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Ohio’s Managed Care Overhaul Delayed – New Implementation Timeline

Client Alert

At the direction of Governor Mike DeWine, the Ohio Department of Medicaid (ODM) launched the Medicaid Managed Care Procurement process in 2019. ODM’s stated vision for the procurement was to focus on people and not just the business of managed care. This is the first structural change to Ohio’s managed care system since the Centers for Medicare & Medicaid Services' (CMS) approval of Ohio’s Medicaid program in 2005. Initially, all of the new managed care programs were supposed to be implemented starting on July 1, 2022. However, ODM Director Maureen Corcoran recently confirmed that this date will be pushed back for several managed care-related programs.

What Caused the Delay?

Like many plans over the past two years, ODM’s rollout of the Next Generation of Managed Care was delayed partially as a result of COVID-19. The federal government is not expected to renew the public health emergency status beyond mid-July, which will trigger the required eligibility redetermination of millions of Medicaid beneficiaries. Until then, Medicaid is barred from removing anyone from the program while receiving enhanced federal matching funds provided in response to the pandemic. In order to minimize disruption for all Medicaid beneficiaries, the phased approach to introducing the new managed care system will allow time for the public health emergency to end and the new managed care plan coverage to begin. Additionally, ODM states that the staggered start will also promote continuity of care, limit confusion, and provide adequate time for provider testing and training.

The New Plan

Originally, ODM was supposed to roll out seven new managed care plans, centralized credentialing, a single pharmacy benefit manager, and a new managed care plan for multi-system youth called OhioRISE on July 1, 2022. For the reasons named above, ODM is now instituting a staggered start. Here is the new implementation schedule:

  • Stage 1, July 1, 2022 – OhioRISE: OhioRISE will provide care coordination and specialized services to help children and youth with behavioral health needs who receive care across multiple systems. The program builds on the launch of a statewide network of community-based care management entities; the design and implementation of the Child and Adolescent Needs and Strengths assessment tool; and the completion of extensive community and provider training sessions for more than 1,650 participants.
  • Stage 2, October 2022 – Centralized Provider Credentialing & Single Pharmacy Benefit Manager: Centralized Provider Credentialing (CPC) will provide a single place for provider credentialing rather than forcing providers to be credentialed with each individual managed care plan. Medicaid will implement CPC through the Ohio Medicaid Enterprise System (OMES) Provider Network Management (PNM) module, which aims to reduce administrative burdens on providers and will largely replace the current MITS system. Additionally, in Stage 2, the Single Pharmacy Benefit Manager (SPBM) will begin providing pharmacy services across all managed care plans and members.
  • Stage 3, 4th quarter of 2022 – Next Generation Managed Care Plans: ODM will finish the three-phase implementation with the opening of all seven Next Generation Managed Care Plans to provide healthcare coverage under the new program. ODM will also complete the OMES implementation by launching the Fiscal Intermediary (FI), which seeks to simplify and streamline the provider process for submitting claims and prior authorizations.

Incumbent plans will still continue to operate as usual, including UnitedHealthcare Community Plan of Ohio, Molina Healthcare of Ohio, CareSource Ohio and Buckeye Community Health Plan. New plans include Humana Health Plan of Ohio, AmeriHealth Caritas of Ohio and Anthem Blue Cross and Blue Shield. Patients will have the opportunity to stay with their current plan or switch to a new one.

If you have any questions about any of the new Medicaid programs and how they may impact your practice, please reach out to your local BMD Healthcare Attorney or Ashley Watson at abwatson@bmdllc.com.


Latest Batch of Ohio Chemical Dependency Professionals Board Rules: What Providers Should Know

The Ohio Chemical Dependency Professionals Board recently released several new rules and proposed amendments to existing rules over the past few months. A hearing for the new rules was held on February 16, 2024, but the Board has not yet finalized them.

Now in Effect: DOL Final Rule on Classification of Independent Contractors

Effective March 11, 2024, the U.S. Department of Labor (DOL) has adopted a new standard for the classification of employees versus independent contractors — a much anticipated update since the DOL issued its Final Rule on January 9, 2024, as previously discussed by BMD.  In brief, the Fair Labor Standards Act (FLSA) creates significant protections for workers related to minimum wage, overtime pay, and record-keeping requirements. That said, such protection only exists for employees. This can incentivize entities to classify workers as independent contractors; however, misclassification is risky and can be costly.

Florida's Recent Ruling on Arbitration Clauses

Florida’s recent ruling on arbitration clauses provides a crucial distinction in determining whether such clauses are void as against public policy and providers may have the opportunity to include arbitration clauses in their patient consent forms. On March 6, 2024, Florida’s Fourth District Court of Appeals reversed and remanded Florida’s Fifteenth Circuit Court ruling of Piero Palacios v. Sharnice Lawson. The Court of Appeals ruled that the parties’ arbitration agreement did not contradict the Legislature’s intent of Florida’s Medical Malpractice Act (the “MMA”), but rather reflects the parties’ choice to arbitrate claims entirely outside of the MMA’s framework. Therefore, the Court found that the agreement was not void as against public policy.

Corporate Transparency Act Update 3/14/24

On March 1, 2024, a federal district court in the Northern District of Alabama concluded that the Corporate Transparency Act (“CTA”) exceeded Congressional powers and enjoined the Department of the Treasury from enforcing the CTA against the plaintiffs. National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.). On March 11, 2024, the U.S. Department of Justice appealed the district court’s decision to the Eleventh Circuit Court of Appeals.

The Ohio State University Launches Its Accelerated Bachelor of Science in Nursing Program

In response to Ohio’s nursing shortage, The Ohio State University College of Nursing is accepting applications for its new Accelerated Bachelor of Science in Nursing program (aBSN). Created for students with a bachelor’s degree in non-nursing fields, the aBSN allows such students to obtain their nursing degree within 18 months. All aBSN students will participate in high-quality coursework and gain valuable clinical experience. Upon completion of the program, graduates will be eligible to take the State Board, National Council of Licensure Exam for Registered Nursing (NCLEX-RN).