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CMS proposed new rule: Medicaid and Children's Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality

By:

Liz is a Senior Consultant in the Medicaid Practice Group with a background in state government oversight of Medicaid managed care compliance. She has 10 years’ experience in the regulatory/policy environment at the crossroads of government and managed care, as well as demonstrated success in managing government regulatory and communications activities on a national scale. She has a successful history in engaging internal and external stakeholders to promote Medicaid initiatives.

Liz Vose,

Ryan is a Senior Consultant in the Medicaid Practice Group, supporting state Medicaid agencies with their managed care compliance and oversight, policy initiatives, and managed care contractual language. He also reviews, synthesizes, and analyzes CMS guidance and federal and state regulations to interpret the impact to state Medicaid agencies.

Ryan Melson
05.17.23 /

Read this if you are a State Medicaid Agency (SMA).

On April 27, 2023, the Centers for Medicare & Medicaid Services (CMS) published a proposed new rule titled “Medicaid and Children’s Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality,” intended to address the most critical elements of access and person-centered care. The COVID-19 Public Health Emergency (PHE) tested states’ abilities to connect individuals to quality care, stabilize the workforce, and monitor Medicaid managed care programs. Leveraging the proposed changes in this rule, CMS aims to provide guidance to states to help advance CMS efforts to improve access to care, quality, and health outcomes, and better address health equity consistent with the CMS Framework for Health Equity 2022 – 2032.

This summary is intended to offer a glimpse of the proposed provisions for which CMS is seeking feedback. Below are some highlights of the significant changes:

Enrollee experience

To enhance state monitoring of network access, CMS is proposing that states take on a qualitative and quantitative approach to monitoring service access. Specifically, CMS proposes to revise regulations to explicitly include “enrollee experience” and require states to use the results from the annual enrollee experience survey and secret shopper surveys that offer a person-centered view to understanding network deficiencies.

Transparency

In an effort to promote transparency and empower enrollee choice, CMS proposed several requirements that would make states' websites easier to use. The proposed rules require states to post up-to-date information on their websites, including making available a one-stop location for enrollees to compare health plans.

State Directed Payments (SDPs)

Given the growing number of SDP preprints submitted for approval, proposed changes in this area are focused on strengthening vague contractual, procedural, and monitoring requirements to help ensure access to care and implement proper fiscal and program integrity guardrails.

Medical Loss Ratio (MLR) standards

CMS aims to establish consistency in MLR methodology across multiple markets (private, Medicare, Medicaid, and CHIP) to improve administrative efficiency for the states regulating insurance and Medicaid/CHIP and for the collection and measurement of data to calculate an MLR and provide reports. The proposed changes include revisions to requirements for clinical or quality improvement standards for provider incentive arrangements, prohibited administrative costs in quality improvement activity reporting, and additional requirements for expense allocation methodology reporting

In Lieu of Services (ILOS) and settings

ILOS offers states the flexibility in managed care to substitute a service or setting for a service or setting covered under the state plan, when medically appropriate and cost effective, to enrollees. This proposed rule looks at ILOS as a mechanism for addressing Social Determinants of Health (SDoHs) and health-related social needs, proposes that states evaluate the impact ILOS has on health equity, and evaluates whether ILOS is an appropriate and efficient use of Medicaid and CHIP resources. There are several requirements based on helping to ensure fiscal protections are in place for investments in ILOS.

Medicaid managed care quality rating system

CMS is proposing changes to how states monitor quality of services delivered and aimed at promoting member choice. The goals of quality improvements are intended to make quality reporting more transparent and meaningful for driving quality improvement, reduce burden on certain quality reporting requirements, and establish a rating system for Medicaid and CHIP health plans.

CMS is seeking feedback on these proposed rules. Public comments are due by July 3, 2023, and can be submitted at the following link: Regulations.gov.

If you would like more information or have questions about the proposed rule and guidance on assessing, developing, or implementing changes to your managed care program, please contact our Medicaid consulting team. We are here to help.

