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American Association of Community Psychiatrists
Position Paper on
Standards of Quality Management in Implementing Public
Sector Managed Care Systems Introduction
The introduction of managed care into mental health
delivery systems has represented a dramatic transformation of the
organization and payment methodology for mental health services. In the
private sector, managed care initiatives have offered the promise of
controlling escalating costs without compromising quality. The perception
of success in the private sector has led to increasing pressure to develop
managed care initiatives in the public sector.
The emergence of public sector managed care (PSMC) offers
the opportunity for creativity and flexibility in program and system
design, as well as the potential for more efficient utilization of scarce
public funds. At the same time, PSMC may pose great dangers. Unlike the
private sector, public mental health and substance abuse expenditures,
while at times inefficient, have never been excessive. Unfortunately,
public payers, struggling with diminishing budgets, may view PSMC as an
opportunity to reduce already inadequate funding without sufficient
guarantees of quality. This can seriously jeopardize clinical outcomes for
public patients, who are relatively powerless to voice their concerns or
have much influence on policy or funding decisions. This can be compounded
by the willingness of managed care organizations, (MCOs), seeking new
markets, to accept and implement underfunded contracts. In some states and
regions these negative outcomes have already occurred or are beginning to
be realized.
The AACP supports the development of PSMC, but only as a
method for more efficient utilization of scarce resources to improve the
quality and outcome of care. However, currently available methodologies
for measuring performance of managed behavioral health systems (e.g. PSMC,
HEDIS, JCAHO-ORYX) are woefully inadequate. We believe more comprehensive
quality management systems are a necessity.
We have carefully examined
numerous PSMC initiatives and have identified key variables that contribute
to or detract from quality outcomes. Based on this analysis, we have developed
the following standards for quality management in PSMC systems. These
standards are not simply statements of principle. They are intended to be
measurable indicators by which any individual or entity can determine
whether an adequate structure for quality management is in place prior to
the implementation of any PSMC contract.
PSMC Quality Standards
1. Consistency of Funding.
In order to ensure that fiscal constraints do not jeopardize
quality during the implementation of a new PSMC system, service
funds must be maintained constant during the first year and
until quality adherence in the new system is demonstrated.
2. Measurable Indicators.
All PSMC initiatives must define a set of measurable quality
indicators to define program objectives.
3. Comprehensive Quality Monitoring.
These indicators must cover, at minimum, the following areas
that relate to the structure, process, and outcome of care in
the PSMC system:
- Access to Care:
Size, availability, and composition of provider network
Caseload sizes and waiting lists
Availability of crisis services
- Continuity of Care:
Preservation of existing community treatment
relationships and support systems
Availability of case management services for
high-risk, high-utilizer children and adults
Linkages between outpatient and inpatient services
- Comprehensivness and Appropriateness of Care:
Comprehensive continuity of services for all ages,
diagnoses, and levels of complexity
Flexible benefit design to encourage utilization of
alternative service models including a comprehensive array
of psychotherapeutic and psychopharmacology modalities
Treatment in the least restrictive and most therapeutic
setting
Adequacy of formulary and laboratory services and
resources
- Responsiveness of Care:
Documentation of consumer and family involvement in
treatment planning
Adherence to appropriate consumer rights policies
Monitoring use of restraint, seclusion, and
involuntary treatment
Cultural competence in services as defined by
ethnically and culturally specific indicators
- Integration of Care:
Mental health and addictions services
Mental health and primary care services, including
health promotion and disease prevention
Child/family mental health and child/family social
and educational services
Mental health and community support and rehabilitation
services, including psychosocial rehabilitation,
housing, and vocational supports
Mental health and corrections services
- Outcomes of Care:
Measure of clinical outcomes, including quality
of life
Relapse and rehospitalization rates
Adverse incidents monitoring
Consumer and family satisfaction surveys
4. Adherence to National Standards.
The program design and quality measures must reference one or
more existing standards for PSMC and clarify and demonstrate
adherence to those standards.
5. Inclusive Governance.
All systems must have inclusive governance, through a
structured and empowered accountability system in the form of
an oversight board or similar entity, with representation of
consumers, families, providers, and other advocacy groups.
6. Empowered Quality Monitoring.
The oversight group should have the authority to approve the
quality standards for monitoring quality data and to require
corrective action to address identified quality deficiencies.
7. Grievance and Appeals Process.
There must be a well-defined grievance and appeals process
which can promptly and effectively evaluate adverse incidents
and resolve disagreements that occur between the managed care
organizations and consumers and/or providers. There must be an
independent ombudsman's office to act as final arbiter of appeals,
as only an independent agency can equitably rule on quality care
issues without conflict of interest.
8. Effective Management Information Systems.
The information system should effectively capture clinical data
to utilize for quality and outcomes monitoring, while preserving
client confidentiality.
9. Independent Program Evaluation.
In addition to the internal QM system, there should be a funded
independent program evaluator to conduct an external audit of
the program at least annually in order to ensure the likelihood
that the PSMC system change is successfully maintaining or
improving quality.
References are available upon request of Editor, Community Psychiatry,
at sowers@connecttime.net
or FAX 412-622-6756.
Web Editor's Note, June 1, 2002:
An updated version of this position paper,including the references, can
be found at
http://www.wpic.pitt.edu/aacp/finds/quality.html.
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