Tuesday, February 23, 2016

SIM’s CCIP proposal for Medicaid reform – poor process drives weak plan

Public comments from the CT Health Policy Project raise deep concerns about SIM’s proposal for Medicaid reform requirements could undermine hard-won successes in the program and may not achieve the goals. The Community and Clinical Integration Plan (CCIP) is SIM’s plan for community-based resources to support Medicaid advanced networks that will be sharing in savings under the evolving reform plan. While CCIP’s goals, to promote health equity among others, are important, independent advocates and other stakeholders have expressed concerns about the plan. The CCIP proposal imposes substantial costs on Medicaid provider networks without any source of funding. CCIP’s 66 pages of standards are too prescriptive in some places and too vague in others, creating a very large burden for already busy providers and undermining innovation and flexibility to serve local conditions. Consumers could get conflicting advice on how to manage their conditions from different sources. No evidence is given to support the effectiveness of CCIP’s standards. Unlike successful states, SIM is proposing that CCIP standards be required of Medicaid networks. However networks that don’t serve Medicaid members will not be affected. The proposal to have SIM and their vendor oversee the standards is also a concern. Because of a loophole in the law, SIM is not subject to the State Code of Ethics; concerns have been raised about SIM grants being awarded to SIM committee insiders in the past. Advocates and other stakeholders are urging delay allowing Medicaid stakeholders to consider the evidence, ensure CCIP is feasible, and ease the burden on providers.