A Hybrid Funding and Coverage Model to Ensure Universal Access to Mobile Crisis Services
Patricia Boozang, Sabrina Corlette, Ashley Traube, and JoAnn Volk, Manatt Health and Georgetown University’s Center on Health Insurance Reforms
COVID-19, the resulting behavioral health crisis (including those related to mental health and substance use disorders), and calls for law enforcement reform related to behavioral health crisis response have heightened the urgency among federal, state, and local policymakers to expand access to behavioral health crisis services. Recently, the federal government has provided new funding opportunities to states to improve access to behavioral health crisis services, including mobile crisis services. The American Rescue Plan Act of 2021 (ARP) gives states the option of covering community mobile crisis intervention services in Medicaid for five years beginning in April 2022 (see here for additional information on the ARP mobile crisis option).
As states review the opportunities available to begin, enhance, or expand mobile crisis intervention services under ARP, policymakers may further consider a hybrid funding model that provides mobile crisis providers with a consistent and steady stream of funding to ensure they are able to maintain 24/7 availability and respond in a timely manner to all individuals in crisis, regardless of insurance status. Such a new model for funding mobile crisis services could also be designed to hold payers accountable for covering mobile crisis services when their enrolled members use this essential resource. This issue brief presents a sustainable, hybrid coverage and funding approach for mobile crisis services where mobile crisis providers would obtain:
A set amount or base funding that allows them to maintain continuous coverage; and
Third-party insurance reimbursement for services rendered to commercially covered individuals and Medicaid
enrollees.
On January 27, 2023, the Centers for Medicare & Medicaid Services released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” The SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible. This expert perspective reviews the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter.
On January 26, 2023, the Centers for Medicare & Medicaid Services approved California’s request to amend the California Advancing and Innovating Medi-Cal Section 1115 demonstration. This expert perspective describes the amendment, a centerpiece of which is approval for California Medicaid to provide a targeted set of Medicaid services to youth and adults in state prisons, county jails, and youth correctional facilities for up to 90 days prior to release. By providing re-entry services to Medicaid-enrolled individuals who are incarcerated, California aims to build a bridge to community-based care for justice-involved enrollees, offering them services to stabilize their physical and behavioral health conditions and establishing, prior to release, a re-entry plan for their community-based care.
On January 23, 2023, the Federal Communications Commission issued an important ruling that provides states with new flexibility to support enrollee outreach and communication efforts as part of their processes to unwind the Medicaid continuous coverage requirement. The ruling permits state agencies and their partners to send text messages and make phone calls to individuals about enrollment-related issues not only for Medicaid but for other state-run health insurance programs, including marketplace coverage. This expert perspective reviews the ruling and implications for states.
