Effective July 1, 2021, the Florida Medicaid Management Information System (FMMIS) will no longer pay for services billed to Medicaid for recipients enrolled in a Dual Eligible Special Needs Plan (D-SNP) for the following provider types:

Assistive Care, Case Management Agency, Behavioral Health, Home Health, Private ICF/DD Facility, and Skilled Nursing Facility.

This policy might have been created with good intentions, but the implementation has been a total failure. As a result of this policy, thousands of older adults have lost access to mental health treatments, and others are seeing their treatments interrupted continuously. Hundreds of Medicaid Providers have been forced to close their businesses because of the instability that the DSN-Ps have brought to their businesses. 

The policy released by AHCA stated that Florida Medicaid has been coordinating with the D-SNPs to ensure a smooth transition of services and to ensure impacted D-SNP members are provided with a 60-day advance notice. The notice includes instructions on how to find a D-SNP network provider and will be delivered to D-SNP members this week.

There was no smooth transition at all. Until this day, some DSNPs don't know what a Targeted Case Management Agency is, and they refuse to contract this type of Medicaid provider because, according to them, the DSNPs are only for Medicare services. They list these Medicaid services in their DSNPs benefits, but their credentialing departments have no idea how to credential these Medicaid Providers.

Even though Medicaid has a Coverage and Limitation Handbook for each of these Medicaid Providers to define how they have to operate to comply with AHCA policies and Florida Statutes, some DSNPs have developed their own extreme eligibility criteria, difficulting their members to have access to these important services.

Nowadays, Medicaid Providers have to spend 80% of their time over the phone calling claims departments for denied claims, responding to imposed overpayments for reasons that do not align with AHCA policies, requesting updates for authorization requests that take months for them to respond to, etc. The software that some of these DSNPs use to process Claims has not been updated with the Medicaid Fee Schedule Codes causing Claims to be denied constantly or applying huge deductions for no reason.

Last year I saw people cry because they were forced to abandon their current treatments and could not continue seeing their Mental Health Therapists, Psychiatrists or participating in their Psychosocial Rehabilitation sessions because the DSNPs decided to reduce their network drastically and sent termination letters to many of these types of providers, interrupting thousands of adult people's treatments and leaving thousands of professionals without employment.

This policy has also created a conflict of interest between the medical provides and behavioral health providers. The capitation paid to Medical Centers for their members is drastically affected by the Medicaid-covered behavioral health services their members receive. Medical providers at such centers have received instructions from the owners not to refer any clients to Behavioral Health because of the economic impact this bring to their businesses. This is just unbelievable.

These Providers played a vital role during the Covid-19 pandemic by supporting our Floridian community, especially this fragile population sector. AHCA executed this policy right after the Covid-19 emergency period had finished, forcing many of these Providers to close.

It would be good for AHCA to conduct surveys with current providers to hear about their experiences with this policy. If they look at the statistics, they will notice a massive drop in the applications for types of providers. No one wants to open these types of providers anymore because of the instability created by this policy. 

Recently, our Governor, Ron DeSantis, approved 600 million dollars to increase the minimum salary wage for all Medicaid Providers' employees. A few nights ago, I heard our president talk about the billions of dollars the country plans to dedicate to Mental Health and Substance Abuse treatments. How will the members and providers of these DSNPs benefit from these helps if all the previously mentioned issues persist?

Many of these providers have submitted complaints to AHCA and expressed their frustration, but no solution has been provided. AHCA has recognized that this is an issue affecting all types of providers across the board, but they refuse to act. I think it's time for Governor Ron DeSantis's office to examine this policy and ask AHCA to find a better solution because it is clear that this policy did not work out as expected.