California's Medicaid program, Medi-Cal, currently operates separate managed care delivery systems for behavioral and physical health services under federal Medicaid waiver authorities. The program excludes most mental health and substance use disorder services from its contracts with Medi-Cal managed care plans and makes those services available through county- operated mental health plans (MHPs) and Drug Medi-Cal program contracts. These separate delivery systems operate under distinct statutory and regulatory authorities, and the contractors and their network providers are subject to differential standards developed over decades in the context of separate programs. The programs are also reimbursed and financed differently, with the Medi-Cal managed care plans placed at risk for the cost of services, and the county programs reimbursed through cost-based structures. The separateness of the delivery systems creates challenges to achieving administrative and financial integration of physical and behavioral health services in Medi-Cal. In February 2019, the California Health Care Foundation and Well Being Trust published Behavioral Health Integration in Medi-Cal: A Blueprint for California, which addressed the benefits of assigning responsibility for Medi-Cal's behavioral and physical health services to a single accountable entity, thereby creating opportunities for integration of care. To help identify potential paths forward, this article explores different contracting structures through which a county could lead efforts to create such an accountable entity. One option is for a county to work with the state and a Medi-Cal managed care plan to have the plan designated as the local MHP or Drug Medi-Cal program contractor. State laws governing the MHPs and the Drug Medi-Cal program were designed to default contracts to counties, but in the absence of a county contract--for example, if the county terminates or declines to renew its contract--the laws also permit a contract to be awarded to a qualified nongovernmental entity. Alternatively, a county could achieve a similar result by electing to delegate its responsibilities under its MHP or Drug Medi-Cal contract to a qualified Medi-Cal managed care plan. The integration of physical and behavioral health could also be approached from the other direction--by granting new authority for a county to opt to cover physical health services as a supplement to its existing behavioral health services contracts. For example, a county could agree to serve as a Medi-Cal "specialty health plan" responsible for comprehensive health services for a designated patient population (e.g., those currently receiving Drug Medi-Cal services or specialty mental health services through the county). This result could be achieved either by having the county enter into a new Medicaid managed care plan contract with the California Department of Health Care Services that would be in addition to other plans currently operating in the county, or by having the county enter a subcontract with one (or more) of those plans to provide coverage for a subset of the plan's enrollees. Each of these options potentially can be pursued consistent with existing law through the execution of voluntary contractual agreements. In most cases, in addition to having both a county that would initiate the effort and a willing Medi-Cal managed care plan, success would require the approval and participation of the state Medi- Cal agency--the California Department of Health Care Services (DHCS)--and the approval of the federal Centers for Medicare and Medicaid Services (CMS). Integration would also require a number of important decisions about what legal, fi and operational standards apply to the accountable entity. In the sections that follow, we identify potential paths forward and highlight some key legal and operational issues.
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