PsychOdyssey Comments on NJ’s Comprehensive Waiver Demonstration Application

PsychOdyssey's CommentsAs part of its ongoing advocacy work, PsychOdyssey on Friday submitted its comments regarding a State of New Jersey application to the Centers for Medicare and Medicaid. The application is for permission to extend by another 5 years its current so-called Medicaid “Waiver Demonstration” program. This demonstration program relates to ongoing changes and innovations for New Jersey’s Medicaid system, which funds much of the state’s public mental health services system.

Warning! This is wonkish stuff. Please bear with us as we try to explain. Not all families will be able to delve into all this. For those that can, however, we hope the explanation below will make the matter more intelligible. Regardless, all families in the maelstrom have a stake in the changes that this application proposes to New Jersey’s Medicaid program.

What is this Application About?

The application is formally titled “New Jersey Family Care 1115 Comprehensive Waiver Demonstration Application for Renewal: Strengthening Medicaid: Alignment & Redesign Through Care Integration, dd. June 10, 2016”. The applicant is the New Jersey Division of Medical Assistance and Health Services (i.e,. NJ Medicaid), which is part of the New Jersey Department of Human Services (where also is located the NJ Division of Mental Health and Addiction Services).

Why is this important?

The entire Medicaid Waiver undertaking is complex and hard for the average family member to follow. Still, it is very important since each time such a waiver is proposed and granted, there can be significant effects on what and how Medicaid funds in New Jersey. Many of our loved ones with psychiatric disabilities are covered by Medicaid. Many services within our public mental health system, such as outpatient programs, are funded by Medicaid. And mental health advocates believe that many other services, like services for supportive housing, should be funded by Medicaid.

Background

Medicaid is a Federal/State partnership. Each state has a State Medicaid Plan. Each plan details all the aspects of a state’s Medicaid program. Each state’s plan is written by the state government and approved by the Centers for Medicare and Medicaid (CMS) at the Federal level.

From time to time, states determine that their state plans need changing or modernization. To do this, states propose “waivers” to their approved plans. Waivers are generally sought for periods of five years and can be renewed or expanded. Waivers can cover a variety of changes. Such changes can include experimental innovations, or pilot projects, to try new ideas to improve the state’s Medicaid system. Such experiments are called “demonstration projects”, since they seek to demonstrate, or prove, a particular new approach before integrating it into the State Medicaid plan permanently.

In New Jersey, the government entity that manages the Garden State’s Medicaid system is the New Jersey Department of Medical Assistance and Health Services (NJDMAHS). NJDMAS is a part of the New Jersey Department of Human Services (NJDHS), under which also resides the division of particular interest to families of loved ones with psychiatric disabilities: the New Jersey Division of Mental Health and Addiction Services (NJDMHAS). [Note the subtle difference in the two acronyms, which look almost alike. NJDMAHS is NJ Medicaid’s administrative home. NJDMHAS is the administrative home of NJ’s public behavioral health systems and programs.]

What came before: The 2013 Comprehensive Waiver

In 2013, NJDHS, acting through NJDMAHS, organized a massive consolidation of NJ Medicaid programs. The consolidation ombined eight different Medicaid programs that had accumulated separately over the years into one bigger program. This consolidation was achieved under something called the “Comprehensive Waiver”. At that time, the state also received approval for several “demonstration programs” as part of that Comprehensive Waiver. The consolidation and demonstration projects all related to particular sections of the Social Security Act of 1935 under which such things were legislation. These sections include “Section 1115”, “Section 1915(a)”, “Section 1915(b)”, and so on. We’ll leave to the policy wonks the exact terms of these sections.

Several years have now passed since the approval and implementation of the Comprehensive Waiver. Now NJDHS, again acting through NJMAHS, is again approaching CMS to approve more demonstration programs for the next 5 years. Some of these projects would continue work being done under the previously approved demonstration projects. Some of these projects are new demonstration projects in their own right.

The Proposed Demonstration Projects

What are the demonstration projects in this new application? Simply noted, they are:

  1. More managed care and “Medicaid Long Term Supports and Services” (MLTSS)
  2. Behavioral health systems improvement, including substance abuse treatment
  3. More supports for loved ones with developmental disabilities
  4. Modernization of eligibility and enrollment processes
  5. Help for ex-prisoners returning to the community
  6. More housing supports for the homeless and those nearly so
  7. More “alternative providers”
  8. Better purchasing systems and methods
  9. More “health partnerships”

Each of these has impacts on important services that many of our loved ones receive, either now or potentially.

The “Public Comment” period

A typical aspect of such applications is a “public comment” period. Such periods enable the public to comment on elements in such requests. They also enable advocates to state important principles that they believe must be included to guide all such changes.  One such principle stated by many in this application’s public comment period is “Housing First”, the idea that all loved ones with various disabilities should first receive safe and secure housing to stabilize their lives and provide an adequate foundation for recovery. This is different from the traditional view that, say, a loved one with an addiction should get clean first before receiving housing.

PsychOdyssey also participated in this public comment period. In our own name, but on behalf of families in the maelstrom all over New Jersey, PsychOdysset submitted 6 pages of comments covering each proposed demonstration project and offered general comments about overall changes.

The Relevant Documents

To help families in the maelstrom know more about this entire undertaking, PsychOdyssey is pleased to post the following documents:

  1. PsychOdyssey’s summary of the Waiver Demonstration Application context (prepared for NAMI Mercer), a simple primer on the Comprehensive Waiver’s recent history and process.
  2. New Jersey Medicaid’s Application (“NJ Family Care 1115 Comprehensive Waiver Demonstration Application for Renewal”, dd. June 10, 2016), the State’s somewhat turgid and hard-to-understand application.
  3. PsychOdyssey’s Comments about NJ Medicaid’s Application, dd. August 12, 2016, focusing on each of the State’s proposed projects.
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