NH CARES Issues for COMMUNITY MENTAL HEALTH SERVICES -3/23/09
NH Community Behavioral Health Association (NHCBHA)
Bureau of Behavioral
Health HB 1 Pages: Page 1555, Lines 552, Rehab Services, 553
Case Management, 554 Evaluation & Mgmt Services, 555 Therapy Services
A. Issue of No Caseload Increases in HB1 - Page 1555, Classes 552 – 555
HB 1 proposes NO increase
for Medicaid caseload increases. The
ten Community Mental Health Centers (CMHCs) are already experiencing meaningful
caseload and acuity increases from this time last year. The DHHS maintenance budget proposed a 2.6%
caseload increase, and, as the Committee has heard, that assumption was made
when DHHS was projecting a “mild recession”.
The NHCBHA is projecting a likely 8% caseload increase in 2010 and 2011.
The lack of adequate
funding to address caseload and acuity increases will impact our ability to
maintain efforts under Medicaid. NHCBHA
wants to emphasize that with more people out of work, more individuals and
families are under stress and may require quality mental health services in
their communities, increasing the intensity and volume of need from what we
have previously experienced or expected.
These individuals may not be categorically eligible for any benefit
under Medicaid; when they present themselves to us for help, we will see a
profound increase in the number of “non-pay” or “self-pay” clients, thus
increasing our uncompensated, but statutorily required care.
Funding for the 8%
caseload increase is requested. This is
$7.2 million in total funds in each fiscal year; or $3.6 million in General
Funds (assuming a 50-50 match, less with new FMAP). With regard to uncompensated
cost increases, the lack of any rate increases will weaken even further the
Centers’ business models.
This is a reduction in the
rate for individual psychotherapy for non-eligible clients at CMHCs. HB 1 proposes to reduce this to the rate
paid to individual providers. However, the CMHCs - unlike private providers -
are required to offer screening and assessment, emergency services, and
critical incident debriefings to assist communities when a crisis occurs. The
Centers estimate the annual impact of this rate reduction at $431,000 in total
funds.
HB1 proposes to reduce
Class 555 by approximately $931,000 in 2010; and $931,000 in 2011. BBH justifies the reduction because of a
change in CPT Code 90806, based on a new interpretation of a medical rule
regarding therapy codes. NHCBHA believes that alternative solutions can be
found that will resolve the matter and not harm the CMHCs. We are currently in discussions with BBH to
reach an agreement on this matter.
While we do not expect Division III to resolve this dispute, we would
urge you to (1) keep the dollars in the line, so that once it is resolved, we
don’t have to re-fill it later; and (2) recognize that regardless of the
outcome of the CPT code matter, the reduction will cause a reduction in total
funds to the Centers and
will need to be absorbed somewhere else in our operational budgets.
a. Individual psychotherapy:
Add $215,437 General Funds ($430,875 total funds) in 2010 and $215,437
General Funds ($430,875 total funds) in 2011.
b. CPT code for psychotherapy: Add $465, 643 in General Funds
($931,286 total funds) in 2010 and $465,643 in General funds ($931,286 total in
2011.
C. Issue of Transitional/Community Housing
Section 12 D & 46,
Section 12 of HB 25, the capital budget bill, transfers $976,000 from
previously funded transitional housing that would have been built on the NH
Hospital grounds, to fund local community housing. While the concept might be a
positive one, the Centers believe that because the budget fails to fund any
operational supports for proposed housing in this biennium, no individual
Center would likely undertake the risk of constructing or purchasing this type
of housing, as it would constitute too risky an investment.
NHCBHA proposes that these
funds be allocated to the Bridges Program that was included in the DHHS
maintenance budget and is part of the Ten Year Mental Health Plan ($300,000 in
‘10 and $600,000 in ‘11). This program established a rent subsidy payment fund
for those on the waiting lists for Section 8 housing. Amendments are requested to add a new “Bridges Program” section
in HB2 and a new Class Line on page 1555 of HB 1.
HB 1 offers no rate
increase for the CMHCs, despite a maintenance budget funding that at 4.1% is
needed to keep pace with health care inflation and to maintain effort. In order
to address this dilemma, the Centers would propose that several non-critical
administrative and reporting requirements be suspended for the upcoming
biennium. The Centers are in discussions with BBH to develop a list and a
proposed footnote. This should have no
negative impact on HB1.
Contacts
NH Community Behavioral Health Association (NHCBHA), 1
Pillsbury Street, Suite 200, Concord, NH 03301-3570 603-225-6633 FAX
603-225-4739 and for additional information or answers to
questions, please contact:
Roland Lamy, Executive
Director, NHCBHA RLamy@helmsco.com
Jay Couture, Chair, NHCBHA
gacouture@aol.com
Jim Monahan, The Dupont
Group jmonahan@dupontgroup.com
Susan Paschell, The Dupont
Group spaschell@dupontgroup.com