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The client was looking for an experienced team who could assess the current pipeline of innovative therapies, examine current reimbursement policies to assess long-term compatibility with the adoption of innovative therapies and novel delivery mechanisms, and make policy recommendations to address any challenges identified through the process. HMA, The Moran Company, and Leavitt Partners, both HMA subsidiaries, were selected as the team with the needed expertise and capacity to create several deliverables. These deliverables were focused on the impact of the upcoming pipeline of certain innovative therapies on different payment systems, as well as working with the client’s team to develop and refine federal and state policy recommendations to address identified challenges.
Even before the COVID-19 pandemic, Indiana’s public health system, administered primarily at the local level, struggled to meet the state’s public health challenges. The pandemic further exposed the system’s deficiencies, as well as the geographic, racial, ethnic, and socio-economic disparities in health outcomes that exist across the state. Recognizing that the state can and must do better, Governor Eric Holcomb appointed a 15 member Governor’s Public Health Commission (“the Commission”) charged with examining the strengths and weaknesses of Indiana’s public health system and making recommendations for improvements.
The Commission held monthly meetings from September 2021 through July 2022. Its work was driven through the following six workstreams led by designated policy advisors who conducted research, engaged experts and stakeholders, and developed draft recommendations for the Commission’s consideration: 1) governance, infrastructure, and services, 2) public health funding, 3) workforce, 4) data and information integration, 5) emergency preparedness, and 6) child and adolescent health.
Like many states Colorado has historically struggled with a mixture of challenges relating to its public behavioral health system including funding issues, duplicate processes across multiple state systems, and the absence of a cohesive statewide strategy, which has proved increasingly problematic for Coloradans, especially those with complex needs. The state set out to create a system with a coherent vision and strategy that could provide high quality, equitable and accountable care to all Coloradans.
In 2019, Colorado Governor Jared Polis created a Behavioral Health Taskforce (BHTF) charged with evaluating and setting a roadmap to improve the state’s behavioral health system. The BHTF created a set of more than 200 recommendations that were both structural and programmatic in nature. The most significant structural change was a recommendation to create the Behavioral Health Administration (BHA)—a single accountable entity that would reduce fragmentation across sectors and programs and build a more strategic approach to ultimately improve behavioral health outcomes.
In early 2022 HMA and Wakely Consulting Group, an HMA Company, assisted multiple clients with their applications to participate in the new Centers for Medicare and Medicaid Services (CMS) Medicare Accountable Care Organization Realizing Equity, Access, and Community Health (ACO REACH) model program. The purpose of this model is to improve quality of care for Medicare beneficiaries through better care coordination and increased engagement between providers and patients including those who are underserved. ACOs and participating providers are held responsible for patients’ total cost of care and must meet certain quality metrics. In return, they have more flexible payment arrangements, can achieve shared savings, and can provide additional services such as telehealth, home-based care, and more options for post-acute care.
This week, our In Focus highlights a Leavitt Partners white paper, The Impact of the 340B Program on Drug Prices Charged by Manufacturers and Covered Entities, published in November 2022. Leavitt Partners examined publicly available resources to determine the 340B Drug Pricing Program’s (340B) impact on drug prices charged by both covered entities and pharmaceutical manufacturers. To answer these questions, Leavitt Partners undertook a comprehensive literature review of publicly available governmental reports, peer-reviewed journal articles, white papers, news articles, and other publicly available sources to identify the degree to which, and to what extent, the 340B program may impact drug prices. To supplement this literature review, Leavitt Partners also conducted interviews with ten subject matter experts representing the perspectives of covered entities (including Federally Qualified Health Centers, Ryan White Clinics, and Disproportionate Share Hospitals) and drug manufacturers, as well as the analysis of health economists and academic researchers.
Insights/Key Findings:
The 340B program is a mandatory program for pharmaceutical manufacturers wishing to participate in the Medicaid drug rebate program. Today, the program has more than 53,000 participating covered entities and the total amount of drugs purchased at the 340B ceiling price under the program is almost $44 billion (Drug Channels).
Drug list prices, like other prices in health care, are increasing. The research for this white paper suggests that 340B is one of many factors putting upward pressure on launch prices.
Covered entities can generate savings from the prices charged for 340B drugs. There are no requirements for hospitals for how they use the savings, so pricing for services vary.
Lack of comprehensive data across the program limits insights on pricing and discount strategies.
This week, our In Focus reviews the Oklahoma Medicaid managed care SoonerSelect Program request for proposals (RFP) and the SoonerSelect Children’s Specialty Program RFP released by the Oklahoma Health Care Authority (OHCA) on November 10, 2022.
Background
Oklahoma currently does not have a fully capitated, risk-based Medicaid managed care program. The majority of the state’s 1.3 million Medicaid members are in SoonerCare Choice, a Primary Care Case Management (PCCM) program in which each member has a medical home. Other programs include SoonerCare Traditional (Medicaid fee-for-service), SoonerPlan (a limited benefit family planning program), and Insure Oklahoma (a premium assistance program for low-income people whose employers offer health insurance).
Prior efforts to transition to Medicaid managed care have encountered roadblocks, starting in 2017 with a failed attempt to move aged, blind, and disabled members to managed care.
More recently, in June 2021, the Oklahoma Supreme Court struck down a planned transition of the state’s traditional Medicaid program to managed care, ruling that the Oklahoma Health Care Authority does not have the authority to implement the program without legislative approval.
Contracts had been awarded to Blue Cross Blue Shield of Oklahoma, Humana, Centene/Oklahoma Complete Health, and UnitedHealthcare. Centene/Oklahoma Complete Health also won an award for the SoonerSelect Children’s Specialty Program.
In May 2022, Governor Kevin Stitt signed a new Oklahoma law to implement Medicaid managed care by October 1, 2023.
SoonerSelect RFP
Oklahoma will award contracts to at least three entities to provide medical, behavioral, and pharmacy coverage to nearly one million eligible children, pregnant women, newborns, parents and caretake relatives, and the expansion population. However, enrollment in these populations is expected to drop following the end of the public health emergency (PHE).
At least one of the contracts may be awarded to a provider-led entity (PLE). PLEs would need to provide proof that a majority of their ownership is held by Oklahoma Medicaid providers or the majority of the governing body is composed of individuals who have experience serving Medicaid members and are licensed providers. PLEs would also be able to bid on urban regions if the PLE agrees to develop statewide readiness within a timeframe set by the OHCA. If no PLEs meet OHCA standards, Oklahoma can choose not to award a PLE.
Goals of the program will include:
Improve health outcomes for Medicaid members and the state as a whole
Ensure budget predictability through shared risk and accountability
Ensure access to care, quality measures, and member satisfaction
Ensure efficient and cost-effective administrative systems and structures
Ensure a sustainable delivery system that is a provider-led effort and that is operated and managed by providers to the maximum extent possible.
Timeline
Proposals will be due on February 8, 2023, and contract implementation is scheduled for October 1, 2023. The contract is expected to run through June 30, 2024, with five, one-year options.
Evaluation
Bidder’s technical proposals will be scored out of a total 1550 points. OHCA will award PLEs an additional 50 points for qualifying, bringing the total up to 1600 points. OHCA may also choose to conduct oral presentations for an extra total of 50 points.
SoonerSelect Children’s Specialty Program RFP
Oklahoma will select one of the awarded SoonerSelect plans for a separate statewide contract to provide comprehensive integrated health coverage to foster children, former foster children up to 25 years of age, juvenile justice-involved children, and children receiving adoption assistance. Contract terms will be the same as the main SoonSelect procurement, running from October 1, 2023, through June 30, 2024, with five one-year renewal options.