Earlier this month, in response to a Request for Information (RFI) issued by the Pennsylvania Department of Human Services (DHS), PHLP joined with Community Legal Services to provide extensive feedback on the planned re-procurement of Community HealthChoices (CHC) managed care plans.
As readers may know, the CHC Program began in 2018 in Southwestern Pennsylvania and expanded statewide in 2020. The state contracted with three managed care plans to provide CHC coverage during this start-up phase through the first five to seven years of the CHC program. As we near the end of this first phase of CHC, the state plans to do a re-procurement where they will select plans to provide coverage during the next phase of CHC as well as outline the requirements of CHC program moving forward. Our comments to the RFI reflected themes which emerged from our clients’ experiences with CHC during the past five years. We called upon DHS to adhere to the following principles in developing the application for managed care plans to become, or continue to be, CHC plans; evaluating such applicants; and operating the CHC Program in future years:
- Stakeholder engagement – putting people with disabilities and older adults in the center of both the re-procurement process and the CHC program
- Increased accountability, compliance and oversight
- Ensuring High Quality Care and Performance
- Advancing Health Equity
- Increased transparency
With these principles in mind, we made a number of recommendations aimed at improving the CHC program for the Medicaid populations it serves: older adults and people with disabilities who get home and community-based waiver services, nursing facility residents, and people with Medicare and Medicaid who do not get Medicaid long-term care services. Among our many recommendations, we emphasized that due process rights must be honored. This includes guarding against arbitrary and capricious decision-making, ensuring that service denial notices provide complete and clear explanations for the denial decision and also ensuring that participants can fully exercise their appeal rights to challenge service denials. We also focused on the need to ensure person-centered service planning principles are valued. This includes requiring service authorization decisions to be based on validated and appropriate processes. It also involves giving service coordinators both the time and tools necessary to succeed in developing, implementing and coordinating robust service plans to meet the needs and goals of participants in the community.
In developing the application to be a CHC managed care plan, evaluating applicants and molding the CHC program for years to come, we hope DHS will carefully review and consider our recommendations as well as the recommendations of other organizations and individuals that represent the interests of CHC participants.