RFA for BH/IDD Tailored Plan – What You Need to Know

A key indicator that Medicaid Transformation is back is the recent publication of the Request for Application (RFA) for the BH/IDD Tailored Plan. The Tailored Plan is scheduled to go-live on July 1, 2022, one year after the Standard Plan is implemented. And with all of the requirements in the RFA for physical health, it is clear that the BH/IDD Tailored Plan will be a major shift in service delivery and payment mechanisms for our system.

Only LME/MCOs can respond to the current RFA. More specifically, LME/MCOs can only respond initially for their current catchment area. Once those responses are received, NC DHHS will determine if there are “empty regions” or areas where either the current LME/MCO did not respond or NC DHHS did not accept the RFA from the current LME/MCO. At that point, NC DHHS will consider LME/MCOs that indicated willingness to take on “empty regions” by answering supplemental questions in the RFA. RFA responses are due back to NC DHHS by February 2, 2021.

Service Package

The BH/IDD Tailored Plan will encompass mental health, substance use disorders, intellectual-developmental disabilities, physical healthcare, pharmacy and unmet social needs. The benefit package for the Tailored Plan includes more intensive services than are offered in the Standard Plan for certain individuals with behavioral health and substance use disorder needs as well as the Innovation Waiver services for individuals with intellectual-developmental disabilities. The health care coverage and pharmacy benefits are the same as those served under the Standard Plan.

Care Management

A centerpiece of integrated care for both plans is the care management role.[AR1] Every individual in the BH/IDD Tailored Plan will be assigned a care manager and that will be a critical place where unmet social needs are identified for Medicaid beneficiaries. In the time between the implementation of the Standard Plan and the go-live date for the Tailored Plan on July 1, 2022, Medicaid beneficiaries who will be eligible for the BH/IDD Tailored Plan will not see a change in their services and will continue with the LME/MCOs and their current Medicaid structure for physical healthcare and pharmacy until the Tailored Plans go live.

Index of RFA Documents:

Document	Length of Document	Purpose
Request for Application due back to NC DHHS by 2/2/21	73 pages	Provides the overview of key components of the RFA
Scope of Services— Unified and Medicaid	254 pages	Enumerates requirements for both State-funded and Medicaid services.
Scope of Services – State-funded Services and Contract Performance	82 pages	Further specifies State-funded service requirements and focuses on contract performance requirements.
Attachments A-P	207 pages	Provides specifics around components such as required organization roles for the BH/IDD Tailored Plan, performance measures, provider adequacy, BH/IDD Tailored Plan authorization of State-facility services.
Attachment Q Application Response and Completed Attachments	118 pages	Detail on completion of the RFA. Includes supplemental questions on “empty regions”.
Medicaid Tailored Plan Draft Rate Book	244 pages	Considerations to determine costs and per member/per month capitation.

The Basics:

Some of the basic requirements of a BH/IDD Tailored Plan include:

A required BH/IDD Tailored Plan Operating Plan that is updated and submitted annually to NC DHHS;
Maintain Board and CFAC requirements per Chapter 122C;
Maintain NCQA accreditation;
A contract with a Prepaid Health Plan [to carry out responsibilities related to provision of physical healthcare services]
As a measure to ensure integrated care, BH/IDD Tailored Plans are not allowed to shift all risk of health care services to the PHPs and are expected to share savings;
Certain positions within the BH/IDD Tailored Plan are required to be located within North Carolina. Care managers, peer support specialists and complaint and grievance staff are a few of those positions.

NC DHHS will conduct readiness reviews of those LME/MCOs that receive contract awards, this is tentatively scheduled to occur six months after the award of the contracts. The goal is for each LME/MCO to be deemed to have the capacity to be a BH/IDD Tailored Plan. The readiness reviews could result in corrective action needed before the BH/IDD Tailored Plan implementation. The reviews could also possibly result in NC DHHS ending the contract.

Each BH/IDD Tailored Plan must offer certain service lines i.e. telephone numbers and they include:

Member and Recipient service line for both Medicaid and State-funded members;
Provider service line;
BH Crisis service line operating 24/7/365 for both Medicaid and State-funded members;
Pharmacy service line for Medicaid members only;
Nurse service line for Medicaid members only.

Required Community Engagement Strategies and Education and Outreach:

Tribal engagement strategy;
Engagement with Community and County Organizations for Medicaid and State-Funded Services including local health departments and social service departments, area agencies on aging, local housing, law enforcement, local systems of care programs, county magistrates;
Outreach to local public housing authorities and other organizations related to housing;
Continued coordination of the local community crisis services plan.

Medicaid Beneficiary Engagement:

Member/consumer engagement expectations are laid out in several sections of the RFA documents.

Transitions of Care: There are multiple provisions laying out the requirements of the BH/IDD Tailored Plan when an individual transitions from the Standard Plan to the Tailored Plan. The provisions (located in Section V—Scope of Services A-B beginning on page 59) incorporate requirements that ensure seamlessness for Medicaid beneficiaries. For example, there is special consideration for transition if the individual is already engaged with a care manager.

Systems of Care: The RFA incorporates the System of Care guiding principles via requirements for staff positions such as Family Partners and stakeholder engagement and community partnerships (located in Section V – Scope of Services A-B, page 50, 147 and page 167 begins the SOC section, and Scope of Services C and Section VI, page 39 begins the SOC section).

Provider and Network:

The Network Adequacy Plan must be submitted to NC DHHS within 30 days of the contract being awarded.
BH/IDD Tailored Plans will use contract templates with providers and the templates must be submitted to NC DHHS within 30 days of the contract being awarded.
Every BH/IDD Tailored Plan will have contracts with all State-operated facilities and the contract template between the BH/IDD Tailored Plan and the State-operated facilities will be provided by NC DHHS.

The release of the RFA puts NC DHHS into a “silent period” so as not to impact RFA responses. NC DHHS has indicated earlier that it is their intention to award the contracts with ample time to complete the readiness reviews and allow for data integration prior to the go-live.