May 11, 2018
Thomas J. Betlach
Arizona Health Care Cost Containment System
801 E Jefferson Street
Phoenix, AZ 85034
Dear Administrator Betlach:
I write on behalf of the Arizona Public Health Association (AzPHA) – one of Arizona’s oldest and largest membership organizations dedicated to improving the health of Arizona citizens and communities. An affiliate of the American Public Health Association, our members include health care professionals, state and county health employees, health educators, community advocates, doctors, nurses and students.
Thank you for the opportunity to comment on your AHCCCS Contractors Operations Manuals for the upcoming October 1 Integrated Care Contracts. We have reviewed the proposed 400 Series Manuals and have comments on ACOM 436 (Minimum Network Requirements) and 417 (Appointment Availability, Monitoring and Reporting).
ACOM 436 Minimum Network Requirements
We applaud the Administration for applying measurable and verifiable standards for geographic network adequacy. We like the way the Administration is using a standard which includes a percentage of the members within both a discrete distance and time from a provider in the various categories. The percentages and distances for rural and urban areas seem reasonable. We encourage you to keep these types of easily measurable and verifiable standards in the final ACOM 436.
County public health departments support medical homes especially in under-served areas. Their core services include vaccinations, sexual transmitted disease testing and treatment, reproductive health, and tuberculosis prevention and control. These are services that patients are not always able or willing to access in their medical home. When county health departments are not a network provider, this critical health care infrastructure component is unavailable to members which can gave a substantial negative impact on community and member health. Please require your new integrated managed care plans to include Public Health departments in their health care provider networks.
This will ensure fairness in providing services to your members, provide revenue that enables county health departments to continue to serve their communities, and prevent taxpayers from paying twice for access to critical health services.
A key to making member choice meaningful requires contractors to be transparent about whether they are meeting Minimum Network Requirements. When contractors are out of compliance with the ACOM 436 Standard(s), we encourage the Administration to require contractors to disclose on their websites, newsletters and other member communication materials which standards they have not complied with and/or have requested exceptions from so that Members can take that information into consideration as they choose plans. This disclosure standard may need included in ACOM 404 for compliance purposes. The information should also be added to the AHCCCS enrollment websites
ACOM 417 Appointment Availability, Monitoring, and Reporting
We applaud the Administration for applying statistical methods and measurable and verifiable standards for regulating appointment availability, monitoring and reporting. We like the way the Administration is using a standard which includes an explanation of how sample sizes meet a 95% statistically significant confidence level including the calculations used to confirm the confidence level. We encourage the Administration to keep these criteria and the reporting template.
As with ACOM 436, we encourage the Administration to require contractors to disclose on their websites, newsletters, and other member materials which standards they have not complied with and/or have requested exceptions from so that Members can take that information into consideration as they choose plans. This disclosure standard may need included in ACOM 404 for compliance purposes. The information should also be added to the AHCCCS enrollment websites.
Will Humble, MPH
Arizona Public Health Association