a. Periodic internal monitoring and auditing of compliance;
b. Periodic review and analysis to determine if there are any changes in its benefits, policies and procedures, and utilization management protocols that impact compliance.
c. Periodic communication to delegated contractors regarding changes impacting compliance, including parity of health care services such as mental health and/or substance use disorder parity (MHPAEA).
7. A comprehensive list of services and procedures that support integrated and comprehensive recovery models must be available to clinicians and consumers.
8. Integration must include all levels and aspects of care – emergency departments; all inpatient hospital care; partial hospitalization; nursing homes; assisted living facilities; group homes, residential programs; day programs; outpatient care; diversion programs; pharmacy, including all medications; and all types of care including mental health, somatic and addiction care.
9. Either require coordination of clinical information via the state-designated HIE or provision of a shared electronic health record service for all integrated care, with appropriate provisions to protect patient privacy.
10. Financial, administrative, and clinical data collection systems must be integrated to permit analysis of expenditures associated with patient outcomes.
11. Consumers should be allowed to receive services from any willing clinician.
12. The comprehensive list of services that patients may receive must be developed using a recovery-based model and covered under the integration of services.
13. Data transparency for all stakeholders is critical for trust and success.
14. An oversight group of stakeholders will monthly review integrated data from all payor sources (MCO, ASO, MBHO, etc) and service utilization sources (ADT, Pharmacy, etc) for the purposes of ongoing review and ensuring coordination of care.
15. Spreadsheets must be developed that permit ongoing ability for stakeholders to view levels of care being provided and denied, as well as their outcomes, for all patient subpopulations at the granular level.
16. Standards should be developed for network provider directories that ensure accurate and up-to-date contact information as well as the ability to indicate if a provider is able to accept new outpatients in a timely manner.
An interesting approach that could merge these ideas is to develop an MCO that is led by people with expertise in managing the health of people with behavioral health conditions. This would be a pretty new animal, one that is savvy to the needs of both behavioral health and primary care and that can effectively incentivize health system behaviors that improve overall health while reducing total costs.
There could also be a role for Maryland’s two large medical systems, University of Maryland and Johns Hopkins, to work together in running such a hybrid animal. With the goal of getting this up and running by 2014, time may be the most limiting factor here, potentially resulting in us going down more familiar, if less effective, pathways.
What is going on in your state? Is there a challenge to integrate care? Which populations? Is somatic care included? Let us know what is going on in your state.
—Steven Roy Daviss, M.D., DFAPA
DR. DAVISS is chair of the department of psychiatry at the University of Maryland’s Baltimore Washington Medical Center, policy wonk for the Maryland Psychiatric Society, chair of the APA Committee on Electronic Health Records, and co-author of Shrink Rap: Three Psychiatrists Explain Their Work, published by Johns Hopkins University Press. In addition to @HITshrink on Twitter, he can be found on the Shrink Rap blog.