Mercer Report: MH/DD/SAS far from ready for waiver oversight

An organizational review of the state division responsible for the oversight of statewide Medicaid waivers for mental health, developmental disability and substance abuse services found the division acutely unprepared for that oversight role.

Despite findings of the report that warn of ineffective and inefficient oversight, the Department of Health & Human Services has announced plans to forge ahead with plans to implement the waivers statewide.

Released last August, the report from Mercer Consulting found DHHS’s Division of Mental Health, Developmental Disabilities, and Substance Abuse Services with significant needs in staff training and IT infrastructure, key positions that were vacant, and the need to develop a vision, guidelines, policies and procedures for monitoring new waiver entities. (A summary of findings begins on page 16 or the report, with recommendations on page 19.) 

The Division contracted with Mercer for the study to help it cope with the increased responsibilities that statewide implementation would mean.

Among key recommendations:

• Establish a Quality Management Section headed by a Director of Quality Management, institute a cross-Divison QM committee and develop an annual QM plan for the Division. Presently, the Division is served by a Quality Management Team under the Community Policy Management Section, a team Mercer reports has been kept busy since 2005 primarily collecting data and reporting information instead of quality management. The Division’s LME Performance Teams also reported they were not adequately staffed to conduct regular quality reviews. Because the Division does not provide regular quality review of Local Management Entities, LMEs are usually in charge of their own reviews.

• Train staff. “Division staff do not receive training which would enable them to develop skills necessary for waiver program oversight … . Furthermore, they believe, if training were available, current workloads would prevent them from participation.”

• Perform an IT assessment of the current system. The report states: “Even when the Division is able to collect useful performance data, outdated information technology hampers the timely use of the data … . The Information Technology (IT) infrastructure is archaic and knowledgeable staff are worried that significant component failure could occur at any time. In order to perform waiver oversight, the IT system needs to be able to produce accurate and timely reporting.” LMEs often have more advanced IT than the Division, the report says, meaning the Division is not able to provide standards or assistance, resulting in a hodgepodge of information systems.

• Standardize policies and protocols for monitoring LMEs. “Implementation of additional waiver entities without standardization of policies and procedures, will result in ineffective and inefficient oversight.” “Many areas within the Division have individual components of waiver oversight but that there doesn’t appear to be an overall plan that is understood throughout the organization.”

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