Community Support is patterned after "best practices" services in other states. It was implemented in North Carolina in March 2006. The rate was set using a cost modeling process that looked at staff qualifications and ratios, and estimated costs of personnel, travel, staff training and accreditation. The Department of Health and Human Services stated when the new services were implemented that it would revisit the rates after a period of time.

In the months following, DHHS identified a rapid growth of Community Support that far exceeded the budgeted use. We were spending more on this service than our Medicaid payments to physicians and hospitals and for prescription drugs. We also identified concerns that the service was being delivered in a way that was a disservice to consumers, as it appeared to have become an obstacle to referrals to other, potentially more effective services for some recipients.

These concerns prompted DHHS to release an action plan addressing the use and billing of Community Support service. As DHHS concluded the initial round of medical record audits, we identified deficiencies in Medicaid documentation requirements and limitations in the understanding of the correct implementation of the treatment components of the service. Furthermore, it became clear that paraprofessional staff members -- high school graduates -- were delivering most of the service, when master's-level or qualified professional expertise was required and would provide better treatment outcomes.

At the same time, DHHS began a review of actual cost data from selected providers. To date, that review has confirmed the concern that the rate in place prior to April 1 exceeded the actual cost of the service.

As fiduciary agents of federal, state and county tax dollars, DHHS has a responsibility to ensure appropriate payment for the level of services rendered. Since the Medicaid State Plan mandates that the reimbursement rate for Community Support Service be a statewide rate that is based upon cost, DHHS had no choice but to adjust the rate to reflect the fact that this service was being provided almost exclusively by lower-cost staff. Failure to act would have jeopardized not only the overall funding of the Medicaid program that supports 1.5 million recipients in North Carolina, but also the integrity of all the new service definitions critical to treating people with mental illness, developmental disabilities and substance abuse services.

We recognize and appreciate the Community Support providers who are participating in the cost modeling discussion, which will conclude in late April or early May and will confirm whether the rate implemented April 1 is correct or needs adjustment.

DHHS will continue to balance its responsibilities to the taxpayers of North Carolina and to the consumers who depend upon this important service.

Carmen Hooker Odom

Secretary, Department of Health and Human Services

Raleigh

(The length limit was waived to permit a fuller response to the article.)

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