Advocacy Issues and Take Action
Medicaid Payment Reform
A Population-Based Alternative Payment Methodology (APM) for Health Centers
Background:
In the FY2024 budget, the Legislature included budget boilerplate that directs the implementation of a population-based alternative payment methodology (APM) to delink health center payment from the volume of traditional patient encounters and instead shift reimbursement to a per-patient payment (generally paid per patient per month) for the population of Medicaid beneficiaries participating health centers serve.
Currently, health centers are paid in the Medicaid program through a Prospective Payment System (PPS), which has some value-based aspects (the PPS uses a single bundled payment for multiple services provided in the same encounter) but is still based on the number of traditional patient encounters health centers provide. The PPS’s volume-based structure limits innovation because health centers must design their services around what is reimbursed as a patient encounter, otherwise, the services are not sustainable.
Allowing health centers to transition from the PPS to a population-based alternative payment model (APM) will reduce those limitations and support the adoption of more innovative models of care that are better suited to meet Medicaid patients’ needs. For example, a dietitian is not currently an eligible provider to be reimbursed under the PPS guidelines, but dietitian nutritionists can provide valuable support and care for a diabetic patient and have a significant positive impact on a patient’s healthcare outcomes as part of a patient’s healthcare team.
The population-based APM will allow health centers the flexibility to deliver care in ways that support their patients’ needs and long-term health rather than the confines of the traditional PPS. The APM will provide more predictability in budgeting Medicaid revenue and lessen the administrative burden associated with Medicaid payment today by reducing the number of services that have to go through a time and resource-intensive reconciliation and settlement process.
In the FY2024 budget, the Legislature made a one-time investment of $6 million to support the adoption of the APM. $4 million will be provided to health centers to support their readiness and capacity-building to participate in the APM. The remaining amount will be used by MDHHS to support the implementation of the APM.
Recommendations:
The APM is moving forward in a phased approach to ensure health centers are fully prepared to participate successfully and systems supporting the APM are well constructed. Using the appropriation the Legislature has already made, approximately five health centers will implement the APM in 2026, and approximately another five will in 2027. It will be critical to achieve additional funding in future years to ensure many more health centers are supported in making the transition.
MPCA recommends $18 million in additional one-time funding to support that need. We anticipate the costs of this transition will far exceed the funding request; however, an $18 million appropriation would provide the same degree of critical capacity-building funding and support an additional 20+ health centers that may adopt the APM in 2028 and beyond. That funding will support upfront, specialized training for care team members, redesigning patient care workflows to provide better access and coordination, setting up new policies/processes that each center will need, updating patient care technologies including electronic health records and population health management systems, and ensuring state infrastructure, processes, and technology needed for the APM are in place.
340B Contract Pharmacy State Protections
Overview:
The federal 340B Drug Pricing Program provides health centers access to outpatient drugs at a reduced price. While every health center decides how its 340B savings can best benefit its patients, these savings often support clinical pharmacy programs, extended evening and weekend hours, case management services for at-risk community members, and sliding fee discounts for healthcare services– ultimately increasing patient access to care.
The Challenge:
Many pharmaceutical manufacturers have made it more difficult for 340B entities like health centers to benefit from the savings associated with discounted drugs. They do this by restricting the number of 340B contract pharmacies to which discounted drugs can be distributed.
The Basics:
- Health Centers are the safety nets for their communities.
- The 340B program is critical to help providers stretch their limited resources to better serve their vulnerable communities.
- Health Centers are dedicated to increasing transparency.
- Limitations of contract pharmacies will restrict patient access to discounted medications and cause them to travel further to obtain their medications.
Recommendation:
MPCA recommends supporting SB 94 which will prohibit pharmaceutical manufacturers from limiting health centers’ (and other 340B covered entities’) use of critical contract pharmacy arrangements. This will ensure access for underserved Michiganders who may otherwise struggle to acquire the medications they need.
Health Centers Careers Training Program (HCCTP) Permanence
Background:
The Health Center Careers Training Program (HCCTP) was launched in March of 2022 to train and employ at least 300 new healthcare professionals using a 7.6-million-dollar investment from the Michigan Department of Health and Human Services (MDHHS). Participating health centers receive funding to cover employer costs, including tuition and wages, which avoids prohibitive student loan debt or cost barriers for individuals. To date, 360 individuals have graduated or are currently participating in the HCCTP.
MPCA is approved by the U.S. Department of Labor to serve as an intermediary for health centers transitioning their training programs into Registered Apprenticeship Programs. The HCCTP has enabled rural, urban, and tribal health centers to grow local talent and provide economic opportunities within the low-income, underserved communities in which they operate. MPCA is actively exploring new opportunities to build on the program’s success by innovating apprentice-style training and paid internship opportunities for behavioral health professionals.
Recommendations:
We urge the reinvestment in the Michigan Health Center Careers Training Program (HCCTP) to sustain and expand on-the-job training and registered apprenticeship programs that help overcome barriers to entering health professions. This initiative is critical to rapidly growing the workforce needed to meet healthcare demands in Michigan’s low-income and medically underserved communities.
We propose establishing permanent funding of $2 million per year for the HCCTP program. This funding will empower Michigan Health Centers to maintain their newly established training programs for entry- level health careers and expand internship training models that support the development of critically needed behavioral health professionals. The allocated funding will be utilized to broaden and sustain the HCCTP while fostering the growth of the health center workforce in multiple professions, including medical and dental assistants, community health workers, doulas, medical billers and coders, pharmacy technicians, and opticians. This program model will continue to demonstrate a highly efficient return on investment in an area where growth is desperately needed.
Nurse Practitioner Full Practice Authority
Background:
Full Practice Authority (FPA) is the authorization of nurse practitioners (NPs) to evaluate patients, diagnose, order, and interpret diagnostic tests and initiate and manage treatments-including prescribing medications-under the excusive licensure authority of the state board of nursing.
Michigan is just one of 11 state that restricts NP scope of practice, including requiring NPs to maintain a state-managed agreement with a physician to provide care and treatment for patients.
FPA would bring Michigan’s Public Health Code into alignment with current Michigan Board of Nursing Rules and the national education and practice standards for nurse practitioners.
To date, 27 states have enacted full practice authority for NPs.
Nurse practitioners offer high quality, cost-effective healthcare. Removing barriers to practice creates greater access to care, especially for minority and disadvantaged populations in underserved areas that Michigan’s federally qualified health centers serve. In states with similar PFA statutes, more NPs practice in health professional shortage areas.
Full Practice Authority Will Not:
- Require new or additional third-party
- Require or mandate increased reimbursement rates for healthcare services from healthcare
- Increase medical malpractice liability for
- Allow NPs to form certain corporations independently, e. “Hanging a Shingle” (current law restricts this practice already).
- Interfere with current or future healthcare insurers requirements for direct
- Interfere with current or future practice arrangements made with employers and
- Allow an NP legal authority to practice outside of his/her defined scope of
Recommendations:
MPCA recommends supporting legislation which authorizes NPs to directly apply for control substances license, in addition to maintaining their DEA number registration and requirements of their Board of Nursing License. NPs have been safely prescribing controlled substances in the state for decades. Defining the scope of practice for NPs based on their national certification is consistent with the Board of Nursing rules.


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