Dual Advocate Coalition Public Comment
Medicaid Reform Unit Manager
Department of Health Care Policy and Financing
1570 Grant Street
Denver, CO 80203
May 12, 2012
I am writing on behalf of a coalition of advocates (AKA the Dual Eligible Advocacy Coalition) that has gathered to think through the development and implementation of the Dual Eligible project in Colorado. These comments can be considered public comments and represent the commonly shared principles among the whole coalition. Some organizations may submit individual questions, comments, and concerns outside of this coalition’s communication.
Overall, we are pleased with the ACC/RCCO model and believe that if properly and thoughtfully implemented, it can address some long-standing issues in Colorado and maximize some of our unique strengths. We believe that the dual eligible project represents an opportunity to:
1. Advocacy: to create a solid advocacy model for a government program serving a vulnerable population;
2. Data Use: to use data in new ways consistent with shared values of the administration and advocates;
3. Strategy: to bring stakeholders together to develop, implement, and evaluate specific strategies to address identified problems;
4. Shared Vision: to work with a broad cross section of stakeholders including but not limited to: clients, families, advocates, providers, care coordination entities, policy researchers, and legislators to create a shared vision for ideal care coordination and provision of high quality coordinated health care for disabled and elderly citizens;
5. System Focus: to shift the emphasis from a provider-centric system to a client-centric system. This includes simplification with client input on what should be prioritized for simplification, as well as client input on important benchmarks and measurements.
We also would like that the Department consider addressing the following specific recommendations as we move forward with the Dual Eligible Project:
1. Stronger oversight processes: With many Department heads at each meeting and the paid facilitators running the conversation, it becomes unclear what the internal oversight process is. Making this clear will help advocates better understand how implementation will be spearheaded.
2. More robust stakeholder engagement processes:
a. More inclusion of client and family member stakeholders as we believe that these stakeholders in particular have a lot to bring to the table. They can offer input on client outreach, cultural understanding and diversity, and “insider” knowledge of how the system actually performs.
b. All stakeholders (clients, family members, and professional stakeholders) need the following for more meaningful engagement, which will lead to a more successful program:
1. More transparency around data and metrics:
a. Increased access to underlying data used to create assumptions that are part of proposal (including the number of expected enrollees, and cost-shift and cost-saving assumptions)
2. Training on how data and analytics are used and will be used
3. Ability to participate in defining the metrics to be used and outcomes sought
i. More robust general engagement:
1. Provision for mentoring for client participants on boards and policy-making committees
2. Support existing advocacy groups to provide quality training for client participants on boards and policy making committees
ii. More effective meeting processes:
1. More streamlined meeting process- It is difficult to engage effectively when there are many meetings for the ACC/RCCO process alone, then several sub-committees for the duals in addition to the larger meeting.
2. More robust agendas sent out a full week ahead of time
3. Equal amount of time on agenda devoted to presentations and collaborative problem-solving.
4. Inclusion of all involved in implementation, such as the Department ACC staff, RCCO staff, dual providers, Treo employees, etc.
2. Define components of proposal in order to create common understanding moving forward:
a. Care coordination and case management:
i. How broadly are these defined?
4. Will case management include client assistance with non-medical needs such as housing or food?
5. Does care coordination mean simply improved referral processes or team approach to care?
ii. How will this co-exist with other established processes in the system? Will RCCOs hire or contract out for these services?
iii. Will this only be offered via Medicaid, or both programs?
iv. Who is expected to do the coordinating and management? What will be the expected training and/or education background?
i. What are the expected funding streams? How many dollars are expected?
ii. How will payment incent doctors to take high-need patients?
iii. Will there be adequate funding for case management?
iv. Will payment address cost-shifting?
c. Communication: we want to ensure that any client communication will satisfy ADA and LEP (limited English proficiency) requirements, and communication avenues outside of correspondence are being explored, especially for harder-to-reach (and potentially higher-need) clients.
3. Transition team- Even the best plans can have unexpected bumps and challenges and short delays in access to care can create severe problems for an especially vulnerable population. Until a strong system is in place and other issues outlined herein are addressed, it is imperative that HCPF designate a “go to” person or team to help resolve any problems that dual eligible clients who experience may experience.
a. General capacity- we want you to ensure that HCPF is prepared to accommodate expected changes especially with drastically changing health care landscape over next few years.
4. Systems issues- Client experience shows us that CBMS issues are still ongoing. We would like to see system improvement as part of your plan so we can ensure that clients do not face unnecessary barriers in getting their coverage.
a. Due process- We want to ensure that due process rights of client are maintained.
5. Implementation- Due to the still-developing nature of the ACC and the especially vulnerable nature of the dual eligible population, we would like to see the implementation be thoughtful, and deliberate and with testing at each phase. We especially would like to see extra attention paid to the following before and during implementation:
a. Strength and capability of chosen infrastructure (ACC/RCCO/Other)
b. Enrollment process (Notices, process, trouble-shooting, etc)
c. Assessment of need
d. Care coordination
e. Providers (including acute care, long term care medical and non-medical, mental health)
We expect our coalition to continue to grow and will work in partnership with HCPF as this program is implemented.
On behalf of Colorado’s newly formed Dual Eligible Advocacy Coalition,