Minnesota Hospital Association

Policy & Advocacy

rules, regulations and comments

The Minnesota Hospital Association continually monitors state and federal rules and regulations to keep members informed and advocates on behalf of members regarding the impact of regulations on the state’s hospitals and health systems. MHA submits comment letters to share recommendations and feedback with the appropriate government organizations and health care stakeholders. Examples of rules and regulations that MHA addresses include those implementing federal or state health care reform efforts, changing payment methodologies, establishing community benefit or other standards for tax-exempt organizations, or modifying government oversight of health care activities.

February 03, 2015

MHA comments regarding Governor Dayton's proposed budget

February 2, 2015

The Honorable Tony Lourey and
Members of the Senate Health & Human Services Finance Committee
G-12 Capitol
75 Rev. Martin Luther King, Jr. Blvd.
St. Paul, MN 55155-1606

Dear Senator Lourey and members of the Committee:

On behalf of the Minnesota Hospital Association (MHA) and our members, which include 143 hospitals and health systems that care for patients and strengthen healthy communities throughout the state, I am pleased to offer the following comments regarding Governor Dayton's proposed budget. These comments focus on those elements of the proposed budget that are particularly important to MHA's members, the needs of health care patients, and Minnesotans.

Mental Health
As MHA looks at the proposed budget, we are pleased that it reflects our commitment to one of the highest policy priorities facing our state: the critical need to expand access to mental health care,especially community-based, non-hospital care.

Recently, Minnesota's nonprofit hospitals conducted community health needs assessments and prioritized the most pressing issues. Almost without exception, mental health care ranked as one of the top three most urgent needs of every community. The aggregate amount of additional funding recommended for mental health reforms and investments is $45 million for FY2016-17. MHA encourages you to appropriate these funds so we can begin to address the widespread issues that keep our mental health system from adequately caring for Minnesotans.

Throughout the state, patients in need of mental health care resort to hospital emergency rooms because they can't find other available mental health services in their community. Across the state,mental health patients stay for days or weeks in hospitals waiting for space in more appropriate settings to open up. And, far too often, when space does become available, it is hundreds of miles away from their homes and support systems.

Transitions to Community Initiative
One of the most important proposals is expanding eligibility for the Transitions to Community Initiative, which will allow more people to receive community-based services so they do not need to rely on the limited resources and capacity of Anoka-Metro Regional Treatment Center (AMRTC) or other state operated facilities. Because the most difficult patients for hospitals to place in more appropriate care settings are often those with violent or aggressive behaviors who need the specialized services of AMRTC, this proposal is strongly supported by MHA and our members because longer stays in the hospital not only delay the most appropriate level of care that these patients need, they also increase the risk of injury for our employees, as well as other patients.

Crisis and Intensive Residential Services
Of course, it is even better for the individual and our mental health system if we can deliver services earlier and more effectively to avoid the need for hospitalization altogether. This is why MHA supports multiple pieces in the proposed budget that are designed to increase the state's capacity to provide crisis and intensive residential services throughout the state. These proposals include the following:

  • $4.6 million for mental health crisis services;
  • $2.59 million for additional Intensive Residential Treatment Services (IRTS), as well as $5.51 million for stabilizing reimbursements for IRTS and crisis teams; and
  • $1.32 million for expanding the number of and quality of care provided by Assertive Community Treatment (ACT) teams.

All of these proposals are designed to deliver services for those experiencing a mental health crisis or who would otherwise suffer further exacerbation of their conditions and increase the likelihood that they end up needing emergency room or inpatient care.

Generally, MHA supports the policy of making a significant investment of $6.62 million for 150 beds in Psychiatric Residential Treatment Facilities (PRTFs) for children and adolescents. We need to gather more feedback from our members with respect to the administration's intention to rely on extended-stay contracts with hospitals for an additional 30 beds.

