Meaningful Systemic Stakeholder Involvement

A person centered care delivery system should include meaningful consumer engagement at all levels of the system.  Consumer and advocacy groups that participate in planning systems for managed care should be provided with support, within conflict-of-interest guidelines, to promote beneficiary awareness of and expectations for HCBS, advocate for an appropriate balance between medical and LTSS supports, and translate consumer concerns into specific policy recommendations, action plans, and goals.  After integration has been implemented, consumer involvement should extend into ongoing monitoring through representation in standing advisory groups at both a state and local plan level.

  • The state must have a stakeholder advisory board that includes Medicaid-eligible beneficiaries to advise it on all aspects of the planning, implementation and operation of the managed care program.  The advisory board should continue through program implementation.  Individuals with a range of LTSS service needs and their representatives and advocates must be included.
  • Each MCO must have a standing consumer advisory committee that includes seniors, younger persons with disabilities, and family members of individuals enrolled in plans.  A range of disabilities should be represented and users of a range of LTSS must be included. The advisory committee will advise the MCO on all policies and practices affecting the experience of care, have access to information regarding the MCO’s policies and practices as well as grievance and quality measure information, and make recommendations for changes in policy or practice to be presented to the MCO’s governing board.
  • Every MCO must convene meetings with its members at least quarterly to document fully all grievances raised by individuals at the meetings, to keep comprehensive minutes of all member meetings that are made available to all individuals, and to provide written responses to all articulated grievances prior to the convening of the next member meeting. The MCO’s should notify all members at least 15 days prior to each meeting regarding the date and location of the meeting, and offer to assist with transportation to the meeting if the member cannot travel independently.  Telephone access or other provisions should be made for participation by people who cannot travel.
  • Individuals participating in state or MCO stakeholder processes should be connected to advocacy organizations with the necessary expertise to assist them in understanding state and federal laws, contracts and guidance that spell out CMS, state and MCO requirements.  These organizations can also help stakeholders identify and recommend solutions to systemic problems in the MCO.
  • All of the above meetings should be held in locations that are physically accessible.  Accommodations such as sign language interpreters must be available for individuals requesting them.
  • To ensure meaningful consumer participation, there must be transparency at the state and plan level.  Agreements between and among CMS, the state and the MCO must be made public.  Results of readiness reviews, evaluations and quality measures must also be made public.  MCOs, as they are performing a state function, must be subject to state freedom of information act laws.
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