The Mental Health Service’s Act’s (MHSA) Contribution To Integrated Care
In November 2004, California voters passed the Proposition 63, otherwise known as the Mental Health Services Act, a statewide initiative taxing the State’s highest income earners to exclusively fund specified mental health services. The significant funding stream it created, along with its emphasis on new approaches, has encouraged the transformation of mental health services in California and has fueled the integration of health and behavioral care in the state. County mental health departments are funding and forging partnerships with community agencies, including primary care clinics, to enhance behavioral care services (For more information about local efforts, see the October, 2008 Petris Center paper “Transformation of the California Mental Health System: Stakeholder-Driven Planning as a Transformational Activity.”
MHSA gave collaborative care a tremendous boost through its Innovation funding: 5% of revenues raised through the Act must be devoted to Innovations – novel and creative mental health approaches and practices that are expected to contribute to learning. Twenty-two of the Innovation work plans submitted by 33 California counties involve some facet(s) of integrated care.
Prevention and Early Intervention (PEI)
The Mental Health Services Act (MHSA) allocates 20% of the Mental Health Services Fund to counties for PEI as a key strategy to prevent mental illness from becoming severe and disabling and improve timely access for underserved populations. Many California county mental health departments took advantage of this funding opportunity to forge linkages with primary care organizations to better identify and treat those at-risk for mental health problems.
The California Mental Health Services Authority (CalMHSA)
CalMHSA is an organization of county governments working to improve mental health outcomes for individuals, families and communities. CalMHSA administers programs funded by the Mental Health Services Act on a statewide, regional and local basis. IBHP, this website host, is one of the many CalMHSA-supported Prevention and Early Intervention statewide programs.
Stigma and Discrimination Reduction Program
The MHSA Stigma and Discrimination Reduction initiative uses a full range of Prevention and Early Intervention strategies to confront the fundamental causes of stigmatizing attitudes and discriminatory and prejudicial actions. IBHP’s efforts to advance integrated care are part of this initiative.
California’s Health / Mental Health Transformation Efforts – Implementing The Affordable Care Act
The State of California has accelerated its efforts to integrate care across mental health, primary care and substance use disorders to carry out the provisions of the Accountable Care Act. California has used an 1115 Medicaid Waiver, CMS pilots, administrative restructuring and amendments to the State Medicaid Plan to add and test features that enhance counties’ and providers’ abilities to provide integrated care. Driving its transformation is a new Behavioral Health Plan. Chockablock with useful statistics, the Assessment provides extensive analysis of the target populations, past services utilization, gaps in provider capacity and workforce, financing challenges, county services and provider readiness. Notably, the Assessment contains a specific health integration chapter (beginning on page 251) and identification of many health integration projects being implemented throughout the state.
California is maintaining its carve-outs of mental health services for seriously mentally ill populations and specialty substance abuse services while expanding mental health and substance use disorder services for mild to moderate conditions through the 2014 Medicaid/Medi-Cal expansion, based on the Kaiser Small Business Plan. Specialty mental health services are provided by county mental health plans and specialty substance abuse disorder services are provided through a State/County partnership for the administration of the Drug Medi-Cal Program.
Both Medi-Cal benefits and beneficiaries have been expanded for the ACA. Expansion details have been reviewed and approved by CMS. The State has moved the entire Medi-Cal population into managed care. Health plans are now assessing provider networks and many have chosen to sub-contract behavioral health benefits to specialty behavioral health plans. An amendment to the State’s 1115 Waiver is being planned to reform the delivery of Drug Medi-Cal Services and its payment structure.
The expansion of substance abuse services under the ACA is being phased in. Alcohol screening in primary care and up to three motivational interview sessions is being provided through the Medi-Cal managed health plans responsible for managing the care of the expansion population. The Department of Health Care Services has issued an All Plan Letter that describes the new benefits and required processes. Additionally, the State is continuing to involve stakeholders through a variety of work groups and multiple committees to advise the development of a transformed Drug Medi-Cal program. The new committees focus on cross-system integration including improving access, communication, data collection and building on regional models developed in California’s Duals Eligible Pilots (Cal Medi-Connect). Those interested in substance use disorder integration can find information here.
