CHA News Article

DHCS Releases Guidance to Medi-Cal Managed Care Plans on Providing Palliative Care

The California Department of Health Care Services (DHCS) has released the attached All Plan Letter (APL) informing Medi-Cal managed care health plans (MCPs) of their obligation to provide palliative care to Medi-Cal members, pursuant to Senate Bill (SB) 1004 (Chapter 574, Statutes of 2014).To fulfill the bill’s requirement that DHCS establish standards and provide technical assistance to MCPs for the delivery of palliative care, the department outlines its Palliative Care Policy specifying the minimum types of palliative care services MCPs must authorize when medically necessary for a Medi-Cal member who meets eligibility criteria. This APL advises MCPs that, effective Jan. 1, 2018, when a Medi-Cal member meets the minimum eligibility criteria for palliative care, MCPs must authorize palliative care without regard to age.

At a minimum, palliative care must include advance care planning, palliative care assessment and consultation, plan of care, palliative care team, care coordination, pain and symptom management, and mental health and medical social services. The APL further advises MCPs that they must have a process to determine the type of palliative care that is medically necessary or reasonable for eligible beneficiaries, and must have a large enough network of palliative care providers to meet their Medi-Cal members’ needs.

DHCS indicates that MCPs may authorize provision of palliative care in a variety of settings, including inpatient, outpatient or community-based settings. MCPs may also contract with hospitals, long-term care facilities, clinics, hospice agencies, home health agencies, and other types of community-based providers that include licensed clinical staff with experience or training in palliative care.

MCPs are required to develop written policies and procedures for palliative care that must describe how the MCP will meet the requirements for the palliative care benefit outlined in the APL as well as how MCPs will monitor and collect palliative care enrollment, provider and utilization data to report to DHCS. In addition, MCPs are responsible for ensuring that their delegates comply with all applicable state and federal law and regulations and other contractual requirements as well as DHCS guidance, including APLs and Dual Plan Letters. 

The requirements discussed in the APL specifically apply to Medi-Cal managed care members who are not dually eligible Medicare/Medi-Cal beneficiaries.

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