Behavioral Health Homes
Going even further upstream, the proposed budget recommends funding to advance Behavioral Health Homes, which is a new care delivery model for people with serious mental illness. Behavioral Health Home clinics will integrate mental and physical health care services to better coordinate and manage these patients' overall health. Over a two year period, patients in a similar project in New York had 15% fewer ER visits and their hospital admissions plummeted 45%. MHA believes that New York's results offer a compelling example of the improved care and decreased utilization we can achieve in Minnesota.

Mental Health Provider Education
There are elements of the proposed budget that serve as a helpful starting point for the Legislature and, in the end, we hope are expanded when a final budget is adopted. For example, the governor's proposed budget seeks $354,000 to fund a new public sector psychiatry residency position. MHA supports creating this new position, but we would like to see at least four new mental health residencies, including at least one that is dedicated to child or adolescent mental health delivery. To address the unmet and growing mental health needs in our communities, Minnesota needs to begin investing in developing a larger number of mental health providers.

Mental Health Transportation
If the state's projected surplus is larger in the upcoming February budget forecast, MHA encourages the Committee to consider appropriating funds for grants to communities willing to conduct pilot projects to test new arrangements for transporting mental health patients from a hospital to another care site. Today, many hospitals and communities struggle to arrange for these transports because law enforcement agencies are increasingly unwilling to devote officers and squad cars for the potentially long drives and, likewise, many ambulance services are reluctant to devote EMT and ambulance time for these non-emergent trips. Instead, MHA believes that protected transportation models can provide a safe, efficient option for transferring patients without the anxiety and stigma that come with riding in a squad car.

MHA thanks the administration for recognizing and offering steps to address our state's mental health care needs. Every aspect of our health care system and every business, school and governmental unit is more strained today because of unmet mental health care needs. These budget proposals will increase access to needed mental health care, and take important steps toward a healthier and more productive Minnesota.

Ebola Preparedness
The potential spread of the Ebola virus to communities in Minnesota led to a rapid, statewide effort to ensure that our health care delivery system is ready to identify, transfer and, if necessary, treat a patient suffering from Ebola. These activities, including training and drills for our hospital staff, obtaining additional equipment and supplies, and even altering existing facilities required significant and unexpected expenditures for Minnesota's hospitals. Accordingly, MHA is grateful that the proposed budget includes recommended funding to partially offset some of the costs hospitals incurred.

Stabilizing Certain Hospital Payments
There are key hospital provisions in the Governor's proposed budget that MHA wants to highlight. As the Minnesota Department of Human Services (DHS) continues to formulate new inpatient hospital payment rates for our Medical Assistance program, it has identified a couple of potential problems that might arise from the rebasing unless legislation is enacted this year. To avoid these problems, the administration has proposed and MHA supports $5.2 million of additional state spending.

The first proposal will help our smallest, rural hospitals avoid potential problems resulting from the required rebasing of Medical Assistance rates. To maintain access to inpatient care for Medical Assistance enrollees in our rural communities, it is necessary to have hospital payment rates that will not put small, Critical Access Hospitals in financial jeopardy.

The other proposal will eliminate the statutory caps on reimbursement for vaginal and caesarean births. MHA understands the policy rationale for imposing these caps under the traditional Medical Assistance reimbursement methodology, but the new more differentiated payment system DHS is developing no longer needs to artificially limit reimbursement for these services because they will be weighted relative to all other services. Moreover, because the statutory caps are significantly below the actual costs hospitals incur, the current policy unduly harms those hospitals that have a large number of births each year.

We strongly support these recommendations and appreciate the administration's recognition of the need to head off these unintended consequence of rebasing inpatient payment rates.

Conclusion
MHA continues to review and evaluate the details contained in the numerous proposals put forward in the governor's budget. Many proposals require us to have additional conversations with our members in order to ensure that our advocacy aligns with the best interests of our patients and communities. MHA looks forward to further discussions of the budget and to working with you to ensure that the priorities outlined above are key elements in the state's biennial budget.

Sincerely,
Lawrence J. Massa, M.S., FACHE
President and CEO