1115 Waiver Amendment to Reform the Drug Medi-Cal Program
In order to implement the expanded substance abuse benefit authorized by the Affordable Care Act, California is seeking to reform its Drug Medi-Cal program by amending its 1115 Waiver. In November, 2014, the California Department of Health Services submitted an amendment proposal to CMS to create a new organized delivery system for the expansion and for the traditional Medi-Cal population. Although this proposal maintains California’s carve out of substance abuse services, many California counties anticipate that this proposed amendment will enhance their ability to further primary care and mental health integration with substance abuse services at the local level. For a schedule of upcoming meetings and more information about this topic, click here.
California’s Bridge to Reform 1115 Waiver–Nov 1, 2010-Oct 31, 2015
Section 1115 of the Social Security Act allows federal authorization of state demonstration pilot projects that potentially promote Medicaid objectives, so long as they are budget neutral (i.e., will not cost the federal government any more than it would normally pay under Medicaid provisions). With its previous Waiver expiring, California seized the opportunity to reform its health care system by proposing a new waiver strengthening, expanding and coordinating the health care safety net. In the fall of 2010, the State submitted an 1115 Waiver proposal to prepare health plans and providers for health care reform. The State’s goal for the Medicaid Waiver include: expanding coverage to single uninsured childless low income adults; helping preserve the safety net; improving coordination for vulnerable populations and promoting public hospital delivery system transformation. Strategies to implement these goals include: 1) creation of county-based Low Income Health Plans (LIHP) that can restrict provider networks to safety net providers only; 2) a funding structure for public hospitals that covers uncompensated care; 3) mandatory enrollment for seniors and persons with disabilities into managed care; and 4) implementing care improvement targets for public hospitals.
The Department of Healthcare Services developed a Fact Sheet explaining in more detail what changes the waiver triggered. The State continues to provide Medicaid services for the seriously mentally ill population through a carve-out 1915b waiver. The State has now designed a continuation of the waiver and has incorporated the new features for the Drug Medi-Cal Program that are under development and review by CMS (August, 2014).
In April, 2014, California’s Medi-Cal program and the federal Medicare program began a three-year demonstration project that promotes coordinated health care delivery to low income seniors and people with disabilities who are dually eligible for both programs. Because State analysis of service utilization by this dual population indicated a high rate of mental and substance abuse problems, integration of behavioral health benefits is part of this program. This pilot project is expected to drive how behavioral health and primary care health services will be integrated not only for this complex population but for the general adult Medi-Cal population as well. In the long term, the State seeks to enroll the entire dually covered population statewide in this managed care model. Eight counties have been selected for the pilot project: Alameda, San Mateo, Santa Clara, Los Angeles, Orange, San Diego, Riverside and San Bernardino. CMS and DHCS readiness evaluations have resulted in start up delays in Los Angeles and Orange counties and the addition of three more managed health care plans in Los Angeles County. More information about each counties’ pilot, consumer and provider information and State implementation can be found at http://www.calduals.org.
Low Income Health Programs (LIHP)
A feature of the 1115 Waiver to prepare California for the transition to the ACA, the LIHP mandated the provision of limited mental health services for mild to moderate conditions within primary care. DHCS has released “Safety Net Delivery System Redesign in California: Innovations in the Low Income Health Program (LIHP)“, the November 2013 evaluation of the 10 counties that implemented the California Health Care Coverage Initiative as a precursor of the ACA. Prepared by UCLA Center for Health Care Policy Research, the report examines the successes and challenges of the initiative that integrates behavioral health and primary care for single low-income adults. As of January 1, 2014, 630,000 single adult LIHP beneficiaries were enrolled into Medi-Cal.
Statewide Organizational Activities (Many Described Below Are Also Funded Wholly Or In Part By Revenue From The MHSA Act)
Alcohol and other Drug Policy Institute (ADPI) contracts with UCLA (see below) to provide training to the substance use field, including training on integration with mental and physical health services.
California Council of Community Mental Health Agencies (CCCMHA), a statewide trade association of primary providers of mental health and substance abuse services in California, advocates “before the Legislature and state agencies to increase funding for community mental health services, and to assure that state and county programs in health, mental health, housing, social services, education, substance abuse, and vocational rehabilitation, support integrated services for severely emotionally disturbed children and severely mentally ill adults and older adults.” Its website contains useful information about the Mental Health Services Act.
