Duals Demonstration/Coordinated Care Initiative (CCI) As Amended by May Revise
California State Legislature
Re: Duals Demonstration/Coordinated Care Initiative (CCI) As Amended by May Revise ? Concerns
The undersigned organizations have been active participants in the planning process for the Duals Demonstration Project, which was authorized by SB 208 (Statutes of 2010) as pilot programs in up to four counties. We have also written to oppose the Governor?s State Budget Proposal which proposed to expand the demonstration from four to ten counties as part of the Coordinated Care Initiative (CCI). In early May, several of our organizations individually gave input to the Department of Health Care Services (DHCS) and Department of Social Services (DSS) on our outstanding concerns regarding the State?s draft plan to the Centers for Medicare and Medicaid Services (CMS).
We continue to work collaboratively with the Administration and hope to see a demonstration which delivers on the potential for integrated funding and services for people who are dually eligible for Medi-Cal and Medicare. While we appreciate the proposed changes in the May Revision to delay implementation from January 1, 2013 to March 1, 2013 and to reduce the proposed expansion of pilots to eight counties, we must continue to oppose the CCI as it is proposed. We believe that the timeline and scope of the CCI as proposed in the draft plan has the potential to harm rather than help the participants.
Below we outline the major themes of our organizations? comments submitted on the State?s draft plan, many of which were identified in our previous letters to the Legislature and Administration. The Administration is currently vetting these and other issues raised by numerous stakeholders for inclusion into its final plan to CMS. However, given the number and scope of the issues raised, we urge the Legislature to articulate minimum readiness standards for the health plans in the four pilot counties and State departments to meet, which would address the issues noted below and improve the chances of meeting the goals in SB 208. These standards should be developed with input from stakeholders.
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August 3, 2018
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