To be successful, we must acknowledge and overcome our own tendency to resist change, and we need to accelerate our pace when we accept that we must change.
We must also examine the degree to which our field has been underresourced and underfunded when required to change. With the right resources and demands on us for accelerated change processes, we can, in fact, deliver in the fast lane. We can’t afford a repeat of the Health Information Technology for Economic and Clinical Health Act under the American Recovery and Reinvestment Act of 2009, which overlooked the technology needs of our field while allocating billions for physician, clinic, and hospital electronic medical record systems.
The Impetus for Vertical and Horizontal Collaboration
If MHPAEA has taught us anything, it is that regulations and stakeholders’ responses to them can be difficult to predict. Consequently, new and perhaps anxious conversations need to begin taking place among interdependent stakeholders that haven’t historically found it necessary to collaborate very closely. On the vertical, that means federal, state, county, health planissuer, and provider organizations must work together in the pursuit of alignment. On the horizontal, agencies such as Medicaid and state departments of insurance, mental health, substance abuse, family and children’s services, and juvenile justice will be called on to collaborate. Hospitals, primary care providers, and employers play vital roles in this horizontal collaboration as well. Each has an important part in the emerging paradigm.
In the case of MHPAEA, for example, states must first conduct a “cross-walk” that compares and contrasts state and federal regulations. The resulting regulatory guidance must make its way to local health plans and managed care organizations, which then need to communicate new benefits and processes to their brokers, customers, employers, providers, and plan members.
Ours is a system with many moving parts, and each has to be accounted for in our planning and execution. The field depends on the direction, planning, and resources that radiate out from federal, state, and county agencies, whose internal “revolution” in change management is absolutely essential to the field. The manner in which Medicaid and Medicaid managed care plans, as well as Section 1115 waivers, are dealt with both vertically and horizontally is a good example of the communication challenge and procedural complexity ahead.
The most pressing needs right now are organizational and procedural, centered around ensuring the vision and intent of lawmakers. Those priorities include the following:
- Convening stakeholders from federal, state, and county mental health and substance use disorder programs to develop new relationships, a shared vision, a robust communication plan, and comprehensive plans of action.
- Providing leadership regarding the impact of MHPAEA and PPACA on state plans, Section 1115 waivers (among others), the continuity of the safety net, and the purpose of block grants in the future.
- Delivering technical assistance concerning the impact of MHPAEA and PPACA on the prevention of, treatment of, and benefit coverage for mental health and substance use disorders.
- Comparing and contrasting state and federal laws and regulations to provide adequate guidance to the state insurance commissioners and the health plans they regulate.
- Disseminating similar guidance to self-insured employers (Employee Retirement Income Security Act of 1974 groups) and their plan administrators.
- Standardizing and normalizing terms; data definitions; data collection practices; screening and assessment tools; treatment planning; patient placement criteria; and billing, claiming, and coding and reporting everything from encounters to outcomes.
- Accelerating procurement processes to enable federal, state, and county agencies to more swiftly execute their action plans.
- Properly defining comparative effectiveness, quality, and value initiatives in the reformed paradigm, and planning to build capacity and competency for each.
- Realigning financial incentives between payers and providers in public and private sectors while fashioning innovative reimbursement reforms that lead rapidly to the formation of accountable care organizations and the creation of bona fide value.
- Adequately financing the infrastructure and capacity required by reforms, including professional project management resources, workforce, and business architecture dimensions. Financing must address serious gaps in workforce and technology.
Federal departments understand that they are responsible for providing the field with guidance through the change process. All of these reforms require clear regulations and the tools to make them part of procedures.
MHPAEA and PPACA represent ideals and intentions for health and behavioral health that will require sacrifice, prioritization, joint agreements, planning, andabove allaction. What we need now are vision, leadership, and management resources.
[Extracted from National Council Magazine, 2010, Issue 2]