September 20, 2012 Due to dhcshealthyfamiliestransition@dhcs.ca.gov and hfptransition@mrmib.ca.gov Re: Comments on the Draft Strategic Plan for HF Transition To Whom It May Concern: I write on behalf of the California Children’s Hospital Association to provide comments on the State’s draft strategic plan for the transition of Healthy Families children into Medi-Cal managed care. I appreciate the opportunity to provide comments on this important topic. I am pleased that Charity Bracy of my staff has been asked to join the small planning group of legislative staff and advocates that has been formed to meet regularly and provide feedback on the policy issues related to the transition. The perspective added by the Children’s Hospitals, as the key provider of specialty care in the State, is critical to these important discussions around transitioning and maintaining access to medically necessary care. I believe this planning group and additional stakeholder meetings are necessary in order to get necessary input on transition and implementation issues, and think that the State should be convening these groups regularly. Also, during the transition, it would be critical to have a dedicated staff person at the State who is available to work with providers to answer questions and offer assistance. Children’s Hospitals provide the majority of the care to the State’s sickest and most medically fragile children. On average, the hospitals are 55% Medi-Cal. Transitioning children from Healthy Families to Medi-Cal will further increase our commitment to low-income children as the volume of children in the MediCal program will rise. Given the low-reimbursement and high cost of living in California, we are concerned that there will not be enough pediatric-focused providers available to the growing number of Medi-Cal children who will require access to health care. Staying focused on ensuring a strong network of providers for children under Medi-Cal is critical and must be the focus when implementing this transition. Additional consideration by the State must also be given to providing adequate reimbursement for services. We are especially concerned that children are able to maintain access to both their specialty and primary providers while transitioning from one program to another. For many children with special health care needs, the specialist is their primary care doctor. Continuity of care must be provided for all children, regardless of whether or not they require access to specialists or a primary care physician. For example, a child with diabetes may spend more time with his/her endocrinologist than his/her primary care doctor. The transition plans and networks must recognize this fact, and strong language ensuring continuity of care (including maintenance of all current physicians) must be implemented. The sections of the draft strategic plan that I would like to be provide detailed comments on is below:  Summary Provider Data on Network Adequacy: I am pleased to hear that DHCS and DMHC are tasked with assessing health plan provider network adequacy and continuity of care. This information is critical to ensuring that there are an adequate number of providers available to the number of transitioning children for both primary and specialty care services. In the draft strategic plan document, it states: “The departments will use this data to estimate the increase in demand for provider services after the transition and to evaluate whether each plan’s provider network will be sufficient to accommodate that demand.” I think it’s critical for the strategic plan to outline how the Departments will address issues that arise from this data. How will problems identified from this work be resolved? What are the specific evaluation criteria that will be used to determine network adequacy? It would also be critical for the State to reach beyond the information provided by the plans and to get input from other pediatric-specific providers about network adequacy.  Detailed Provider Network Lists: In the draft strategic plan, it states: “For specialists, the plans must also indicate each provider’s specialty type and whether that provider operates a pediatric practice. This data will allow the departments to take a more detailed look at the geographic availability of providers and the capacity of individual providers to take on additional patients.” It would also be useful to understanding access if the plans had to indicate which hospitals each specialty provider currently has privileges at. This will also help the Department understand geographic availability. Additionally, once this information has been collected, identifying which specialty types are missing or under-represented (e.g. psychiatry) and how the Department will address these deficiencies is critical. Also, how will the Department certify that access to care is adequate both for what must be submitted to the Legislature and to CMS?  1115 Waiver Amended and CMS Review: For the purposes of this draft strategic plan, it would be useful for the Agency/Department to provide more detailed information on how it is envisioned that the 1115 waiver would have to be changed. Specifically, what impact this will have on budget neutrality and other aspects of the waiver. Since this wavier expires in 2015, should it be assumed that this issue will then need to be integrated in the next 5-year waiver that will need to be developed? Lastly, any additional information you can provide about the process and timing for CMS review would be important. Thank you for the opportunity to provide feedback on the draft strategic plan and for inviting Children’s Hospitals to have a representative join the Agency’s planning group. I look forward to continuing to collaborate with you on issues impacting children. Sincerely, Lucinda Ehnes President & CEO