The “Great Lakes State” is the latest to ink an agreement with CMS for a demonstration project, called MI Health Link, aimed at integrating care for people with both Medicare and Medicaid (dual eligibles). The Michigan Memorandum of Understanding (MOU) describes an unusual and somewhat complex approach in which health plans, called Integrated Care Organizations, or ICOs, will work with long-established behavioral health organizations in Michigan, called Prepaid Inpatient Health Plans (PIHPs), to jointly improve care for dually eligible individuals. The MOU outlines the terms of what will eventually be a three-way contract between the federal government, the state and selected ICOs. Michigan advocates have worked for over two years to make sure the demonstration is structured in the best interests of consumers, and that effort has paid off in many ways.
In particular, the focus on “person-centered planning” in the MOU is a direct result of persistent advocacy efforts, especially by advocate RoAnne Chaney, with the Michigan Disability Rights Coalition. The person-centered planning process will be used to develop enrollees’ care plans, and will help honor enrollees’ personal goals and preferences, while maximizing their independence. In addition, ICOs will have to ensure adequate investment in ICO staff training on the person-centered planning process to assure competency in how it is used. Also, advocates worked hard to gain the inclusion of a requirement that each ICO assemble a diverse consumer advisory board and create a process for ensuring that the advisory board’s recommendations are shared with the ICO’s governing board. This approach to consumer engagement holds the promise of obtaining ongoing, meaningful feedback from enrollees to continuously improve the delivery system.
Still, as with other states’ demonstration projects, “the devil is in the details.” And there are still a lot of details to get right, as surveyed in this fact sheet. For instance, advocates have concerns that upfront expectations of savings put ICOs – and therefore beneficiaries – at too great a risk. This concern is compounded by the use of broad Medicaid rating categories that leave room for adverse risk selection.
The biggest concern of advocates in Michigan is whether the selected ICOs will pass readiness review, and then have the capacity to seamlessly coordinate with the PIHPs. For some of the ICOs, providing medical services to the dually eligible population is not all that new. However, assuming responsibility for the long-term services and supports (LTSS), as well as the obligation to coordinate with PIHPs on the behavioral health issues is new. Advocates remain anxious about the ICOs’ ability to ensure that benefits like self-determination (also called consumer directed care) will be respected and that crucial provider relationships will not be disrupted.
The Michigan MOU signifies a cautious step in the right direction. But the hard work starts now. The readiness review process and details of the three-way contract will be important to watch. Ongoing, transparent collaboration among the state, plans, providers and consumers, and their advocates will be vital.