Los Angeles County€¦ · The Los Angeles County Mental Health Plan (MHP) has reviewed the State...
Transcript of Los Angeles County€¦ · The Los Angeles County Mental Health Plan (MHP) has reviewed the State...
Los Angeles County
DEPARTMENT OF MENTAL HEALTH JONATHAN E SHERIN MD PhD
DIRECTOR
April 26 2018
Ms Brenda Grealish Acting Deputy Director Mental Health and Substance Use Disorder Services Department of Health Care Services 1500 Capital Avenue Sacramento CA 95814
Dear Ms Grealish
The Los Angeles County Mental Health Plan (MHP) has reviewed the State Department of Health Care Services (DHCS) Draft Medi-Cal Managed Care Quality Strategy Report Thank you for allowing us to comment We offer the following recommendations
Maintain consistency
bull Align DHCS and External Quality Review Organization (EQRO) quality metrics The Performance Outcome System (POS) uses a different methodology compared to EQRO One common metric to track for quality improvement and to compare against other MHPs and Statewide numbers (pg 22 Quality Metrics and Performance Targets) is best Use consistent language For example replace QI Work Plan (QIWP) with terminology from the System Review Protocol Quality Assessment and Performance Improvement (QAPI) Work Plan (pg 26 Performance Improvement Activities)
ClarifyElaborate
bull Further define certain concepts For example under Quality Metrics and Performance Targets (pg 22) a description should be provided of how Expenditures and Service Quantity per Beneficiary will be used as a metric for performance and quality tracking Higher expenditure and greater service quantity do not always indicate quality services unless they are tied to clinical outcomes When discussing metrics related to care coordination between MHPs and the child welfare system (pg 23) specify whether SMHS refers specifically to assessment and whether services refers only to treatment or can include targeted case management or even community outreach services Specify whether days represents business days or calendar days or is defined differently depending on context
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Ms Brenda Grealish April 26 2018 Page Two
AddModify
bull Include additional conceptsterms or modify existing ones For example include beneficiary satisfaction to the metrics that might be targeted by a non-clinical PIP (pg 22) Community level metrics are currently not outlined engage stakeholders in developing these metrics (pg 24) and indicate all age categories and groups (eg youth youth family adult and older adult) that are the focus of the satisfaction surveys that are part of the Performance Dashboards discussed on pg 25
Other Recommendations
bull Include MHP Ethnic Services Managers and Quality Improvement Leads when developing certain reports and analyses such as the report referenced on pg 24 to identify populations disproportionately affected by mental health conditions and disparities in access to SMHS and the analysis of mental health disparities across the State referenced on pg 39 Engage community stakeholders in developing community level outcomes (pg 24) Leverage quality indicators reported elsewhere to fulfill requirements of the Performance Dashboard such as addressing Dashboard translationinterpretation capabilities with Language Line Utilization data for Final Rule Network Adequacy (pg 25) Involve MHPs in developing and implementing a more robust and intensive QIWPQAPI evaluation process (pg 27) Provide a sample ulturally and Linguistically Appropriate Services (CLAS) Plan template or outline (pg 38)
Originally Signed by
Jonath E Sherin MD PhD Director
JESBBcm
c Dina K Gonzales Chief DHCS Curley Bonds MD DMH Bradley Bryant DMH Gregory Polk DMH Terri Boykins DMH
Ms Brenda Grealish April 26 2018 Page Two
AddModify
bull Include additional conceptsterms or modify existing ones For example include beneficiary satisfaction to the metrics that might be targeted by a non-clinical PIP (pg 22) Community level metrics are currently not outlined engage stakeholders in developing these metrics (pg 24) and indicate all age categories and groups (eg youth youth family adult and older adult) that are the focus of the satisfaction surveys that are part of the Performance Dashboards discussed on pg 25
Other Recommendations
bull Include MHP Ethnic Services Managers and Quality Improvement Leads when developing certain reports and analyses such as the report referenced on pg 24 to identify populations disproportionately affected by mental health conditions and disparities in access to SMHS and the analysis of mental health disparities across the State referenced on pg 39 Engage community stakeholders in developing community level outcomes (pg 24) Leverage quality indicators reported elsewhere to fulfill requirements of the Performance Dashboard such as addressing Dashboard translationinterpretation capabilities with Language Line Utilization data for Final Rule Network Adequacy (pg 25) Involve MHPs in developing and implementing a more robust and intensive QIWPQAPI evaluation process (pg 27) Provide a sample ulturally and Linguistically Appropriate Services (CLAS) Plan template or outline (pg 38)
Originally Signed by
Jonath E Sherin MD PhD Director
JESBBcm
c Dina K Gonzales Chief DHCS Curley Bonds MD DMH Bradley Bryant DMH Gregory Polk DMH Terri Boykins DMH