California Department of Drug and Alcohol Programs is no longer a free-standing entity; its responsibilities, including administration of the Drug Medi-Cal Treatment Program, were assumed by the California Department of Health Care (below) in 2013.
California Department of Health Care Services (DHCS) assumed all responsibility for policy-setting and program development for Medicaid behavioral health services in July 2012 and completed the transition in June, 2013. AB 102, signed into law June 2011, required the transfer of Medicaid specialty mental health and substance use disorder-related services to DCHS. The resulting administrative structure creates a Deputy Director to oversee these two new sub-organizations: the Mental Health Services Division and the Substance Use Disorder Treatment Services Division.
California State Department of Mental Health is no longer a free-standing entity; its responsibilities have now been folded into the California Department of Health Services (see above). A new Department of State Hospitals has been created to improve conditions in California’s five State-run psychiatric hospitals and two prison-based psychiatric programs. The 2011 report “California’s Mental Health System” traces the evolution of the state’s mental health services and explains its complex workings.
California Institute Behavioral Health Solutions (CIBHS), formerly the California Institute for Mental Health (CIMH), was founded by the California Mental Health Directors Association as its policy and program development arm. Its renaming was the result of the organization’s 2014 merger with the California Association of Alcoholism and Drug Abuse Counselors, a merger that promotes an integrated approach in training, research and development for mental health and substance use professionals.
CIBHS (under its prior CIMH name) and IBHP have co-sponsored informational webcasts and regional workshops to familiarize primary care clinics and mental health agencies with the fundamentals of integrated behavioral care. IBHP also worked with CIMH in 2008 to plan a statewide conference about integrated care, attended by both primary care and mental health professionals
In 2012, CIBHS launched three integration-related initiatives: a) The Small County Integration Collaborative concentrates on improving medical outcomes in persons with serious mental health disorders in rural counties by instituting and testing better identification and referral practices within the mental health system; b) The Care Integration Collaborative works with county mental health and substance use disorder providers and primary care and safety net health plan partnerships to coordinate care and improve outcomes for individuals with co-occurring cardiovascular or metabolic disorders; and c) The Strategies for Integration Health, Prevention and Community works with community health centers serving low-income ethnically and racially diverse populations that have or are at risk for co-occurring mental and physical health problems. Participants are supported in developing effective partnerships with community organizations to offer wellness promotion, prevention, and self-management services.
California Mental Health Directors Association (CMHDA) is a non profit advocacy association representing the mental health directors from each of California’s 58 counties, as well as two cities (Berkeley and Tri-City). The organization has included integrated care among the myriad issues it addresses. The website is an excellent source for public policy and current events in the mental health arena.
California Mental Health Services Authority (CalMHSA) is an Independent Administrative and Fiscal Governments Agency focused on the efficient delivery of California mental health projects. Member counties jointly develop, fund, and implement mental health services, projects, and educational programs at the state, regional, and local levels. See “Mental Health Services Act’s Contribution to Integrated Care” above.
California Primary Care Association (CPCA) represents more than 1,000 not-for-profit Community Clinics and Health Centers (CCHCs) and Regional Clinic Associations, which provide comprehensive, quality health care services, particularly for low-income, uninsured and underserved Californians, who might otherwise not have access to health care. Community clinics and health centers are those nonprofit, tax-exempt clinics that are licensed as community or free clinics, as defined under Section 1204 of the California Health and Safety Code, and provide services to patients on a sliding fee scale basis or, in the case of free clinics, at no charge to the patients. The term “CCHCs” includes federally designated community health centers, migrant health centers, rural health centers, and frontier health centers. Clinics meeting federal requirements and definitions for purposes of Medicaid reimbursement may also be referred to as federally qualified health centers (FQHCs) or FQHC look-alikes. IBHP’s work often parallels the work of CPCA in that both organizations are highly committed to identifying barriers that prevent patients from accessing whole-person care, though IBHP does not necessarily endorse all of CPCA’s policies.
