financial viability and sustainability of the program over the long term:

• Refine care coordination to better meet the needs of high-cost, high-need members, especially during transitions in their setting of care;
• Continue to expand access to Long-Term Services and Supports (LTSS) and maintain the progress achieved in rebalancing efforts;
• Improve the integration of behavioral and physical health services, with greater emphasis on other social factors that impact population health;
• Expand payment reform through value-based purchasing (VBP) arrangements to achieve improved quality and better health outcomes;
• Build upon and incorporate policies that seek to enhance beneficiaries’ ability to become more active, responsible and involved participants in their own health care, including the introduction of modest premiums for higher income populations; and
• Further simplify administrative complexities and implement refinements in program and benefit design, some of which will be achieved with the replacement of the Medicaid Management Information System, including advanced data analytics capability. A summary of this project may be found HERE.

II. Proposed Health Care Delivery System and Eligibility Requirements, Benefit Coverage, and Cost-Sharing

1. Delivery System & Eligibility Requirements

Centennial Care provides a comprehensive benefit package to eligible populations through an integrated managed care model that includes a number of innovations. The following is a description of the current eligible populations and covered benefits:

Table 1: Eligibility Groups Covered in Centennial Care

The following populations are excluded from Centennial Care:

• Qualified Medicare Beneficiaries;
• Specified Low-Income Medicare Beneficiaries;
• Qualified Individuals;
• Qualified Disabled Working Individuals;
• Non-citizens only eligible for emergency services;
• Program of All-Inclusive Care for the Elderly (PACE);
• Individuals residing in Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IIDs);
• Medically Fragile 1915(c) waiver participants for Home- and Community-Based Services (HCBS);
• Developmentally Disabled 1915(c) waiver participants for HCBS; and
• Individuals eligible for family planning services only.

2. Benefit Coverage

Centennial Care provides a comprehensive package of services that includes behavioral health, physical health, and long-term care services and supports (LTSS). Members meeting a Nursing Facility Level of Care (NF LOC) are able to access LTSS through Community Benefit (CB) services (i.e., home- and community-based services) without a waiver slot. The CB is available through Agency-Based Community Benefit (ABCB) services (services provided by a provider agency) and Self-Directed Community Benefit (SDCB) services (services that a participant can control and direct). Individuals under age 21 who are enrolled in Medicaid or the Children’s Health Insurance Program (CHIP) receive Early and Periodic Screening, Diagnosis and Treatment (EPSDT) services.

Under Centennial Care today, most adults who are enrolled in the Medicaid Expansion category receive services under an Alternative Benefit Plan (ABP). The ABP is a comprehensive benefit package that covers all services that are defined under the Patient Protection and Affordable Care Act (ACA) as “essential health benefits”, as well as adult dental services. Centennial Care 2.0 proposes to redesign the ABP into a single, comprehensive adult benefit package that would cover both the Medicaid Expansion Category as well as Medicaid adults in the Parent/Caretaker category. The state proposes adding a limited vision benefit to the ABP, and waiving EPSDT services for 19-20 year-olds who are covered under the Adult Expansion or Parent/Caretaker categories. Adults who are considered “medically frail” are exempt from the ABP and may receive the standard Medicaid benefit package, including access to CB services and nursing facility care for individuals who meet the NF LOC criteria.

As outlined in the draft waiver application, the state has proposed some additional refinements to benefits and eligibility, including:

• Developing buy-in premiums (i.e., riders) for dental and vision services, if needed due to state financial constraints;
• Incorporating eligibility requirements of the Family Planning program into Centennial Care 2.0, so that it covers men and women through age 50 with no other health insurance (with certain exceptions);
• Eliminating the three-month retroactive eligibility period for most (non-SSI) Centennial Care members;
• Accelerating the transition off of Medicaid for individuals who are eligible for the Transitional Medical Assistance (TMA) program due to increased income;
• Addressing limitations imposed on the use of Institutions for Mental Disease (IMDs);
• Requesting federal financial participation to cover former foster care individuals up to age 26 who are former residents of other states;
• Piloting wrap-around services (intensive care coordination) for youth involved with the Children, Youth and Families Department (CYFD);
• Piloting a home visiting program that focuses on prenatal care, post-partum care and early childhood development in collaboration with CYFD and the New Mexico Department of Health;
• Securing enhanced administrative funding to expand the availability of Long-Acting Reversible Contraceptives (LARC) for certain providers;
• Expanding the health home model and developing peer-delivered, pre-tenancy and tenancy support housing services to individuals with complex behavioral health conditions;
• Continuing to provide access to Community Interveners for deaf and blind individuals;
• Continuing to allow all Medicaid-eligible members who meet a NF LOC to have access to home and community-based waiver services without the need for an allocation to the waiver;
• Implementing an ongoing automatic NF LOC approval with specific criteria for members whose condition is not expected to change;
• Increasing the limit of respite hours in the Community Benefit from 100 hours to 300 hours annually;
• Allowing for one-time start-up goods funding when a member transitions from the agency-based community benefit model to self-direction; and
• Establishing limits on costs for certain self-directed Community Benefit services:
  • Related Good & Services – $2,000 annual limit
  • Non-medical transportation – $1,000 annual limit
  • Specialized Therapies – $2,000 annual limit