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There’s a good chance that your organization is in the position of needing to do more with less under the strain of staffing constraints and competing initiatives. With fewer resources to work with, you’ll need to be persuasive to get the green light on new enterprise technology initiatives. To do that, you need to present decision makers with well-thought-out and targeted business cases that show your initiative will have impact and will be successful. Yet developing such a business case is no walk in the park. Perhaps because our firm has its roots in New England, we sometimes compare this process to leading a hiking trip into the woods—into the wild. 

Just as in hiking, success in developing a business case for a new initiative boils down to planning, preparation, and applying a few key concepts we’ve learned from our travels. 

Consensus is critical when planning new technology initiatives

Before you can start the hike, everyone has to agree on some fundamentals: 

Who's going? 

Where are we going? 

When do we go and for how long? 

Getting everyone to agree requires clear communication and, yes, even a little salesmanship: “Trust me. The bears aren’t bad this time of year.” The same principle applies in proposing new technology initiatives; making sure everyone has bought into the basic framework of the initiative is critical to success.

Although many hiking trips involve groups of people similar in age, ability, and whereabouts, for your business initiative you need to communicate with diverse groups of colleagues at every level of the organization. Gaining consensus among people who bring a wide variety of skills and perspectives to the project can be complex.

To gain consensus, consider the intended audiences of your message and target the content to what will work for them. It should provide enough information for executive-level stakeholders to quickly understand the initiative and the path forward. It should give people responsible for implementation or who will provide specific skills substantive information to implement the plan. And remember: one of the most common reasons projects struggle to meet their stated objectives (and why some projects never materialize to begin with), is a lack of sponsorship and buy-in. The goal of a business case is to gain buy-in before project initiation, so your sponsors will actively support the project during implementation. 

Set clear goals for your enterprise technology project 

It’s refreshing to take the first steps, to feel that initial sense of freedom as you set off down the trail. Yet few people truly enjoy wandering around aimlessly in the wilderness for an extended period of time. Hikers need goals, like reaching a mountain peak or seeing famous landmarks, or hiking a predetermined number of miles per day. And having a trail guide is key in meeting those goals. 

For a new initiative, clearly define goals and objectives, as well as pain points your organization wishes to address. This is critical to ensuring that the project’s sponsors and implementation team are all on the same page. Identifying specific benefits of completing your initiative can help people keep their “eyes on the prize” when the project feels like an uphill climb.

Timelines provide additional detail and direction—and demonstrate to decision makers that you have considered multiple facets of the project, including any constraints, resource limitations, or scheduling conflicts. Identifying best practices to incorporate throughout the initiative enhances the value of a business case proposition, and positions the organization for success. By leveraging lessons learned on previous projects, and planning for and mitigating risk, the organization will begin to clear the path for a successful endeavor. 

Don’t compromise on the right equipment

Hiking can be an expensive, time-consuming hobby. While the quality of your equipment and the accuracy of your maps are crucial, you can do things with limited resources if you’re careful. Taking the time to research and purchase the right equipment, (like the right hiking boots), keeps your fun expedition from becoming a tortuous slog. 

Similarly, in developing a business case for a new initiative, you need to make sure that you identify the right resources in the right areas. We all live with resource constraints of one sort or another. The process of identifying resources, particularly for funding and staffing the project, will lead to fewer surprises down the path. As many government employees know all too well, it is better to be thorough in the budget planning process than to return to authorizing sources for additional funding while midstream in a project. 

Consider your possible outcomes

You cannot be too singularly focused in the wild; weather conditions change quickly, unexpected opportunities reveal themselves, and being able to adapt quickly is absolutely necessary in order for everyone to come home safely. Sometimes, you should take the trail less traveled, rest in the random lean-to that you and your group stumble upon, or go for a refreshing dip in a lake. By focusing on more than just one single objective, it often leads to more enjoyable, safe, and successful excursions.

