In accordance with public notice requirements established at 42 CFR 447.205, the Indiana Family and Social Services Administration (FSSA) Office of Medicaid Policy and Planning (OMPP) intends to submit the proposed amendment to the Behavioral and Primary Healthcare Coordination (BPHC) to the Centers for Medicare and Medicaid Services (CMS) for consideration.

The amendment to the 1915(i) State Plan benefit will have an effective date of October 1, 2020, contingent upon CMS approval. The changes to the BPHC State Plan benefit include adding the ability to request additional service units using the prior authorization (PA) process, changing the Community Health Worker (CHW) provider type to the Integrated Health Technician (IHT), adding clarification with regard to three BPHC services that must be provided to each eligible member every 180 days and documented in progress notes, and changing the BPHC staff qualifications for individuals who complete state evaluations for the program from three years of post-degree experience to two years of post-degree experience of working with individuals with serious mental illness (SMI) and/or substance use disorders (SUD). Additionally, the amendment includes the addition of the Electronic Visit Verification (EVV) system.

The State Evaluation Team (SET) will review all BPHC PA requests for Indiana Health Coverage Programs (IHCP) members on a case-by-case basis through the Data Assessment Registry Mental Health and Addiction (DARMHA) system and decide whether to approve or deny PA requests based on medical necessity. The change from the CHW to the IHT will mitigate any confusion with the CHW that was introduced in the State Plan in July of 2018. Changing BPHC staff qualifications for individuals who complete state evaluations will increase staff capability for providing consumer evaluation.

Fiscal Impact:

The 30 day public comment period for the BPHC amendment will run May 6, 2020, through June 5, 2020. Comments can be emailed to bphc.service@fssa.in.gov or mailed to the address below:

The BPHC amendment is available for review and public comment on the DMHA-A Draft Policies for Public Comment webpage (https://www.in.gov/fssa/dmha/3103.htm). Hard copies of the proposed amendments are available upon request at the address contained herein. Additionally, copies of the proposed amendments are available at local Bureau of Division of Mental Health and Addiction Services offices.

Jennifer Sullivan, M.D., MPH

Secretary