While preparing for the rollout of the Pediatric Health Assessment Tool (PAT) in August 2012, Health Care Policy and Financing (HCPF) staff predicted that “…this is going to be ugly.”
When HCPF launched their new Medicaid Management Information System “The Colorado interChange”, for claims payment on March 1, 2017, for months providers complained of reimbursement problems threatening their financial sustainability and services continuation. HCPF reported the system underwent several hours of testing. However, the testing apparently did not catch a list of issues.
In July 2023 as HCPF launched a new IT system and Phase I Case Management Agency (CMA) transitions, Disability rights agencies such as Colorado Cross Disability Coalition and The Arc chapters predicted “…this is going to be ugly.”
July 2023, HCPF launched the Care and Case Management System (CCMS) which is said to be designed to take over the Benefits Utilization System (BUS), the electronic system used by Single Entry Point agencies. All community centered board case managers were provided training in the new system. Boots on the ground staff entered information into the new system but continued to rely on the BUS that provided additional detail and historical information in relation to each client that is not captured in the CCMS.
October 31, 2023, HCPF denied Single Entry Point leadership and staff access to the BUS.
November 1, 2023, Phase I CMA Transition for Denver, Adams, Aurora, Arapahoe and Douglas counties. Rocky Mountain Human Services (RMHS) became the case management agency for Denver and Adams Counties; the community centered board for Adams, North Metro Community Services closed; and Developmental Pathways (DP) became the single entry point for Aurora, Arapahoe, and Douglas counties. Some 4,000 clients were moved from RMHS to DP; all clients with intellectual and developmental disabilities that were served by North Metro were moved to RMHS. HCPF refused RMHS and DP bid to notify their clients of pending changes in case management. A letter from Health First Colorado was sent late September/early October to each client stating that their case management agency was changing. By the way, HCPF admits that because of zip codes crossing county lines, the guardian or authorized representative address vs. client’s physical address, some members were inadvertently electronically transferred to the wrong CMA. Nevertheless, the letter included the name of the new agency and said:
Changes to agencies will happen between now and July 1, 2024. You can expect to receive a letter with more information from your new agency about 4-6 weeks before your agency changes. If you are interested in using a different agency for your case management than the one listed above, please reach out to your current case management agency or case manager.
Late notice did not allow the CMA to provide any written information to clients. Instead, Phase I CMAs scrambled to call as many clients as possible to explain changes. Speaking with AdvocacyDenver clients, most do not remember receiving a letter from Health First Colorado. Many do not recognize this as an agency who shares important information, instead, they pay attention to notices from RMHS, DP or North Metro. Finally, some clients are frustrated or confused with the procedures to opt for a different case management agency. November 21, 2023, HCPF said:
The CMA is responsible for informing the member of their CMA including contact information. Outgoing CMAs were required to mail members a notification of their CMA changing and the incoming CMA receiving the member was required to send a welcome letter to the member. Agencies are still sending welcome letters to members currently.
HCPF asserts that each CMA was responsible to provide the new CMA with a list of member information that included pending case management tasks, including any financial eligibility concerns.
. . . to assist CMAs, HCPF is pulling data reports to ensure members are coordinated with their CMA and the agency is aware of the members’ identified 100.2 end date, prior authorization for services and financial redetermination status.
AdvocacyDenver questions whether complete information is included in the Care and Case Management System (CCMS) or whether more complete information is found in the Benefits Utilization System (BUS).
In response to a long list of questions/concerns submitted by metro advocacy agencies HCPF said:
Clients who are concerned their services were terminated inappropriately can file an appeal with the Office of Administrative Court and can continue to receive services during the appeal.
This response is inappropriate. That is, if a client’s services were terminated because of faults in HCPF’s rollout of Phase I CMA, their IT system and/or because a CCB closed their doors and failed to notify a client, HCPF must make it right. HCPF assumes that clients are in a position to file/forward an appeal because of HCPF’s failure to provide appropriate safeguards when implementing a conflict free case management system. AdvocacyDenver challenges HCPF to identify resources/peoplepower to support said clients in any appeal proceedings from start to finish. AdvocacyDenver challenges HCPF to examine their IT system, and review and modify their procedures so that Phase II and III communities have a smooth transition.