This type of outlook is necessary to build a business case for a new initiative. You may need to step back during your initial planning and consider the full impact of the process, including on those outside your organization. For example, you may begin to identify ways in which the initiative could benefit both internal and external stakeholders, and plan to move forward in a slightly new direction. Let’s say you’re building a business case for a new land management and permitting software system. Take time to consider that this system may benefit citizens, contractors, and other organizations that interact with your department. This new perspective can help you strengthen your business case. 

Expect teamwork

A group that doesn’t practice teamwork won’t last long in the wild. In order to facilitate and promote teamwork, it’s important to recognize the skills and contributions of each and every person. Some have a better sense of direction, while some can more easily start campfires. And if you find yourself fortunate enough to be joined by a truly experienced hiker, make sure that you listen to what they have to say.

Doing the hard work to present a business case for a new initiative may feel like a solitary action at times, but it’s not. Most likely, there are other people in your organization who see the value in the initiative. Recognize and utilize their skills in your planning. We also suggest working with an experienced advisor who can leverage best practices and lessons learned from similar projects. Their experience will help you anticipate potential resistance and develop and articulate the mitigation strategies necessary to gain support for your initiative.

If you have thoughts, concerns, or questions, contact our team. We love to discuss the potential and pitfalls of new initiatives, and can help prepare you to head out into the wild. We’d love to hear any parallels with hiking and wilderness adventuring that you have as well. Let us know! 

BerryDunn’s local government consulting team has the experience to lead technology planning initiatives and develop actionable plans that help you think strategically and improve service delivery. We partner with you, maintaining flexibility and open lines of communication to help ensure that your team has the resources it needs.

Our team has broad and deep experience partnering with local government clients across the country to modernize technology-based business transformation projects and the decision-making and planning efforts. Our expertise includes software system assessments/planning/procurement and implementation project management; operational, management, and staffing assessments; information security; cost allocation studies; and data management.  

Article
Into the wild: Building a business case for a new enterprise technology project

Read this if your organization is planning on upgrading or replacing an enterprise technology system.

It can be challenging and stressful to plan for technology initiatives, especially those that involve and impact every area of your organization. Common initiatives include software upgrades or replacements for:

  • Financial management, such as Enterprise Resource Planning (ERP) systems
  • Asset management systems
  • Electronic health records (EHR) systems
  • Permitting and inspections systems

Though the number of considerations when planning enterprise technology projects can be daunting, the greatest mistake you can make is not planning at all. By addressing just a few key areas, you can avoid some of the most common pitfalls, such as exceeding budget and schedule targets, experiencing scope creep, and losing buy-in among stakeholders. Here are some tips to help you navigate your next project:

Identify your IT project roles and resources

While most organizations understand the importance of identifying project stakeholder groups, it is often an afterthought. Defining these roles at the outset of your project helps you accurately estimate the work effort.

Your stakeholder groups may include:

  • An executive sponsor
  • A steering committee
  • A project manager
  • Functional leads
  • A technical team

Once you’ve established the necessary roles, you can begin reviewing your organization’s resources to determine the people who will be available to fill them. Planning for resource availability will help you avoid delays, minimize impact to regular business processes, and reduce the likelihood of burnout. But this plan won’t remain static—you can expect to make updates throughout the project.

Establish clear goals and objectives to keep your technology project on track

It’s important that an enterprise technology project has established goals and objectives statements. These statements will help inform decision-making, provide benchmarks for progress, and measure your project’s success. They can then be referenced when key stakeholders have differing perspectives on the direction to take with a pending decision. For example, if the objective of your project is to reduce paper-based processes, you may plan for additional computer workstations and focus technical resources on provisioning them. You’ll also be able to measure your success in the reduction of paper-based tasks.

