Collective Stakeholder Feedback | BHA Actions to Address Feedback |
BHASO qualifications and experience should include deep understanding of the local community as well as experience with public health administration | BHA will take a deep dive into applicants’ experience in public health and history in its region when reviewing RFP submissions. |
BHASOs should include people with lived experience and people representing historically underserved populations in its staff, provider staff, and advisory groups | BHASOs are required to form and collaborate with Regional Advisory Councils on matters such as availability of care, care coordination, and breaking down barriers to receiving treatment. Further, BHA seeks Applicants who recruit and retain staff who are representative of the communities they serve and who have lived experience with the behavioral health care system. |
BHASOs should align and coordinate with RAEs and should clearly delineate responsibilities | The work of BHASOs and RAEs is closely aligned, but with important differences that make collaboration and information-sharing between the two networks all the more valuable. BHASOs will be expected to establish formal agreements and procedures with RAEs to ensure continuity of care for individuals moving between systems. BHASOs will also engage with RAE’s Advisory Councils. Additionally, BHASO and RAEs will have the same regions to further ensure there is alignment and consistency within the two systems. |
BHA should be clear about the vision for the continuum of care and emphasize early intervention as well as services and supports for people with the most complex needs. | § 27-50-301(3)(a) identifies a complete continuum of behavioral services, from early education and engagement through crisis, treatment, high-intensity interventions, recovery, and many other critical services, all of which the BHASO must make available to children, youth, and adults in its region. The contract has an emphasis on Care Coordination and comprehensive services for the highest-acuity individuals, such as COACT (high-fidelity wraparound services for children), Assertive Community Treatment (wraparound services for adults with severe mental illness), and Crisis Resolution Teams (multidisciplinary care teams which support a child and their family after a crisis episode). |
Promote and support telehealth and digital services to expand access. Telehealth should not be treated as a replacement for in-person services for rural Regions. | BHA encourages BHASOs to deliver care in non-traditional locations and by non-traditional means such as telehealth to increase service accessibility, as long as telehealth is not treated as a replacement for in-person care, and patient choice is centered in the decision to use telehealth. BHA further requires that telehealth services are provided in compliance with the State Digital Equity Plan, are used in a way that centers individuals’ choice and convenience, and are measured to determine their impact on community health. |
BHASOs should address social determinants of health (local community connection to other services and benefits, employment supports, etc) as part of the care continuum. | Recognizing that the conditions in which Individuals live also impact their health and well-being, the BHASO shall establish relationships and collaborate with economic, social, educational, justice, recreational, and other relevant organizations to promote the health of local communities and populations. BHASOs are expected to establish relationships and communication channels with community organizations that provide resources such as food, housing, energy assistance, childcare, education, and job training in the Region. |
BHA should hold the BHASOs accountable for ensuring the continuum of care and network adequacy to meet Individuals’ needs in the Region. | The innovations of the new Data Requirements Exhibit establish robust monitoring and evaluation mechanisms to track progress in reducing service gaps. Through these mechanisms, BHA will continuously collect and analyze data on healthcare disparities to monitor progress and adjust strategies as needed. The BHASOs will be subject to corrective action plans if network adequacy and quality is not sufficient. Further, BHA is implementing a Commitment to Quality Program that holds BHASOs to meet certain performance standards in its network, with financial consequences if targets are not met. BHA will develop network adequacy measures and standards in collaboration with the BHASOs in the first system-delivery year of the BHASO contract and expects the BHASOs partnership to identify critical gaps and areas for improvement. |
BHASOs should reduce silos by forming connections and referral systems across services/providers. | In addition to entering formal agreements with RAEs as discussed above, BHASOs are also expected to build relationships and coordinate proactively with a wide range of stakeholders, including county governments, law enforcement and county jails, hospitals and health providers, community resources, and state agencies such as Dept of Health Care Policy and Financing, Dept of Public Health and Environment, Dept of Regulatory Agencies, Division of Insurance, etc. |
BHASOs should ensure that all services along the continuum are culturally competent and sensitive to the needs of various communities; tailoring the service delivery models to meet unique needs | BHASOS are informed by Regional Advisory Councils and Peer Support Professionals who can offer a lived-experience perspective, not only as receivers of behavioral health services but also as members of their intersectional identity groups.