Community-based primary care is often the first line of defense for detection and treatment of mental health issues and is often the first point of contact for identifying and treating individuals who otherwise might face stigma, cultural or other barriers to accessing traditional mental health services. California’s CCHCs provide a wide range of behavioral health services, varying by clinic and ranging from highly developed & integrated systems of care to on-site mental health assessments and treatment to referrals to outside providers for care. Patients who present with physical health symptoms and have a co‐occurring mental disorder are more likely to use emergency room services than patients without a behavioral health disorder. CCHCs that provide screening and treatment in the primary care setting using coordinated care models see decreased rates of emergency room visits and lower costs to the health system as a whole. In addition to primary care and behavioral health services, many CCHCs offer critical enabling services to ensure that patients remain stable in all aspects of their lives. Enabling services offered at CCHCs can include, but are not limited to, case management, employment services, group support, and affordable housing services.
The CPCA maintains the Behavioral Health Peer Network, open to member clinics, which focuses on issues that impact behavioral services delivered in primary care settings. To join or for more information, contact its current president, Kelly Aldrich at email@example.com.
In 2008, IBHP partnered with CPCA to sponsor a series of webcast seminars focusing on various aspects of integrated care and featuring Kirk Strosahl, Jurgen Unutzer and several other prominent local and national authorities. For more information about past webcasts, click on “TRAINING ARCHIVES” in the left-hand menu.
In addition to the statewide CPCA, there are networks of regional consortia – 14 to date – linking regional community clinics and health centers throughout California. These organizations advocate for local, statewide and national policy and assist their members with issues of both state and local interest. In 2007, The California Endowment awarded grants to these consortia to support their local activities, including participating in the local MHSA (see first entry above) planning and program development. In fall 2006, IBHP surveyed the consortia regarding their efforts to assist clinics integrate mental health into primary care services. Click here for a California primary care consortia map and description.
CPCA Policy Priorities Related To Integrated Behavioral Health
- The Same-Day Visit Billing Barrier
In order to best provide integrated behavioral health services to patients, many community clinics and health centers provide medical and mental health services on the same day, which is the hallmark of the Integrated Primary Behavioral Health Care model. However, Medi-Cal will not reimburse for a patient to see a primary care provider and a mental health provider/behavioral health specialist on the same day at FQHCs and RHCs. Only one visit is reimbursed in this situation. While California’s State Plan Amendment and Medi-Cal Provider Manual will permit FQHCs and RHCs to be reimbursed for same-day medical and dental services, mental health services are not treated with parity. While federal Medicaid law permits reimbursement for same-day medical and mental health visits and for federal matching funds to be provided for states that choose to allow same-day visits, California does not take advantage of these federal funds.CPCA has unsuccessfully forwarded legislation four times to expand the circumstances in which heath centers could pursue independent reimbursement for same-day services. DHCS continues to maintain staunch opposition for a legislative initiative that would potentially increase access to mental health services at health centers when they feel that it is the responsibility of the counties, not the health centers, to ensure access to such services. While CPCA is obviously disappointed in the Administration’s lack of support for integrated behavioral health care, some of these legislative pursuits (SB 260, Steinberg, 2007) have resulted in significant accomplishments such as the creation of a strong coalition of supporters and heightened awareness of the value of the integrated behavioral health care model by legislators and state administrative leadership. CPCA is hopeful that the payment reform demonstration currently being worked on in collaboration with DHCS will help to rectify some of the challenges currently imposed by the same day billing restriction.
- Medi-Cal Reimbursement of Marriage and Family Therapist Services
California faces a serious shortage of mental health professionals. Securing mental health professionals poses a great challenge to many health centers across the state and serves as a major barrier to the centers’ abilities to effectively meet the mental health needs of their patients. In order for a mental health service provided by and FQHC or RHC to be covered by Medi-Cal, the service must be for the diagnosis and treatment of mental illness and must be provided via a face-to-face encounter with a recognized provider. The mental health providers presently recognized by as billable providers at FQHCs and RHCs in California include psychiatrists, licensed clinical psychologists, psychiatric nurse practitioners, and licensed clinical social workers. Marriage and Family Therapists (MFTs), however, are not recognized as reimbursable providers, despite the fact that MFTs have the education, training, and practice rights equivalent to or greater than other recognized providers. MFTs are licensed psychotherapists and healing arts practitioners who treat persons involved in interpersonal relationships. As relationship specialists, MFTs are trained to assess, diagnose and treat individuals, couples, families and groups to achieve more adequate, satisfying and productive marriage, family and social adjustment. Requirements for licensure involve extensive education, training, clinical fieldwork, and rigorous examinations. MFTs stress a systemic, integrated approach to therapy which results in their ability treat patients’ conditions quickly and cost-effectively. MFTs also tend to be lower cost providers than their billable counterparts.DHCS submitted a State Plan Amendment (SPA) that allows Marriage and Family Therapists (MFTs) to independently provide psychotherapy services to Medi-Cal patients, which was approved by the Centers for Medicare and Medicaid Services (CMS) earlier this year (certain behavioral health interns were also approved to provide psychotherapy services for Medi-Cal patients under supervision). This was a victory for CPCA and other safety-net advocates who have been working for years to convince the state to make MFTs Medi-Cal billable providers. Unfortunately, DHCS did not explicitly include MFTs or interns as FQHC billable providers. DHCS originally cited the reason MFTs could not be PPS reimbursable providers as due to federal and state barriers. CPCA confirmed that while there are no federal barriers that prevent MFTs from being included as PPS billable, there is a state barrier — to add MFTs as state PPS billable providers, legislation and a budget allocation would be required. Additionally, DHCS is not supportive of adding additional PPS billable providers at this time. One of the major barriers to garnering significant support from CPCA’s partner organization on the national level has been that since MFTs do not make up a significant percentage of the mental health provider pool in most states other than California and a few others, this is not seen as an issue of national priority.