Estimate your IT project budget accurately

Project funding is hardly ever overlooked, but can be complex with project budgets that are either underestimated or estimated without sufficient rationale to withstand approval processes and subsequent budget analysis. You may find that breaking down estimates to a lower level of detail helps address these challenges. Most technology projects incur costs in three key areas:

  • Vendor cost: This could include both one-time software implementation costs as well as recurring costs for maintenance and ongoing support.
  • Infrastructure cost: Consider the cost of any investments needed to support your project, such as data center hardware, networking components, or computing devices.
  • Supplemental resource cost: Don’t forget to include the cost of any additional resources needed for their specialized knowledge or to simply backfill project staff. This could include contracted resources or the additional cost of existing resources (i.e., overtime).

A good technology project budget also includes a contingency amount. This amount will depend on your organization’s standards, the relative level of confidence in your estimates, and the relative risk.

Anticipate the need for change management

Depending on the project, staff in many areas of your organization will be impacted by some level of change during a technology implementation. External stakeholders, such as vendors and the public, may also be affected. You can effectively manage this change by proactively identifying areas of likely change resistance and creating strategies to address them.

In any technology implementation, you will encounter change resistance you did not predict. Having strategies in place will help you react quickly and effectively. Some proven change management strategies include communicating throughout your project, involving stakeholders to get their buy-in, and helping ensure management has the right amount of information to share with their employees.

Maintain focus and stay flexible as you manage your IT project

Even with the most thought-out planning, unforeseen events and external factors may impact your technology project. Establish mechanisms to regularly and proactively monitor project status so that you can address material risks and issues before their impact to the project grows. Reacting to these items as they arise requires key project stakeholders to be flexible. Key stakeholders must recognize that new information does not necessarily mean previous decisions were made in error, and that it is better to adapt than to stick to the initial direction.

Whether you’re implementing an ERP, an EHR, or enterprise human resources or asset management systems, any enterprise technology project is a massive undertaking, involving significant investment and a coordinated effort with individuals across multiple areas of an organization. Common mistakes can be costly, but having a structured approach to your planning can help avoid pitfalls. Our experienced, objective advisors have worked with public and private organizations across the country to oversee large enterprise projects from inception to successful completion.

Contact our software consulting team with any questions.

Article
Planning for a successful enterprise technology project

Read this if you are a police executive, city/county administrator, or elected government official, responsible for a law enforcement agency. 

“We need more cops!”  

Do your patrol officers complain about being short-staffed or too busy, or that they are constantly running from call to call? Does your agency struggle with backed-up calls for service (CFS) or lengthy response times? Do patrol staff regularly find themselves responding to another patrol area to handle a CFS because the assigned officer is busy on another call? Are patrol officers denied leave time or training opportunities because of staffing issues? Does the agency routinely use overtime to cover predictable shift vacancies for vacations, holidays, or training? 

If one or more of these concerns sound familiar, you may need additional patrol resources, as staffing levels are often a key factor in personnel deployment challenges. Flaws in the patrol schedule design may also be responsible, as they commonly contribute to reduced efficiency and optimal performance, and design issues may be partially responsible for some of these challenges, regardless of authorized staffing levels.
 
With community expectations at an all-time high, and resource allocations remaining relatively flat, many agencies have growing concerns about managing increasing service volumes while controlling quality and building/maintaining public trust and confidence. Amid these concerns, agencies struggle with designing work schedules that efficiently and optimally deploy available patrol resources, as patrol staff become increasingly frustrated at what they consider a lack of staff.

The path to resolving inefficiencies in your patrol work schedule and optimizing the effective deployment of patrol personnel requires thoughtful consideration of several overarching goals:

  • Reducing or eliminating predictable overtime
  • Eliminating peaks and valleys in staffing due to scheduled leave
  • Ensuring appropriate staffing levels in all patrol zones or beats
  • Providing sufficient staff to manage multiple and priority CFS in patrol zones or beats
  • Satisfying both operational and staff needs, including helping to ensure a proper work/life balance and equitable workloads for patrol staff

Scheduling alternatives

One common design issue that presents an ongoing challenge for agencies is the continued use of traditional, balanced work schedules, which spread officer work hours equally over the year. Balanced schedules rely on over-scheduling and overtime to manage personnel allocation and leave needs and, by design, are very rigid. Balanced work schedules have been used for a very long time, not because they’re most efficient, but because they’re common, familiar, and easily understood―and because patrol staff are comfortable with them (and typically reluctant to change). However, short schedules offer a proven alternative to balanced patrol work schedules, and when presented with the benefits of an alternative work schedule design (e.g., increased access to back-up, ease of receiving time off or training, consistency in staffing, less mandatory overtime), many patrol staff are eager to change.

