Provider Alert - May 19, 2009 - DCH Requests Testimony Concerning Rates

To: Mental Health Providers

The Department of Community Health has requested input in the provider rates for Medicaid provided services.  These rates can be found on our website at: 
http://www.gahsc.org/nm/2009/mhrates20090320.pdf .  The Notice from the DCH can be found below.  We have until May 29th to send them our input concerning the rate changes.

While most of the rates changes were received with acceptance, one rate reduction was met with special concern. 

Of special concern is the Group Out Patient Services rate change.  The current rate is $14.70 per unit.  The proposed changes will significantly reduce the per unit rate.  When Georgia "debundled" its residential services, group therapy became the therapeutic modality of choice for many residential providers.  It was effective. It worked. It integrated well in the residential and group dynamic model and provided the accountability, socialization, communications skills training and peer culture development that helped children and youth develop. 

DCH is reporting that the rates were cut because "the existing group rate is the highest in the country."  "CMS does not base rates on the value of the services but the cost of the staff who provide the services."  What they do not say is that CMS also considers procedures that ensure that payments are consistent with efficiency, economy, and quality of care.  Other costs can be considered as well such as benefits, travel, overhead and whether the rates are sufficient to enlist enough providers so that care and services are available to the general population in the geographic area with the rate scale. 

Providers should give written testimony to the Department of Community Health using the following points:

Proposed rate changes for Group Therapy:

• Do not promote efficiencies -
• Is a disincentive for effective therapies for the populations targeted for these services -
• Will be hampered by lack of service providers -
• Will be jeopardized Quality of Care -

Ask DCH to raise the proposed rates for each category of provider by 40% to reflect the true cost of providing this much needed care. 

Please send your written testimony to DCH on or before May 29, 2009, to:

Board of Community Health
Post Office Box 1966
Atlanta, Georgia 30303

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PUBLIC NOTICE
Pursuant to 42 C.F.R. � 447.205, the Georgia Department of Community Health is required to give public notice of any significant proposed change in its methods and standards for setting
payment rates for services.

COMMUNITY MENTAL HEALTH SERVICES (CMHS)

Effective for services provided on and after July 1, 2009, and subject to payment at fee-for-service rates, the Department of Community Health is proposing to make the following change to Medicaid
reimbursement for Community Mental Health Services.

Providers of Community Mental Health Services will be reimbursed fee-for-service rates based on:

• Practitioner type;
• Service costs (salaries, fringe benefits, allocable direct and appropriate indirect costs);
• Location of services (in-clinic and out-of-clinic); and
• Productivity factors.

The purpose of this change is to more accurately match payments to the level of service being provided. This change is estimated to be budget neutral.
This public notice is available for review at each county Department of Family and Children Services office.

Citizens wishing to comment in writing on any of the proposed changes should do so on or before May 29, 2009, to the Board of Community Health, Post Office Box 1966, Atlanta, Georgia 30303. Comments submitted will be available for review by the public at the Department of Community Health, Monday � Friday, 9:00 a.m. to 4:30 p.m., in Room 4074, 2 Peachtree Street, N.W., Atlanta, Georgia 30303.

Comments from written and public testimony will be provided to the Board of Community Health prior to the June 11, 2009 Board meeting. The Board will vote on the proposed changes at the June 11, 2009 Board meeting to be held at 10:30 a.m. at the Department of Community Health (2 Peachtree Street, N.W., Atlanta, Georgia 30303) in the Fifth Floor Board Room.

NOTICE IS HEREBY GIVEN THIS 1st DAY OF MAY, 2009

Rhonda M. Medows, M.D., Commissioner

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Provider Alert,     a public service of the
Georgia Association of Homes
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http://www.gahsc.org                            
Normer Adams, Editor
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