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Leavitt Partners Releases “Moving Forward Together” White Paper
Salt Lake City, July 24, 2019—Today, Leavitt Partners released a new white paper, “Moving Forward Together: Opportunities to Improve Program Integrity in Medicaid Non-Emergency Medical Transportation.” This paper examines Medicaid’s non-emergency medical transportation (NEMT) benefit and makes specific recommendations on key actions federal and state policymakers can take to improve program integrity. The recommendations were based on a robust analysis of existing research, as well as interviews with former Medicaid program staff, Medicaid managed care organizations, a transportation network company, NEMT transportation brokers, a medical provider trade association, and other Medicaid stakeholders.
The white paper is authored by Josh Trent, principal at Leavitt Partners, and Charlene Frizzera, senior advisor at Leavitt Partners, who both shaped federal Medicaid policy during previous roles in Congress and the Centers for Medicare & Medicaid Services (CMS), respectively.
The paper examines Medicaid’s non-emergency medical transportation (NEMT) benefit and makes specific recommendations on key actions that federal and state policymakers can take to improve program integrity. The recommendations were based on a robust analysis of existing research, as well as interviews with former Medicaid program staff, Medicaid managed care organizations, a transportation network company, NEMT transportation brokers, a medical provider trade association, and other Medicaid stakeholders.
NEMT “enables Medicaid beneficiaries who lack reliable sources of transportation to use a benefit that will ensure they can access their primary care provider, dialysis appointment, child wellness check-up, addiction treatment, and other forms of non-emergent care,” Trent and Frizzera explain. “Patients who are low-income, who have multiple chronic conditions, or who face challenges related to the social determinants of health are too often challenged in accessing reliable transportation to and from health care providers.” Trent and Frizzera highlighted how the Medicaid “benefit helps to remove transportation barriers to needed health services, improve health outcomes, and reduce utilization of more expensive emergency services,” concluding that “for many patients who lack reliable transportation, the value of the NEMT benefit is clear.”
However, Trent and Frizzera also underscore that “states have faced challenges with program integrity in administering NEMT to beneficiaries.” Highlighting recent examples of oversight audits and enforcement actions, the authors warn “improper payments can undermine the quality of care for Medicaid beneficiaries, create reputational damage for entities involved in delivering the NEMT benefit, and erode public support for Medicaid services.” At the same time, they note that “many of the opportunities to improve program integrity within the Medicaid NEMT benefit may not be specific to NEMT per se, as much as they are reflective of challenges facing Medicaid more generally.”
“Moving Forward Together” calls for “vigilance through strong program management and risk management strategies to protect the program from those who would exploit or defraud the program and could cause harm to Medicaid beneficiaries.” Toward that end, the white paper specifically outlines key areas that Medicaid programs are focusing on to improve program integrity: ensuring access to qualified transportation providers, harnessing technological tools, and utilizing ride-sharing platforms in an appropriate manner.
“The delivery of Medicaid NEMT services has evolved in the last decade or so, as external forces have created new opportunities and placed new expectations on the program,” Trent and Frizzera write. “Abundant research and program audits show the need for additional federal and state actions to improve the program integrity of Medicaid NEMT services,” the authors explain. “Moving forward,” they wrote, “It is essential that Medicaid leaders across Medicaid state programs, brokers, managed care plans and delivery systems work collaboratively to improve the integrity of the program for the benefit of patients and the program itself.”
Key recommendations are that:
- CMS should:
- Update NEMT program integrity review
- Facilitate collaboration onleading practices
- Provide technical assistance to states
- Implement the U.S. Government Accountability Office’s open recommendation
- Require basic program integrity
- Analyze the Transformed Medicaid Statistical Information System data for insights
- State Medicaid programs should:
- Require public transparency of key Medicaid NEMT data
- Leverage existing data to continually improve program integrity
- Position state systems to detect and prevent known fraud schemes
- Use prior approval strategically
- Ensure robust complaint and Medicaid appeals processes for beneficiaries
- Use contracting arrangements to incentivize program integrity and quality
- Transition to/between transportation brokers with careful planning
- Consider the role of TNCs and use them strategically
The white paper can be viewed here.
About Leavitt Partners:
Leavitt Partners is a health care intelligence business. The firm helps clients successfully navigate the evolving role of value in health care by informing, advising, and convening industry leaders on value market analytics, alternative payment models, federal strategies, insurance market insights, and alliances. Through its family of businesses, the firm provides investment support, data and analytics, member-based alliances, and direct services to clients to support decision-making strategies in the value economy. For more information please visit www.LeavittPartners.com.