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PCPA Comments on HealthChoices North/Central Zone Discussion Paper
March 27, 2001

The Association has sent the following letter to the Department of Public Welfare, Office of Medical Assistance Programs, in response to the publication of Implementing HealthChoices in the North/Central Zone: A Public Discussion Paper. The letter addresses the broad issues of implementing Medicaid managed care within this region. Questions about the letter or the implementation of HealthChoices in the North/Central zone can be directed to Rebecca Heidenheim at PCPA.

DPW/OMAP
Bureau of Policy, Budget, and Planning
P.O. Box 8046
Harrisburg, PA 17105

To Whom It May Concern:

The Pennsylvania Community Providers Association is a trade association representing over 200 community-based agencies that provide mental health, mental retardation, substance abuse, children's, and other human services. Our members cover all 67 counties in the Commonwealth, and it is estimated that they serve almost 1 million Pennsylvanians each year, the majority of whom are MA eligible. As such, we submit the following comments on the "Implementing HealthChoices in the North/Central Zone: A Public Discussion Paper." It is our understanding that many groups and individuals will be commenting on specific issues within this document; therefore we feel it necessary to address broad policy issues in our comments.

PCPA remains very supportive of the Behavioral Health Carve-Out. Pennsylvania has demonstrated a successful Carve-Out, and must continue to keep this funding model a reality to best treat persons with mental health and drug and alcohol needs.

The community provider system for mental health and drug and alcohol services has continued to demonstrate it is in the best position to provide accessible, quality, and cost effective services to persons with mental health and drug and alcohol needs. We urge the Department to support the development of models of care providing direct, contractual (including risk sharing) relationships with providers and provider-based organizations. Support for these models will allow money currently used for MCO administration to be used to provide services to Pennsylvania's needy population.

It is critical that the Office of Mental Health and Substance Abuse Services, and the Office of Medical Assistance Programs adequately address the unique needs of rural communities. The North/Central Zone Discussion Paper does not adequately address how HealthChoices will address such issues; therefore serious thought and guidance must be given to counties with rural populations. Transportation, or the lack of it, must be addressed.

PCPA understands that there is a reasonable actuarial process for the rates that are set between the state and the counties, however, there is no such process to determine the rates between the MCO and the provider. If HealthChoices is to continue successfully, a rational actuarially based process must be implemented between the provider and the MCO.

Thank you for the opportunity to provide comments. Please do not hesitate to contact Rebecca Heidenheim on my staff if you have any questions or would like to discuss our comments further.

Sincerely,

George J. Kimes
Executive Director

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