Certainly, we expect the same HCFA vigilance for the Medicaid patient population. We do appreciate HCFA s commitment to assuring access to specialist care for enrollees with complex and serious medical conditions. These procedures must include for a specified time period, direct access to specialists as required by the treatment plan and updated periodically by the physician responsible for the overall coordination of the enrollee s health.
Examples given include depression and direct access to a specialist for psychotherapy.
However, APA wants to apprise HCFA of our concern that under these MCOs, psychiatrists may not be permitted to provide the full range of services within their scope of licensure. We believe HCFA must closely monitor the range of psychiatric services provided Medicaid patients, and particularly those provided by psychiatrists. We want to strongly encourage HCFA to closely monitor state agency and MCO procedures to identify any problems or disruptions in the continued treatment of patients with a mental illness including substance abuse, and provide the direction to the state agency and MCO to facilitate effective solutions. In closing, APA requests that HCFA revise these Medicaid managed care proposed regulations and incorporate our suggestions and recommendations into the final regulations.