Short schedules

Short schedules involve a more contemporary design that includes a flexible approach that focuses on a more adaptive process of allocating personnel where and when they are needed. They are significantly more efficient than balanced schedules and, when functioning properly, they can dramatically improve personnel deployments, bring continuity to daily staffing, and reduce overtime, among other operational benefits. Given the current climate, most agencies are unlikely to receive substantial increases in personnel allocations. If that is true of your agency, it may be time to explore the benefits of alternative patrol work schedules.

A tool you can use

Finding scheduling strategies that work in this climate requires an intentional approach, customized to your agency’s characteristics (e.g., staffing levels, geographic factors, crime rates, zone/beat design, contract/labor rules). To help guide you through this process, BerryDunn has developed a free tool for evaluating patrol schedules. Click here to measure your patrol schedule against key design components and considerations.

If you are curious about alternative patrol work schedules, our dedicated justice and public Safety consultants are available to discuss your organization’s needs.

Article
Efficient police patrol work schedules―By design

Editor’s note: If you are a state government CFO, CIO, project or program manager, this blog is for you.

What is the difference in how government organizations procure agile vs. non-agile information technology (IT) services? (Learn more about agile here).

In each case, they typically follow five stages through the process as shown in Figure A:
 

Figure A: Overview of Procurement Process for Agile vs. Non-Agile IT Services

However, there are differences in how these stages are carried out if procuring agile vs. non-agile IT services. 

Unfortunately, most government organizations are unaware of these differences, which could result in unsuccessful procurements and ultimately not meeting your project’s needs and expectations. 
This blog series will illustrate how to strategically adjust the standard stages outlined in Figure A to successfully procure agile IT services.

Stage 1: Plan project
In Stage 1, you define the scope of the project by identifying what your organization wants, needs, and can achieve within the available timeframe and budget. You then determine the project’s objectives while strategically considering their impact on your organization before developing the RFP. Figure B summarizes the key differences between the impacts of agile vs. non-agile services to consider in this stage.


Figure B: Plan Project for Agile vs. Non-Agile IT Services

The nuances of planning for agile services reflect an organization’s readiness for a culture shift to a continuous process of development and deployment of software and system updates. 

Stage 2: Draft RFP
In Stage 2, as part of RFP drafting, define the necessary enhancements and functionality needed to achieve the project objectives determined in Stage 1. You then translate these enhancements and functionalities into business requirements. Requirement types might include business needs as functionality, services, staffing, deliverables, technology, and performance standards. Figure C summarizes the key differences between drafting the RFP for a project procuring agile vs. non-agile services.


Figure C: Draft RFP for Agile vs. Non-Agile IT Services

In drafting the RFP, the scope of work emphasizes expectations for how your team and the vendor team will work together, the terms of how progress will be monitored, and the description of requirements for agile tools and methods.

Stage 3: Issue RFP
In Stage 3, issue the RFP to the vendor community, answer vendor questions, post amendments, and manage the procurement schedule. Since this stage of the process requires you to comply with your organization’s purchasing and procurement rules, Figure D illustrates very little difference between issuing an RFP for a project procuring agile or non-agile services.


Figure D: Issue RFP for Agile vs. Non-Agile IT Services 

Stage 4: Review proposals
In Stage 4, you evaluate vendor proposals against the RFP’s requirements and project objectives to determine the best proposal response. Figure E summarizes the key differences in reviewing proposals for a project that is procuring agile vs. non-agile services.


