On October 31st, The Mississippi Division of Medicaid (DOM) issued a public notice of proposed state plan amendments to Mississippi Youth Programs Around the Clock (MYPAC) coverage and reimbursement.
According to the Division of Medicaid, “MYPAC is a home and community-based Medicaid program for children and youth with Serious Emotional Disturbance (SED), that follows the High Fidelity Wraparound process. MYPAC provides various services as an alternative to traditional Psychiatric Residential Treatment Facilities (PRTF). Wraparound is an all-inclusive planning process that is youth-guided and family-driven.”
Medicaid updated the MYPAC rates based on “actuarial analysis of historical utilization, payment and cost data for Early and Periodic Screening, Diagnosis, and Treatment (EPSDT) eligible beneficiaries served in the community that meet the Psychiatric Residential Treatment Facility (PRTF) level of care and the expected utilization of services.”
In looking at Medicaid’s Community Mental Health Fee Schedule, it appears on line 55 that the first hour of MYPAC services, such as a therapist, community support specialist or peer support visit, are billed at $251/hour for the first hour and then billed in fifteen-minute increments after that. Outside of MYPAC, Medicaid reimburses those services at hourly rates of $87 – 127 (therapy), $64.24 (community support) and $33.80 (peer support). Given the MYPAC reimbursement is so much higher, we feel that families should have significant input into how MYPAC services can be more effective and impactful.
We did a public records request for the MYPAC rate study. After reviewing it, we submitted the following public comments:
Thank you for the opportunity to submit public comments on the Division of Medicaid’s State Plan Amendment (SPA) 23-0025 Mississippi Youth Programs Around the Clock (MYPAC) Coverage and Reimbursement and the related rate study. I respectfully submit these comments on behalf of Families as Allies. We recommend that this SPA be further reviewed and the following issues addressed before any further action is taken:
1. Consistent with the definition of Family Driven Practice, particularly this principle, “Families and family-run organizations provide direction for policy decisions that impact funding, supports, and services, including the right of families and youth to have meaningful voice at the individual and policy level”, families receiving MYPAC services be given the opportunity to give independent, objective input about MYPAC in at least these three areas:
a. How effective they think MYPAC services are.
b. What services and supports they would want for their children and themselves if they could choose whatever services and supports they thought would be helpful.
c. After being given complete and accurate information about how much money is being spent on MYPAC and how much their sessions are billed for, whether they think current spending patterns are the best use of these funds or if they have suggestions for how those funds should be used to get the best outcomes for families and children.
2. The rate study be updated to include feedback from families and also if/how the current model is related to outcomes and cost neutrality and/or savings. The current rate study seems to be based on data the providers gave about how much it costs to provide MYPAC rather than outcomes and cost savings/neutrality.