- Case Management Reimbursement
One of the major issues reported by mental health and primary care providers at community health centers is the inability to adequately fund and effectively provide case management services to patients. As a requirement for their federal designation as a FQHC, health centers must provide certain primary health services, such as case management – including counseling, referral, and follow-up services. However, there are significant limitations and considerable confusion regarding which types of case management services are reimbursable and under what conditions these services are reimbursed by Medi-Cal and Medicare. Additionally, there is confusion about how the cost of case management services may be included in the prospective payment system (PPS) rate for FQHCs, resulting from a number of instances in which health centers have lost appeals to the State when attempting to claim case management costs in their PPS rate. In order for FQHCs to have sufficient resources to appropriately provide critical case management services for their patients, changes to FQHC financing policy may be necessary. There may be opportunities to provide some level of case management or care coordination through the implementation of the Section 2703 Health Home Demonstration, however, this will only be limited to those patient deemed eligible for health home services by DHCS.
CalMEND, now disbanded, was a partnership initiative of the California Departments of Mental Health and Health Care Services to improve quality and outcomes for publicly funded mental health services. The organization embarked on a pilot-collaborative to integrate primary care and mental health services, enlisting the participation of six counties in the state. The goal of the pilot project was to improve medical outcomes of persons with serious mental health disorders by giving them better access to primary care. While improvement in all areas was sought, the focus was on improving, by at least 50%, the identification and treatment of cardiovascular disease and its risk factors, including physical inactivity, smoking, obesity, diabetes, hypertension, and dyslipidemia. Much of this work has been continued by CiMH collaboratives (see above).
County Alcohol and Drug Program Administrators Association of California (CADPAAC) has now merged with the California Mental Health Directors Association to become the County Behavioral Directors Association of California (see below)
County Behavioral Directors Association of California (CBHDA), a 2014 merger of the California Mental Health Directors Association (CMHDA) and the County Alcohol and Drug Program Administrators Association of California (CADPAAC), is a nonprofit advocacy association representing behaviora lhealth directors from each of California’s 58 counties, as well as two cities (Berkeley and Tri-City).
County Medical Services Program (CMSP), now defunct with the advent of Medi-Cal expansion, provided health coverage for low-income adults in thirty-four primarily rural California counties. It initiated a pilot program whereby several primary care clinics received reimbursement for up to ten client mental health visits and twenty substance abuse visits per year. They found that doing so produced a dramatic decrease in inpatient psychiatric days, but the cost-savings were negated by a concomitant rise in outpatient costs. They also found significant positive clinical outcomes as measured by the Duke Health Profile. For more information, see their 2011 Evaluation Report and a 2012 Evaluation Report of a more current pilot, named Local Health Connections, which tests the effectiveness of an integrated approach to patients with complex medical and/or social conditions. Models adopted by participant counties are described, along with lessons learned.
CMSP built upon its integration pilot to create its Local Income Health Plan (LIHP) – Path2Health, – enabled by California’s 1115 Medicaid Waiver. Consumer benefits include individual and group mental health and substance abuse services provided in primary care. While care integration was encourage by CMSP payment for “warm handoffs”, specific integration models utilized were left to local decision-making rather than being mandated.
