Medicaid Redesign Team Releases Draft RFQ for Health and Recovery Program

On December 9^th, the Department of Health (“DOH”), the Office of Mental Health (“OMH”), and the Office of Alcoholism and Substance Abuse Services (“OASAS”) released a Request for Information (“RFI”) and a draft Request for Qualifications (“RFQ”) for Health and Recovery Programs (“HARPs”) as part of the efforts of the Behavioral Health Workgroup of the Medicaid Redesign Team (“MRT”). The RFI and RFQ provide the first opportunity to understand how the MRT plans to change behavioral health care through HARPs within New York State.

The RFI and RFQ are available online (linked here) and are currently in a comment period, meaning an interested party or stakeholder can submit his or her comments to DOH for consideration in the finalized RFQ, until January 10, 2014. The comments are due in early January so that they can be presented to the Behavioral Health Workgroup of the MRT, which can then finalize and release the final RFQ by February of 2014. The meeting in which the comments will be presented to the workgroup will be open to the public, but the meeting time and place has yet to be set. These activities are in preparation for a January 2015 launch date of the HARP program in New York City and a July 2015 launch date in the rest of the state. 

HARPs have been described as “SNPs (Special Needs Plans) plus,” insofar as they aim to incorporate managed care and supporting behavioral health services into one delivery system. In a seminar hosted by DOH, OMH, and OASAS (the slides for which will be posted at the above link) the speakers stressed the importance of HARPs providing an integrated delivery system, in which physical and behavioral health are addressed as seamlessly as possible for the patients within the program. The other integral part of HARPs, the “plus,” are described as “1915i-like services.” These are community-based services designed to help individuals in the program return to or become active members of the community to complement their behavioral health treatment. 1915i-like services include psychological rehabilitation services, community psychiatric support, habilitation services (described as providing skill sets to individuals who have not had the opportunity to learn them), crisis intervention programs, education and employment support, peer support services, and self-directed services. The provision of these services in addition to the physical and behavioral health services are designed to achieve the goal of complete care for the highest-risk behavioral health patients in New York.

HARPs plan to enroll especially high-risk patients. Any adult with a substance abuse diagnosis or severe mental illness and who is otherwise eligible for a “mainstream” MCO is eligible to enroll in a HARP (note, however, dual Medicare/Medicaid beneficiaries are not) if they meet certain risk factors or if they are identified by a service provider to have serious functional deficits, as determined by an eligibility screening. Some risk factors include 30 days of psychiatric inpatient services in the last three years, three or more psychiatric inpatient admissions in the last three years, discharge from a correctional facility with a history of behavioral health treatment, two or more services at a chemical dependence detoxification program in the last year, and other similar criteria as described in the RFQ. In addition to these risk factors, potential enrollees will have to meet need-based criteria for 1915i-like services in order to be eligible for HARP enrollment.

To participate in HARPs, behavioral health providers will likely need to partner with managed care organizations to provide the complete continuum of care that the program seeks to provide. While DOH, OMH, and OASAS have stated they are willing to accept a wide variety of applicants and criteria in the RFQ (and the RFQ specifically allows for alternative acceptance criteria), it will likely be too difficult for an entity that currently solely provides managed care or behavioral health services to effectively and competently run a HARP program in the manner in which DOH, OMH, and OASAS sees the HARP program working. While the deadline for the final RFQ applications have not been set, entities looking to participate in the HARP program should begin to consider finding managed care organizations or behavioral health providers to partner with now, as the RFQ application period will likely open with the release of the final RFQ in February.     

In addition to preparing to apply under a final RFQ, stakeholders should consider commenting on the draft RFQ. While the period for comments is short (again, the comments are due by January 10, 2014), the comment period will allow those interested in participating in the program to contribute to the guidelines of the program that they must apply to and operate under in the future. As the HARP model is novel within the state, DOH, OMH, and OASAS have expressed their desire to receive and address as many comments as possible in the comment period.

Updates will follow as DOH, OMH, and OASAS continue to develop the HARP program and release the final RFQ.