Community Health Services — The Oklahoma Health Care Authority (OHCA) is seeking approval of emergency rules and a state plan amendment to provide coverage and reimbursement for community health services. These services are performed by community health workers (CHW) within a public health clinic setting. CHWs are critical members of the public health workforce who assist the community with access to services. Specifically, CHWs will be able to provide various screening assessments, health education, health system navigation, and other advocacy-type services. The request to provide coverage for CHWs came from the Oklahoma State Department of Health (OSDH), who will provide the state funding.
Please view the Public Notice ; draft State Plan Amendment #24-0024 and draft rules here: APA WF # 24-34. You may submit feedback via the comment box.
Tribal Consultation: 4/30/24
Circulation Date: 11/5/24
Comment Due Date: 11/19/24
Medical Advisory Committee (MAC) Meeting: 11/7/2024
Board Meeting: 12/11/2024
Submit a Comment
After you submit your comment, you should be re-directed to a confirmation page. If you are not, please submit your comment through e-mail to federal.authorities@okhca.org.
Please note that all comments must be reviewed and approved prior to posting. Approved comments will be posted Monday through Friday between the hours of 7:30 a.m. – 4 p.m. Any comments received after 4 p.m. will be posted on the following business day.
Comments
Gao:
Do FQHC facilities qualifies to bill for CHS services under Fee for service?
OHCA Response: FQHCs will not qualify for reimbursement under this CMS authority.
James:
Reimbursing for Community Health Worker services to patients served by OK Federally Qualified Health Centers and private physician clinical practices, in addition to public health clinic settings could greatly assist the OSDH in its goals of improving quality and reducing costs for patients suffering from chronic illnesses such as Diabetes and Cardiovascular disease. Proven models of integrating CHWs into the primary care workforce has been described in the peer-reviewed literature illustrating the value of adding the CHW's skill set(s) to our stressed delivery system. Fee-for-Service reimbursement for CHW services is a first step in this process. Future value-based contracts could include incentives for implementing evidence-based models leveraging CHWs in accelerating quality improvement performance and further reducing the rate of inflationary growth of health care expenditure for high-risk populations living in low-resourced communities.
OHCA Response: Thank you for your feedback.
Steve:
Under these proposed rules, will CHW reimbursement include assistance with SoonerCare enrollment or renewals; income and other document preparation and uploads; retroactive coverage applications; plus other OHCA-required forms to access coverage? Will reimbursement also include the similar processes to access medical coverage through the Oklahoma Human Services Department? The draft SPA mentions: "Health system navigation and ...assist beneficiaries with access" but does not use the word "enrollment". (This question is *not* about any per-enrollment reimbursement, but rather whether specific enrollment assistance is part of the reimburseable CHW duties.) Thank you.
OHCA Response: Reimbursement will not be available for assistance provided for initial enrollment, as only contracted choice counselors may help enroll SoonerSelect members. For agency partners, per the contract, they must be employees of the agency and cannot be contracted, and this is not a billable service.
The “health system navigation” and “social resource navigation” services of a CHW do include assistance with completing applications or enrollments that will increase access to care and services to help address health and social needs.
Jeffrey:
Community health care workers (CHWs) play a vital role in enhancing patient care and improving health outcomes, particularly in underserved communities. Their ability to connect individuals with necessary services can lead to significant improvements in health metrics. The Oklahoma Health Care Authority (OHCA) is currently seeking approval for emergency rules and a state plan amendment to provide coverage and reimbursement for community health services delivered by CHWs. This initiative is crucial as it recognizes the value CHWs bring to public health clinics.
Statistics from other states demonstrate the positive impact of reimbursing CHW services. For instance, in Massachusetts, where CHWs are reimbursed for their services, studies have shown that patients who receive support from CHWs are 50% more likely to attend follow-up appointments and report improved health outcomes compared to those who do not have access to CHW services (Massachusetts Department of Public Health). Similarly, Texas reports that integrating CHWs into care teams has led to a 12% reduction in emergency room visits among participants in a Medicaid program (Texas Health and Human Services).
Yale Drug, Foster Corner Drug, and Cornwell Pharmacy are proud to have community health care workers as part of their teams. These pharmacies exemplify how integrating CHWs into community health initiatives can enhance patient care. CHWs at these pharmacies assist with health education, facilitate access to screenings, and help navigate the healthcare system, making a significant difference in the lives of their patients.
The funding and reimbursement for CHW services proposed by the OHCA will not only support these essential roles but also ensure that communities have greater access to quality health care. By investing in community health services, Oklahoma can replicate the successes seen in other states, driving better health outcomes and promoting health equity across the state.
In summary, community health care workers are indispensable in bridging gaps in healthcare access and education. Supporting their roles through reimbursement will strengthen public health initiatives and ultimately lead to healthier communities.
OHCA Response: Thank you for your feedback.
Kacee:
Community Health Workers (CHW) have been shown to improve public health by identifying and resolving Social Determinants/Drivers of Health issues.
Community pharmacies are the most accessible health care locations. Therefore, embedding CHWs in community pharmacies is an ideal scenario for targeting public health issues.
Pharmacy technicians trained as CHWs build rapport with patients through the prescription dispensing process and become a trusted partner in a patient's care. CHWs can incorporate health risk assessments, mental health screenings, SBIRT, blood pressure monitoring, and vaccinations into routine encounters at the pharmacy as well as help patients navigate the prescription dispensing process including monitoring for adherence.
At least 11 pharmacies in Oklahoma have a pharmacy technician trained as a CHW through a 16-week course funded by Southwestern Oklahoma State University College of Pharmacy and the Oklahoma State Department of Health. These pharmacies have taken the initiative to provide CHW services accessible to their community. However, these services are currently unfunded by OHCA, and therefore, not fully optimized. It is important that OHCA recognize CHW services in all healthcare settings, not just in a public health clinic setting. In addition, it is important that CHW services be billable under a pharmacist or a pharmacy to take full advantage of CHW accessibility in this setting.
OHCA Response: Thank you for your feedback. To provide input to efforts to expand CHW coverage further please reach out to the Office of Community Health Workers through the Oklahoma State Department of Health.
Steve:
More clarification needed, please:
Initial applications or re-activations for SoonerCare can be completed with no SoonerSelect choice required. If a CHW does not counsel about SoonerSelect, plan options or assist with SoonerSelect plan selection, is reimbursement for CHW services available for an initial application or re-activation for SoonerCare?
The “health system navigation” and “social resource navigation” services of a CHW do include assistance with completing applications or enrollments that will increase access to care and services to help address health and social needs.
OHCA Response: Reimbursement will not be available for assistance provided for Medicaid enrollment as this is not a billable service through Medicaid, but the “health system navigation” and “social resource navigation” services of a CHW do include assistance with completing applications or enrollments - including those with other governmental entities - that will increase access to care and services to help address health and social needs.
Jake:
I represent a clinically integrated network of community pharmacies that specialize in addressing health-related social needs. These pharmacies incorporate CHWs into day to day practice with significant patient and public health outcomes. Our various publications showcasing the impact of a CHW in pharmacy practice may be found here (https://www.choosemypharmacy.com/newsresearch-1). Most notable is the sustainability of the CHW role in a pharmacy AND health outcomes (one vaccine hesitancy program has a cost savings in the tens of millions of dollars)
OHCA Response: Thank you for your feedback.