220-146: Evaluation of Florida's Child Welfare Prepaid Mental Health Plan (CW-PMHP): Year 5

Publication Date: 6/1/2011

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Description:

Most children in Florida's child welfare system and residing in foster care are covered under the Child Welfare Prepaid Mental Health Plan (CW-PMHP) for their mental health needs. The Community-Based Care Partnership, LTD (CBC Partnership) contracts with the Agency for Health Care Administration to administer the CW-PMHP. The CBC Partnership is comprised of Magellan Behavioral Health of Florida (the managed care organization) and Community-Based Care of Central Florida (a CBC lead agency) as general partners and additional CBC lead agencies as limited partners.

Every child entering foster care is required to have a Comprehensive Behavioral Health Assessment (CBHA) in accordance with state rules and Medicaid guidelines. Payment for this assessment is provided through the CW-PMHP. The purpose of a CBHA is to provide an in-depth picture of the child's emotional, social, developmental, and behavioral functioning within various settings to inform case planning and services.

When the CW-PMHP was implemented in February 2007, providers were permitted to bill up to 20 hours to complete a CBHA for each child. Through regular monitoring performed by the CBC Partnership, concerns arose as to the quality of these assessments and the practice of frequently billing for the maximum number of hours. The CBC Partnership provided extensive training to providers across the state regarding allowable billable activities related to completing CBHAs and the necessary components of quality assessments. Despite these efforts, the CBC Partnership saw little improvement. As questions and concerns persisted about the maximum number of hours consistently being billed and the necessity of 20 hours to complete a CBHA, a policy revision was implemented September 21, 2009. Any CBHA referred on or after this date was allowed 10 hours without authorization for children 0 to 5 years of age, and for children with no mental health diagnosis. For children in sibling groups that had shared family information, one child in the sibling group was allowed 15 hours without authorization and each additional child was allowed 10 hours without authorization. Children 6 to 18 years of age and not part of a sibling group were allowed 15 hours without authorization. Providers could request additional hours up to a total of 20 for all CBHAs by submitting justification.

After considering providers' responses to the September 2009 policy change, a second policy revision was implemented April 15, 2010 as it applied to the 0 to 5 year old population. Except for sibling groups, CBHAs referred on or after this date for children 0 to 5 years of age were reimbursed at 15 hours without prior authorization. CBHAs for sibling groups continued to be reimbursed at 15 hours for one child in the sibling group and 10 hours for each additional child without authorization. With justification for the need for additional hours, providers could continue to request up to a maximum of 20 hours for all CBHAs.

This study was comprised of two components: an Impact Analysis and a Quality Analysis. The Impact Analysis examined providers' experiences of the impact of the September 2009 and April 2010 policy changes and the changes in the number of hours paid for CBHAs. The Quality Analysis assessed the quality of CBHAs completed after the April 2010 policy change was implemented. This study was funded by the Agency for Health Care Administration (AHCA).