We write in response to the limitation of Case Management service Medicaid reimbursement being directed to only Community Services Boards. We appreciate the opportunity to register concern with this stipulation and the associated challenges that community-based providers encounter with the provision of this service.

Gateway Homes, Inc. has been serving individuals with serious mental illness diagnoses since 1983. Over the years, we have provided a spectrum of residential support and wrap-around mental health supports that reflect over 90% year to year success rate in the community. We have worked with every Community Services Board across all regions in the Commonwealth, and we consistently observe that with few exceptions, once clients come to Gateway, the CSB exits their care. Some even disenroll their clients from their CSB services because they know that Gateway provides them regardless of their mandate to do so. In direct contradiction, CSBs appear to continue to bill Medicaid for clients they are not serving, which does not meet the published expectations of DMAS. This seems to be a major concern for waste, fraud, and abuse.

Meanwhile, Gateway continues to provide the services necessary to support the individuals to move towards their self-identified recovery and independence goals. Gateway’s case management services far exceed the expectations outlined in the chapter and we, and all other community-based providers, continue to be barred from access to the reimbursement for these services.

This gross oversight categorically denies individuals the right of choice in providers for this service, reinforces a system that does not provide the proscribed service appropriately, and continues to put the burden of mental health care on community-based providers without remuneration. At a time when DMAS is actively working towards the implementation of supposed cost neutral changes, there appears to be a disconnect between reality and funding availability. Will every CSB be required to maintain case management accreditation as part of the CPST roll out or will special consideration be levied to ensure that state agencies benefit from less expectations without sufficient oversight and more reimbursement?

We ask that DMAS review this and allow clients their freedom of choice in providers, which will thereby require:

• cooperation with DBHDS Office of Licensing for there to be an opening of gates to case management licensure,
• case management designation within DMAS portal, and
• expand client access to providers that can and do already exceed the expectations of the case management service and have better outcomes than CSBs.