In an analysis of stakeholder comments on the California Department of Health Care Services (DHCS)’s Medi-Cal Managed Care Draft RFP, the California Health Care Foundation (CHCF) found one of the most prominent themes to be a lack of completeness and clarity.
CHCF invited stakeholders to share the comments they submitted to DHCS during the state’s 30-day public comment period for the draft RFP following its release on July 1. It received 19 responses, representing the perspectives of over 500 organizations.
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Beth Waldman, JD, senior consultant at Bailit Health, categorized and summarized some of these comments in a CHCF webinar last week. She explained that many stakeholders voiced concerns about gaps in the RFP, including missing information about CalAIM, health equity requirements, and the Children and Youth Behavioral Health Program — a significant provision in this year’s budget agreement.
“We know these new requirements are out there, they’re just not necessarily in the RFP or model contract as it stands today.”
Waldman said the comments also requested that DHCS offer stakeholders an opportunity to review the questions it uses to evaluate procurement candidates. In response to a lack of detail on these questions in the RFP, stakeholders suggested evaluation methods for DHCS to use, such as scoring plans on specific criteria like their coverage of wellness visits for children.
“Many commenters that we reviewed had some suggestions about what potential RFP evaluation questions could be and what the scoring could be … That kind of detail isn’t in the draft RFP at all. There’s not evaluation questions for people to reflect on. But many did give DHCS some food for thought in terms of what those topics might be.”
Another issue raised by stakeholders is that the RFP doesn’t address all of the Medi-Cal Managed Care Plan (MCP)’s obligations. These include DHCS’s stated intent to require the sharing of clinical and claims data from all MCPs and providers, already existing requirements for things like abortion care, and details about audits.
Other examples of missing MCP requirements include strategies to improve care coordination and including community health workers in MCP care coordination. They also requested that All Plan Letters (APLs) be incorporated into the contract.
Stakeholders want DHCS to address these gaps and reissue the RFP for further review before it’s finalized and released at the end of 2021. Linnea Koopmans, CEO of Local Health Plans of California, also spoke during the webinar, emphasizing these missing elements and calling for further opportunities for stakeholder review of the full RFP before its release.
“…[There are] a lot of important things missing. CalAIM, enhanced care management, ILOS [in lieu of services], population health management … I think although DHCS has indicated they’ll have plan and stakeholder feedback through the policy process and development of APLs, and guidance outside of the contract, I don’t think that’s a replacement or a substitute for a full review of the draft contract.
We think that it’s really important that DHCS have a transparent and collaborative process to review the draft contract in its entirety and not just the components that were shared with us in June.”
Some are worried the department won’t offer any further opportunities for stakeholder input before the RFP is finalized. Kiran Savage, executive director of the California Pan-Ethnic Health Network — one of the organizations that submitted its comments to CHFC — told State of Reform she’s concerned about the lack of future stakeholder engagement in the process.
“They [DHCS] are not planning to have any other opportunity for stakeholder feedback, which means that we will have no opportunity to comment on those very substantive sections of the RFP.”
Following DHCS’s intended release of the final RFP at the end of 2021, it plans to spend 2022 and 2023 reviewing proposals from contractors, and will reward a final contract in 2024.