Figure E: Reviewing Proposals for Agile vs. Non-Agile IT Services 

Having appropriate evaluation priorities and scoring weights that align with how agile services are delivered should not be under-emphasized. 

Stage 5: Award and implement contract
In Stage 5, you award and implement the contract with the best vendor proposal identified during Stage 4. Figure F summarizes the key differences in awarding and implementing the contract for agile vs. non-agile services.


Figure F:  Award and Implement Contract for Agile vs. Non-Agile Services 

Due to the iterative and interactive requirements of agile, it is necessary to have robust and frequent collaboration among program teams, executives, sponsors, and the vendor to succeed in your agile project delivery.

What’s next?
The blog posts in this series will explain step-by-step how to procure agile services through the five stages, and at the series conclusion, your organization will better understand how to successfully procure and implement agile services. If you have questions or comments, please contact our team.  

Article
Procuring agile vs. non-agile projects in five stages: An overview

Law enforcement, courts, prosecutors, and corrections personnel provide many complex, seemingly limitless services. Seemingly is the key word here, for in reality these personnel provide a set number of incredibly important services.

Therefore, it should surprise no one that justice and public safety (J&PS) IT departments should also provide a well-defined set of services. However, these departments are often viewed as parking lots for all technical problems. The disconnect between IT and other J&PS business units often stems from differences in organizational culture and structure, and differing department objectives and goals. As a result, J&PS organizations often experience misperception between business units and IT. The solution to this disconnect and misperception? Defining IT department services.

The benefits of defined IT services

  1. Increased business customer satisfaction. Once IT services align with customer needs, and expectations are established (e.g., service costs and service level agreements), customers can expect to receive the services they agreed to, and the IT department can align staff and skill levels to successfully meet those needs.
  2. Improved IT personnel morale. With clear definition of the services they provide to their customers, including clearly defined processes for customers to request those services, IT personnel will no longer be subject to “rogue” questions or requests, and customers won’t be inclined to circumvent the process. This decreases IT staff stress and enables them to focus on their roles in providing the defined services. 
  3. Better alignment of IT services to organizational needs. Through collaboration between the business and IT organizations, the business is able to clearly articulate the IT services that are, and aren’t, required. IT can help define realistic service levels and associated services costs, and can align IT staff and skills to the agreed-upon services. This results in increased IT effectiveness and reduced confusion regarding what services the business can expect from IT.
  4. More collaboration between IT and the organization. The collaboration between the IT and business units in defining services results in an enhanced relationship between these organizations, increasing trust and clarifying expectations. This collaborative model continues as the services required by the business evolve, and IT evolves to support them.
  5. Reduced costs. J&PS organizations that fail to strategically align IT and business strategy face increasing financial costs, as the organization is unable to invest IT dollars wisely. When a business doesn’t see IT as an enabler of business strategy, IT is no longer the provider of choice—and ultimately risks IT services being outsourced to a third-party vendor.

Next steps
Once a J&PS IT department defines its services to support business needs, it then can align the IT staffing model (i.e., numbers of staff, skill sets, roles and responsibilities), and continue to collaborate with the business to identify evolving services, as well as remove services that are no longer relevant. Contact us for help with this next step and other IT strategies and tactics for justice and public safety organizations.

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The definition of success: J&PS IT departments must define services

“The world is one big data problem,” says MIT scientist and visionary Andrew McAfee.

That’s a daunting (though hardly surprising) quote for many in data-rich sectors, including higher education. Yet blaming data is like blaming air for a malfunctioning wind turbine. Data is a valuable asset that can make your institution move.

To many of us, however, data remains a four-letter word. The real culprit behind the perceived data problem is our handling and perception of data and the role it can play in our success—that is, the relegating of data to a select, responsible few, who are usually separated into hardened silos. For example, a common assumption in higher education is that the IT team can handle it. Not so. Data needs to be viewed as an institutional asset, consumed by many and used by the institution for the strategic purposes of student success, scholarship, and more.