3. Cost-Sharing

The Centennial Care 2.0 waiver renewal proposal includes new premiums (monthly payments) for higher income categories of Medicaid. Centennial Care 2.0 also refines co-payment responsibilities that are already in place for some categories of Medicaid, adds co-payments for higher-income individuals in the Adult Expansion Group, and adds new co-payments for individuals in most categories of Medicaid for non-emergency use of the hospital Emergency Department and non-preferred prescription drugs. The charts below summarize the proposed cost-sharing under Centennial Care 2.0. Additional details may be found in the proposed waiver application.

Table 2: Proposed Premium Structure

Note: Native Americans exempt from premiums

Note: Native Americans exempt from co-payments

 III. Estimated Expected Increase or Decrease in Annual Aggregate Expenditures

The following projections utilize actual Centennial Care Demonstration Year 1-3 expenditures, aggregate per capita cost trend data, and enrollment trend data for the program, based on the populations expected to be enrolled in the Centennial Care 2.0 Demonstration.

*Estimated

IV. Hypothesis and Evaluation Parameters of the Demonstration

During Centennial Care 2.0, HSD will maintain the original hypotheses and evaluation design plan of Centennial Care, but will add new metrics in order to evaluate the impact of proposed policies and programs presented within this waiver renewal application. The table below describes these hypotheses and how HSD will evaluate the impact.

Table 4 – Quality Goals and Evaluation

V. Waiver and Expenditure Authorities

A.   Title XIX Waiver Requests

B.   Expenditure Authority Requests

Under the authority of the Social Security Act (SSA), Section 1115(a)(2), expenditures made by the State for the items identified below, which are not otherwise included as expenditures under Section 1903 shall, for the period of this demonstration, be regarded as expenditures under the Medicaid State Plan but are further limited by the special terms and conditions for the Section 1115 demonstration.

1. Expenditures made under contracts that do not meet the requirements in Section 1903(m) of the SSA specified below. Managed care plans participating in the demonstration will have to meet all the requirements of Section 1903(m), except the following:
   • Section 1903(m)(2)(H) and Federal regulations at 42 CFR 438.56(g), but only insofar as to allow the State to automatically reenroll an individual who loses Medicaid eligibility for a period of 90-days or less in the same managed care plan from which the individual was previously enrolled.
2. Expenditures for recipient reward programs.
3. To the extent necessary, expenditures for valued added services and/or cost-effective alternative services to the extent those services are provided in compliance with federal regulations and the 1115 demonstration.
4. Expenditures for direct payments made by the State to the Safety Net Care Pool (SNCP), where hospitals receive payments out of a pool.
5. Expenditures under contracts with managed care entities where either the State or the managed care entity will provide for payment for Indian health care providers as specified in Section 1932(h) of the SSA for covered services furnished to Centennial Care managed care plan recipients at the Office of Management and Budget (OMB) rates.
6. Expenditures for Centennial Care recipients who are age 65 and older and adults age 21 and older with disabilities and who would otherwise be Medicaid-eligible under SSA Section 1902(a)(10)(A)(ii)(VI) and 42 CFR §435.217 in conjunction with SSA section 1902(a)(10)(A)(ii)(V), if the services they receive under Centennial Care were provided under an Home and Community-Based Services (HCBS) waiver granted to the State under SSA Section 1915(c) as of the initial approval date of this demonstration. This includes the application of spousal impoverishment eligibility rules.
7. Expenditures to provide HCBS not included in the Medicaid State Plan to individuals who are eligible for Medicaid.