Los Angeles County

DEPARTMENT OF MENTAL HEALTH JONATHAN E SHERIN MD PhD

DIRECTOR

April 26 2018

Ms Brenda Grealish Acting Deputy Director Mental Health and Substance Use Disorder Services Department of Health Care Services 1500 Capital Avenue Sacramento CA 95814

Dear Ms Grealish

The Los Angeles County Mental Health Plan (MHP) has reviewed the State Department of Health Care Services (DHCS) Draft Medi-Cal Managed Care Quality Strategy Report Thank you for allowing us to comment We offer the following recommendations

Maintain consistency

bull Align DHCS and External Quality Review Organization (EQRO) quality metrics The Performance Outcome System (POS) uses a different methodology compared to EQRO One common metric to track for quality improvement and to compare against other MHPs and Statewide numbers (pg 22 Quality Metrics and Performance Targets) is best Use consistent language For example replace QI Work Plan (QIWP) with terminology from the System Review Protocol Quality Assessment and Performance Improvement (QAPI) Work Plan (pg 26 Performance Improvement Activities)

ClarifyElaborate

bull Further define certain concepts For example under Quality Metrics and Performance Targets (pg 22) a description should be provided of how Expenditures and Service Quantity per Beneficiary will be used as a metric for performance and quality tracking Higher expenditure and greater service quantity do not always indicate quality services unless they are tied to clinical outcomes When discussing metrics related to care coordination between MHPs and the child welfare system (pg 23) specify whether SMHS refers specifically to assessment and whether services refers only to treatment or can include targeted case management or even community outreach services Specify whether days represents business days or calendar days or is defined differently depending on context

550 S VERMONT AVENUE LOS ANGELES CA 90020 I HTTP1DMHLACOUNTYGOV Email Dlrectordmhlacountygov I Phone (213) 738middot4601

Ms Brenda Grealish April 26 2018 Page Two

AddModify

bull Include additional conceptsterms or modify existing ones For example include beneficiary satisfaction to the metrics that might be targeted by a non-clinical PIP (pg 22) Community level metrics are currently not outlined engage stakeholders in developing these metrics (pg 24) and indicate all age categories and groups (eg youth youth family adult and older adult) that are the focus of the satisfaction surveys that are part of the Performance Dashboards discussed on pg 25

Other Recommendations

bull Include MHP Ethnic Services Managers and Quality Improvement Leads when developing certain reports and analyses such as the report referenced on pg 24 to identify populations disproportionately affected by mental health conditions and disparities in access to SMHS and the analysis of mental health disparities across the State referenced on pg 39 Engage community stakeholders in developing community level outcomes (pg 24) Leverage quality indicators reported elsewhere to fulfill requirements of the Performance Dashboard such as addressing Dashboard translationinterpretation capabilities with Language Line Utilization data for Final Rule Network Adequacy (pg 25) Involve MHPs in developing and implementing a more robust and intensive QIWPQAPI evaluation process (pg 27) Provide a sample ulturally and Linguistically Appropriate Services (CLAS) Plan template or outline (pg 38)

Originally Signed by

Jonath E Sherin MD PhD Director

JESBBcm

c Dina K Gonzales Chief DHCS Curley Bonds MD DMH Bradley Bryant DMH Gregory Polk DMH Terri Boykins DMH