The first step in addressing your “big” data problem? Data governance.

What is data governance?

There are various definitions, but the one we use with our clients is “the ongoing and evolutionary process driven by leaders to establish principles, policies, business rules, and metrics for data sharing.”

Please note that the phrase “IT” does not appear anywhere in this definition.

Why is data governance necessary? For many reasons, including:

  1. Data governance enables analytics. Without data governance, it’s difficult to gain value from analytics initiatives which will produce inconsistent results. A critical first step in any data analytics initiative is to make sure that definitions are widely accepted and standards have been established. This step allows decision makers to have confidence in the data being analyzed to describe, predict, and improve operations.
  2. Data governance strengthens privacy, security, and compliance. Compliance requirements for both public and private institutions constantly evolve. The more data-reliant your world becomes, the more protected your data needs to be. If an organization does not implement security practices as part of its data governance framework, it becomes easier to fall out of compliance. 
  3. Data governance supports agility. How many times have reports for basic information (part-time faculty or student FTEs per semester, for example) been requested, reviewed, and returned for further clarification or correction? And that’s just within your department! Now add multiple requests from the perspective of different departments, and you’re surely going through multiple iterations to create that report. That takes time and effort. By strengthening your data governance framework, you can streamline reporting processes by increasing the level of trust you have in the information you are seeking. Understanding the value of data governance is the easy part. The real trick is implementing a sustainable data governance framework that recognizes that data is an institutional asset and not just a four-letter word.
Article
Data is a four-letter word. Governance is not.

If you’ve been tasked with leading a high-impact project for your organization, you may find managing the scope, budget and schedule is not enough to ensure project success—especially when you encounter resistance to change. When embarking on large-scale change projects spanning people, processes and technology, appointing staff as “coaches” to help support stakeholders through the change—and to manage resistance to the change—can help increase adoption and buy-in for a new way of doing things.

The first step is to identify candidates for the coaching role. These candidates are often supervisory staff who have credibility in the organization—whether as a subject matter expert, through internal leadership, or from having a history of client satisfaction. Next, you need a work plan to orient them to this role. One critical component is making sure the coaches themselves understand what the change means for their role, and have fully committed before asking them to coach others. They may exhibit initial resistance to the change you will need to manage before they can be effective coaches. According to research done by Prosci®, a leading change management research organization, some of the most common reasons for supervisor resistance in large-scale change projects are:

  • Lack of awareness about and involvement in the change
  • Loss of control or negative impact on job role
  • Increased work load (i.e., lack of time)
  • Culture of change resistance and past failures
  • Impact to their team

You should anticipate encountering these and other types of resistance from staff while preparing them to be coaches. Once coaches buy into the change, they will need ongoing support and guidance to fulfill their role. This support will vary by individual, but may be correlated to what managerial skills they already possess, or don’t. How can you focus on developing coaching skills among your staff for purposes of the project? Prosci® recommends a successful change coach take on the following roles:

  • Communicator—communicate with direct reports about the change
  • Liaison—engage and liaise with the project team
  • Advocate—advocate and champion the change
  • Resistance manager—identify and manage resistance
  • Coach—coach employees through the change

One of the initial tasks for your coaches will be to assess the existing level of change resistance and evaluate what resistance you may encounter. Prosci® identifies three types of resistance management work for your coaches to begin engaging in as they meet with their employees about the change:

  • Resistance prevention―by providing engagement opportunities for stakeholders throughout the project, building awareness about the change early on, and reinforcing executive-level support, coaches can often head off expected resistance.
  • Proactive resistance management―this approach requires coaches to anticipate the needs and understand the characteristics of their staff, and assess how they might react to change in light of these attributes. Coaches can then plan for likely forms of resistance in advance, with a structured mitigation approach.
  • Reactive resistance management―this focuses on resistance that has not been mitigated with the previous two types of resistance management, but instead persists or endures for an extended amount of time. This type of management may require more analysis and planning, particularly as the project nears its completion date.

