The California HIV Alliance Is Calling on the State Legislature and State Department Of

California HIV Alliance Response to the Dual Eligible California Care Coordination Demonstration

The California HIV Alliance is calling on the State Legislature and State Department of Health Care Services to exclude people with HIV/AIDS from participation in the Dual Eligible Care Coordination Demonstration. For the reasons explained below, we believe that the inclusion of dual eligibles with HIV/AIDS in the state’s proposed Care Coordination Demonstration will lead to a substantial disruption in care for a very vulnerable population leading to negative health outcomes and the possibility of increased transmission of HIV disease. In addition, the existing network of specialized home care providers, which has developed over the last 20 years to serve the specific needs of people with HIV, could be undermined and potentially dismantled by the mandatory inclusion of these services into managed care plans. Instead of the inclusion of people with HIV/AIDS in this demonstration, we urge the state to explore the possibility of small demonstration projects that would allow the thoughtful transition of both dual eligible people with HIV and their providers into managed care settings. These projects should be developed with key stakeholders including HIV advocates and providers.

 Passive enrollment has the potential to severely disrupt the HIV coordinated care duals currently receive through providers who accept fee-for-service Medicare and also provide Ryan White wrap around services and services funded by the AIDS Home and Community Based Waiver. o Dual eligibles with HIV/AIDS currently receive coordinated care services funded through a variety of sources and have long established relationships with their providers. o Disruption in these established services is likely because HIV providers, particularly home and community based providers, are not fully enrolled in the managed care plans selected for the demonstrations. Mandatory enrollment in Medi-Cal managed care, passive enrollment and the lock-in period in Medicare managed care will cause unnecessary and potentially life-threating care disruptions for a very vulnerable population at the time with the National HIV/AIDS Strategy seeks to engage and retain more people with HIV/AIDS in care in order to meet the goal of dramatically reducing new HIV infections.

 Inclusion of AIDS Waiver-funded Long Term Services and Supports into managed care would seriously disrupt care and could dismantled specialized services that have proven efficacy meeting the unique needs of people with HIV/AIDS and avoiding the much more expensive option of institutionalization. o AIDS Home Health Waiver providers are not enrolled in managed care plans currently. They have not been approached for planning or technical assistance with becoming part of plan networks. The large scale mandatory movement proposed for current and future clients in need of home and community based services would seriously disrupt the care that keeps HIV positive people in their homes and out of costly institutional settings. o There has been no stakeholder involvement in the plans to phase out or incorporate AIDS Waiver-funded services into managed care plans serving this population.

 The timeline of the proposed demonstration doesn’t allow for the necessary planning to ensure that managed care plans can serve dual eligibles with HIV/AIDS and to leverage and build on the expertise of the existing care provider system to ensure adequate care delivery. o Managed care plans are not ready to serve dual eligibles with HIV/AIDS. HIV-experienced providers are not fully incorporated into the plans. Adequate quality measures that address HIV care must be incorporated into the broader managed care plans before this vulnerable population is incorporated.

o Consumer protections, education and assessment tools have not been articulated and vetted with key stakeholders. There is no communication plan for HIV-experienced providers and their client to ensure they understand the initiative and their rights. Currently almost all HIV/AIDS providers are unaware of the proposal’s components, including the AIDS Waiver inclusion. o Los Angeles County, one of the eight counties chosen for the first phase of the project, is home to 40 percent of the state‘s HIV/AIDS population. We do not want to repeat the same mistakes with inadequate planning that we experienced with the Low Income Health Programs and the movement of seniors and people with disabilities into mandatory managed care.

 Other key items that could be taken into account through small demonstration projects and must be considered before full incorporation of HIV positive duals into managed care o The State Office of AIDS is unaware of the impact of the component of this demonstration on dual eligibles with HIV/AIDS and must be included in discussions. Key stakeholders must also be engaged. o HIV/AIDS providers, particularly the home and community based providers, must get the technical assistance necessary to begin to work with managed care services o Specialized and wrap-around services – such as vision, dental, medical and non-medical, and housing assistance – could be lost to people with HIV/AIDS unless provided by plans or explicitly excluded due to Ryan White payer of last resort. o The assessment tool must include measures that address people with HIV, and it must be clarified, vetted and articulated before the initiative’s start. o Individual assistance that is necessary to ensure a safe transition for this vulnerable population must be considered and articulated.

AIDS Project Los Angeles L.A. Gay & Lesbian Center Project Inform San Francisco AIDS Foundation