OVERVIEW

Community clinics and health centers (CCHCs) are leaders in meeting the behavioral  health needs of low income, ethnically diverse patients in trusted, community-based primary care setting. As  patient-centered health homes that focus on personal, coordinated care at a single location, CCHCs primarily use an integrated care model in which there is a high degree of coordination and collaboration between physical health and behavioral health departments. Because of this integration, health centers are uniquely positioned to identify and care for primary care patients who also present with depression, anxiety, addiction, or other behavioral health concerns.

CCHC behavioral health services reach a population with mild and moderate needs that would not otherwise be reached through the traditional county-based system of specialty care for those with the most significant needs.

California’s decision to carve mild and moderate mental health and substance use disorder services into Medi-Cal Managed Care means that managed care organizations must set up provider networks that are capable and ready to meet the demand for these new services.  CPCA and member CCHCs have been working diligently to prepare to provide the new mental health and substance use disorder services now being required of managed care plans to both current Medi-Cal patients and the Medi-Cal expansion population.  Many CCHCs are designated Federally Qualified Health Centers (FQHCs), which offer access to mental health and substance use disorder services as part of their federal core services.  Many CCHCs also offer individual, family, and group counseling, as well as classes and psychiatric services.  Patients often do not know they are suffering from a behavioral health issue, but can be diagnosed in the primary care setting when providers are trained to recognize these problems.  Our CCHCs use integrated services to identify and assess risk, then link patients with the appropriate services or treat them in-house.

Our system will be greatly strengthened by the behavioral health expansion if certain aspects of the delivery system can be maintained.  DHCS is releasing information on the benefits pertaining to the behavioral health expansion.  This page is meant to serve as a hub for the information coming out so that it is easily accessible in one area.  CPCA staff will make an effort to post information and links as we find them, but please be sure to visit the sites listed below for the most up-to-date information on this issue.

Confidentiality of Substance Use Disorder Patient Records (42 CFR Part 2)

The Substance Abuse and Mental Health Services Administration (“SAMHSA”)’s Final Rule on the Confidentiality of Substance Use Disorder Patient Records (“42 CFR Part 2” or “Part 2”) takes effect immediately as of March 21, 2017. The Final Rule (which makes changes to 42 CFR Part 2), and a Supplemental Notice of Proposed Rulemaking (“SNPRM”) (which proposes additional changes to 42 CFR Part 2) were published on January 18, 2017 and were included in the Trump administration’s 90-day freeze issued on January 20, 2017 for all new and pending regulations.  The Final Rule is scheduled to take effect March 21, 2017.

The final rule is intended to update and modernize the Confidentiality of Alcohol and Drug Abuse Patient Records regulations, which have not been substantially updated since 1987.  The updates intend to facilitate better communication and information exchange within electronic health record systems while addressing legitimate privacy concerns of patients seeking treatment for a substance use disorder. 

The following resources are intended to support health centers interpret how the Final Rule applies to their operations.

Legal Action Center (https://lac.org/resources/substance-use-resources/confidentiality-resources/)

SAMHSA-HRSA Center for Integrated Health Solutions (http://www.integration.samhsa.gov/operations-administration/confidentiality)

California Health Care Foundation (http://www.chcf.org/topics/health-data-and-privacy)

Substance Abuse and Mental Health Services Administration (https://www.samhsa.gov/about-us/who-we-are/laws/confidentiality-regulations-faqs

Department of Health Care Services

Behavioral Health Expansion of Benefits for Medi-Cal Managed Care

The California Department of Health Care Services (DHCS) is in the process of releasing more information about the behavioral health expansion of benefits for Medi-Cal managed care patients.  This webpage is a compendium of the information being released that pertains to community clinics and health centers, which CPCA will continue to make available as we find it.  Please be sure to check the DHCS webpage for the most recent and up to date information.  For questions about this website, please contact Erynne Jones at ejones@cpca.org

DHCS Medi-Cal Provider Home Page

DHCS Mental Health and Substance Use Disorder Stakeholder Page

This webpage provides links to various activities and information related to the planning, delivery and monitoring of MH/SUD services. The webpage has links to partners within DHCS and outside of the department.

DHCS All Plan Letters

All Plan Letters (APLs) are the means by which MMCD conveys information or interpretation of changes in policy or procedure at the Federal or State levels, and provides instruction to contractors, if applicable on how to implement these changes on an operational basis.

  • Main Webpage for All Plan Letter Updates from DHCS:  http://www.dhcs.ca.gov/formsandpubs/pages/mmcdplanpolicyltrs.aspx
  • Relevant Behavioral Health Expansion Updates
  • If the Medi-Cal beneficiary does not meet criteria for county specialty mental health services, the managed care plan is responsible for covering those services.
  • MCPs must cover outpatient laboratory tests, medications supplies, and supplements prescribed by the mental health providers in the MCP network, as well as by PCPs, to assess and treat mental health conditions. The MCP may require that covered services be provided through the MCP's provider network and be subject to a medical necessity determination
  • Effective January 1, 2014, DHCS will adjust MCP capitation payments to include the expanded outpatient mental health services
  • MCPs continue to be responsible for the provision of mental health services within the scope of PCP practice. MCPs will also continue to be responsible for the arrangement and payment of all medically necessary Medi-Cal physical health care services, not otherwise excluded by contract, to MCP beneficiaries who require specialty mental health services.
  • If an MCP beneficiary with a mental health diagnosis is not eligible for MHP services because the adult beneficiary’s level of impairment is mild to moderate, or, for adults and children, the recommended treatment does not meet criteria for Medi-Cal specialty mental health services, then the MCP is required to ensure the provision of the outpatient mental health services listed or other appropriate services within the scope of the MCP’s covered services.
  • MCPs must also cover outpatient laboratory tests, medications (excluding those provided exclusively by county specialty mental health plans), supplies, and supplements prescribed by the mental health providers in the MCP network, as well as by PCPs, to assess and treat mental health conditions

 

CPCA RESOURCES

CPCA Letter to DHCS on CCBHC Planning

CPCA Behavioral Health Survey Results 2016

RESOURCES

 

CPCA Staff Contact

For questions please contact Allie Budenz, Associate Director of Quality Improvement at abudenz@cpca.org.


2017 Annual Sponsors