Do you have candidates in your organization who may need support transitioning into coaching roles? Do you anticipate change resistance among your stakeholders? Contact us and we can help you develop a plan to address your specific challenges.

Article
How to identify and prepare change management coaches

Truly effective preventive health interventions require starting early, as evidenced by the large body of research and the growing federal focus on the role of Medicaid in addressing Social Determinants of Health (SDoH) and Adverse Childhood Experiences (ACEs).

Focusing on early identification of SDoH and ACEs, CMS recently announced its Integrated Care for Kids (InCK) model and will release the related Notice of Funding Opportunity this fall.

CMS describes InCK as a child-centered approach that uses community-based service delivery and alternative payment models (APMs) to improve and expand early identification, prevention, and treatment of priority health concerns, including behavioral health issues. The model’s goals are to improve child health, reduce avoidable inpatient stays and out-of-home placement, and create sustainable APMs. Such APMs would align payment with care quality and support provider/payer accountability for improved child health outcomes by using care coordination, case management, and mobile crisis response and stabilization services.

State Medicaid agencies have many things to consider when evaluating this funding opportunity. Building on current efforts and innovations, building or leveraging strong partnerships with community organizations, incentivizing evidence-based interventions, and creating risk stratification of the target population are critical parts of the InCK model. Here are three additional areas to consider:

1. Data. States will need information for early identification of children in the target population. State agencies?like housing, justice, child welfare, education, and public health have this information?and external organizations—such as childcare, faith-based, and recreation groups—are also good sources of early identification. It is immensely complicated to access data from these disparate sources. State Medicaid agencies will be required to support local implementation by providing population-level data for the targeted geographic service area.

  • Data collection challenges include a lack of standardized measures for SDoH and ACEs, common data field definitions, or consistent approaches to data classification; security and privacy of protected health information; and IT development costs.
  • Data-sharing agreements with internal and external sources will be critical for state Medicaid agencies to develop, while remaining mindful of protected health information regulations.
  • Once data-sharing agreements are in place, these disparate data sources, with differing file structures and nomenclature, will require integration. The integrated data must then be able to identify and risk-stratify the target population.

For any evaluative approach or any APM to be effective, clear quality and outcome measures must be developed and adopted across all relevant partner organizations.

2. Eligibility. Reliable, integrated eligibility and enrollment systems are crucial points of identification and make it easier to connect to needed services.

  • Applicants for one-benefit programs should be screened for eligibility for all programs they may need to achieve positive health outcomes.
  • Any agency at which potential beneficiaries appear should also have enrollment capability, so it is easier to access services.

3. Payment models. State Medicaid agencies may cover case management services and/or targeted case management as well as health homes; leverage Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) services; and modify managed care organization contract language to encourage, incent, and in some cases, require services related to the InCK model and SDoH. Value-based payment models, already under exploration in numerous states, include four basic approaches:

  • Pay for performance—provider payments are tied directly to specific quality or efficiency indicators, including health outcomes under the provider organization’s control. 
  • Shared savings/risk—some portion of the organization’s compensation depends on the managed care entity achieving cost savings for the targeted patient population, while realizing specific health outcomes or quality improvement.
  • Pay for success—payment is dependent upon achieving desired outcomes rather than underlying services.
  • Capitated or bundled payments—managed care entities pay an upfront per member per month lump sum payment to an organization for community care coordination activities and link that with fee-for-service reimbursement for delivering value-added services.

By focusing on upstream prevention, comprehensive service delivery, and alternative payment models, the InCK model is a promising vehicle to positively impact children’s health. Though its components require significant thought, strategy, coordination, and commitment from state Medicaid agencies and partners, there are early innovators providing helpful examples and entities with vast Section 1115 waiver development and Medicaid innovation experience available to assist.

As state Medicaid agencies develop and implement primary and secondary prevention, cost savings can be achieved while meaningful improvements are made in children’s lives.

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Three factors state medicaid agencies should consider when applying for InCK funding