Integrated Behavioral Health Project (IBHP), this website host, was launched in 2006 to accelerate the integration of behavioral health services and primary care in California. The organization’s goal is to identify and elevate program elements, strategies, and treatment approaches leading to successful integration of mental and physical care. Originally a joint program of The California Endowment, IBHP is now a project of the Tides Center and its Community Clinics Initiative (CCI), funded by CalMHSA as part of its Statewide Stigma and Discrimination Reduction Initiative. Among the informative material IBHP has developed are Partners in Health: Mental Health, Primary Care and Substance Use Interagency Collaboration Tool Kit; Integrated Behavioral Health Screening Tool Kit; Training Needs in Integrated Care; Health Reform and Transformation of the Delivery of Care; and Stigma and Attitudes Toward Working in Integrated Care.
Integrated Healthcare Association (IHA) is a California nonprofit association working to convene all healthcare parties for cross- sector collaboration on health care topics. IHA administers regional and statewide programs and serves as an incubator for pilot programs and projects. Board members include major health plans, physician groups, and hospital systems, plus academic, consumer, purchaser, pharmaceutical and technology representatives. Principal projects include the California Value Based Pay for Performance program, the measurement and reward of efficiency in health care, health care affordability, administrative simplification, and accountable care organization (ACO) models.
Integration Policy Initiative (IPI) was created when IBHP (this website host) and its partners, the California Institute of Mental Health, the California Primary Care Association and the County Mental Health Directors Association convened a statewide stakeholder process to develop a vision for service integration across disciplines in California. Their efforts culminated in a policy summit that generated recommendations to policy makers and a three volume report, California Primary Care, Mental Health and Substance Abuse Initiative. The report, along with recommendations and cross-discipline relationships, proved useful in the development of the State’s 1115 Waiver. Exploring models of integrated care throughout the State, the report makes recommendations for service delivery, finances, regulations and measurements. It also provides a suggested continuum for the health, mental health and substance use care of the safety net mental health population. Volume III, Examples describes various California integrated care demonstration projects in primary care sites funded through grants by IBHP, CMSP and CalMEND.
Integration Policy and Practice Initiative (IPPI) is the name for the current collaborative efforts of IBHP and its IPI partners (see above) under the auspices of its CalMHSA Stigma and Discrimination Reduction grant. The partners collaborate to promote care coordination and service integration across mental health, substance use disorder and physical health care services. The IPPI Steering Committee brings together statewide systems, organizations and provider, client and family leaders in mental health, substance use and physical health to promote cross-system knowledge and commitment to integrated services, including policy, delivery design, practice and financing. Its second Annual Integration Summit took place in June, 2014. Among the material IPPI has generated are papers making the business case as well as the provider case for care of persons with complex co-occurring disorders.
Little Hoover Commission, an independent state oversight agency that investigates state government operations and makes reports, recommendations and legislative proposals based on findings, published “Addressing Addiction: Improving and Integrating California’s Substance Abuse Treatment System” in 2008.
Medical Education and Research Foundation, a sister organization to the California Society of Addiction Medicine (CSAM) was established in 1981 to increase and improve the education of physicians about alcoholism and other drug dependencies – specifically about the science base, and how to apply it with patients. Many useful tools for screening and brief intervention can be found on their website.
Mental Health Association of California (MHAC) is the statewide mental health association providing advocacy and education on mental health issues. Its five primary areas of focus are health insurance coverage, funding of public mental health services, stigma, discrimination and research. Itself a chapter of Mental Health America, MHAC has individual chapters throughout California. Its leadership is responsible for the conceptualization and passage of the Mental Health Services Act to expand mental health services in California, which has become a major impetus for the integration of health and behavioral health in the State. MHAC is a partner with IBHP, this website host, in advancing integrated care in this State.
UCLA Integrated Substance Abuse Program (ISAP) was established in 1999 to strengthen drug abuse research efforts and to improve treatment services. As one of its activities to integrate substance abuse services, ISAP teamed up with the Los Angeles County Department of Mental Health to co-sponsor the conference “Treatment of Substance Use, Mental Health, and Primary Care Disorders in the Era of Health Reform” in 2011. The event attracted more than 600 people from across the state.