BHASOs and their Networks are required to undergo cultural competency training and training on special considerations when treating unique populations.
The BHASOs are encouraged to offer services in non-traditional locations and by non-traditional means such as by telehealth, in-home, in community settings such as faith-based locations, libraries, or schools, outdoors, or anywhere else an Individual can readily access and receive meaningful services. |
BHASOs should play a role in workforce development, including recruitment, retention, quality improvement and building provider competencies | BHASOs are expected to engage in workforce expansion and development activities that are responsive to the unique needs of its communities. Examples of these interventions include recruitment and retention, diversifying and cultivating a culturally responsive workforce, and work-based learning to develop career pipelines into behavioral health. BHASOs will coordinate the integration of the OwnPath Learning Hub to increase the competencies and quality of providers in its Network. |
BHA should provide clear definitions of care coordination, including operational and clinical expectations. | A full description of Care Coordination including operational and clinical expectations can be found in the BHASO Contract. BHA has issued further standards for Care Coordination throughout BHA Rules (2 CCR 502-1 and 2 CCR 502-6). |
BHA should clearly describe the roles of the BHASOs and RAES in care coordination and expectations for communication/coordination within and across Regions/intermediaries. | BHA establishes the role of the BHASOs in providing Care Coordination in the Contract, which includes accounting for frequent changes in Medicaid status.
Prior to BHASO launch, the BHASOs will be required to execute formal agreements with all RAEs that establish detailed communication and coordination procedures for Individuals transitioning on/off Medicaid and for Individuals enrolled in Medicaid who are receiving services through the BHASO that Medicaid does not cover. |
BHA should support data exchange and interoperability requirements between entities performing care coordination. | BHASOs will be required to implement a Care Coordination technology program that includes utilization of SHIE and related systems to improve coordination of services, particularly community-based services addressing health-related social needs.
Applicants are asked to describe their plans for utilizing care coordination technology and to identify what they need from the State to support their efforts.
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BHA should establish BHASO requirements related to provider payment & reimbursement, including how BHA will monitor and oversee provider reimbursement and the implementation of Value Based Payment and Alternative Payment Models. | Payment structures (such as cost reimbursement, fee for service, etc) are clearly stated throughout the Contract. BHA sets maximum timeframes for invoice payment and provides guidance on how invoices should be reviewed for compliance with state and federal requirements.
BHA will gradually move the behavioral health safety net towards value based payment and alternative payment models, as will be described in BHA’s implementation strategy in the RFP. |
Be clear and detailed about the BHASO’s role in quality measurement, developing and enforcing reporting requirements, and establishing incentives to improve quality and BHA oversight of these requirements. Clearly define quality measures that focus on access, outcomes, and the Individual’s experience. | BHASOs’ role in quality measurement will be tied to frameworks such as BHA’s Access to Care Methodology and RE-AIM.
Quality measures will be released with BHA’s Performance Monitoring System, with initial launch occurring on July 1, 2024. These measures will be designed in collaboration with the Department of Health Care Policy and Financing and other community stakeholders and will center on access, outcomes, and Individual experience.
BHASOs will also be responsible for regular quality monitoring and improvement activities such as active contract management, peer review, site visits, and managing corrective actions as necessary.
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The BHASOs should achieve administrative and other efficiencies across the behavioral health system. | Applicants with significant experience in public health administration and with pre-existing partnerships and relationships in their Region will receive higher scores on the RFP. Applicants applying administrative fees under the 10% cap will likewise be competitive proposals. BHASOs are required to formalize relationships and referral pathways with multiple other systems/agencies/services and with other BHASOs. |
