We are very excited to announce today a comprehensive effort to improve the experience of our members, patients and purchasers in the area of mental health care.
This California statewide initiative is the result of nearly a year of intensive work that was done in partnership with the Customer Advisory Group sponsored and organized by the Pacific Business Group on Health to better understand the needs and preferences of our members and patients so that we deliver the level of service they are seeking. In developing this improvement initiative, we asked directly for feedback about our mental health services, including feedback from focus groups with hundreds of our members and patients who had received mental health services, as well as from employers.
The improvements we seek to make have been informed by what we’ve heard and learned from our patients and members, from customers, from independent experts, and from our own physicians, therapists, and staff. They include:
- More convenience in appointment times, office hours, and locations for mental health care services, and an improved level of customer service before and after appointments. We are going to be working with staff and receptionists to be responsive to issues raised by members about privacy, as well.
- Better engagement with patients to create treatment plans with them, so that the goals of their treatment are well defined and understood. We will also take steps to help patients more effectively manage their care, including choosing their own therapist.
- Adding more individual therapy as part of a multi-modal treatment plan. When it comes to different ways of providing treatment, we have never approached mental health care as one-size-fits-all, and we are proud of our unique ability to offer many modes of treatment in a personalized plan. We also recognize that patients have preferences within their individualized treatment plans. We will take steps for our patients to develop a relationship with a therapist early on in treatment, one who can assist them in accessing the forms of treatment that best meet their personal needs, including individual and group therapy.
The goal of this effort goes beyond improving the experience of our patients in the near term. Our goal is to help define the vision of a model for 21st century mental health care that will be based on evidence of what works, measurable outcomes and integration of emerging technologies — all necessary parts of an improved way of treating mental health needs. We believe that three of the key elements of this new model of care should include:
- Maximizing the benefits of Kaiser Permanente’s integrated system, so that mental health and primary care are appropriately connected, and our members’ mental health needs are not addressed in insolation from the rest of their health care. Kaiser Permanente’s integrated system, in which all parts are working together to benefit the member, is held as a model for the country, and makes Kaiser Permanente well positioned to lead in this area.
- Expanding the use of outcomes research to guide care — doing what works best to get people better.
- Investigating new ways to use technology where it can enhance mental health care and convenience, understanding that technology is such a growing aspect of society and patients’ daily lives.
In order to focus our energy on productive performance improvement efforts, Kaiser Permanente has informed the Department of Managed Health Care (DMHC) that it is paying the penalty proposed by the DMHC in 2013. We continue to disagree with the basis and size of the penalty as excessive and disproportionate to the findings in the department’s survey. We believe that we were not in violation of the timely access regulations and that the DMHC penalized us even though we met the compliance standards that the DMHC expressly approved. The DMHC’s survey did not identify problems with the quality of the mental health care provided to our members or with the ability of our members to obtain urgent or emergency mental health care. The DMHC did identify some areas where our initial non-urgent appointment wait times and data tracking needed improvement. We took the findings seriously and implemented a corrective action plan.
We decided to contest DMHC’s proposed fine because it was unwarranted and excessive, and they ignored the very compliance standards that they had expressly approved. We believe in continuous performance improvement. We acknowledged that we could have better access and we have in fact improved our access. Rather than continue to focus on the past, we are going to continue with our patient-centered improvement efforts, and forego the expense and distraction of litigation.
It also became apparent that contesting this case does nothing to compel the DMHC to apply clear and fair standards to all health plans in California. We wish to focus all of our energy on our continuing efforts to enhance mental health care for our members and meet their needs. We also call upon the DMHC to engage in an open and fair process of defining standards for timely access to mental health care services and apply these standards equally to all health care service plans in California.
Background: Continuous Improvement at Kaiser Permanente
A critical part of Kaiser Permanente’s leadership as a high-quality care provider is always working to improve the care we provide. So while we provide our members and patients with high quality mental health care that care is highly rated by independent agencies, and is recognized for including best practices, especially around the integration of primary care and mental health care, we have continued to work on getting even better. Kaiser Permanente is a learning organization, which means we are dedicated to continuous improvement and regularly review our care in order to improve.
In fact, we have been making changes and improvements over the years — based on our accumulating clinical experience and research — to the way we approach and deliver mental health care, including:
- Leading with innovative approaches to mental health care in the emergency department.
- Continually analyzing our staffing levels throughout our care delivery system, and hiring appropriate mental health providers to meet growth in membership and our members’ needs.
- We contract with community-based providers in some areas to ensure access to services for our members at times of increased demand that exceeds the current capacity of our therapists.
We have been deliberate in our process of self-evaluation, and have made changes thoughtfully so as not to disrupt what is working so well, but rather improve what we already have.
As an integrated system with thousands of mental health care professionals, we believe we are well positioned to maintain the important responsibility we have for providing excellent mental health care, especially in the face of the growing number of Americans needing and seeking care. We also believe we can have an important role in helping advance the care and treatment of people who need mental health care.
Background: DMHC Timely Access Regulations
The timely access regulations at issue in the DMHC survey became effective in January 2011, establishing wait time standards for offering initial and urgent appointments.
In March 2011, DMHC approved a Compliance Standard for Kaiser Permanente under the timely access regulations based in part on Average Days Wait from request to actual appointment date. This is a standard that is more stringent than the regulations, which only require the “offer” of a timely appointment. Kaiser Permanente’s performance exceeded this DMHC approved compliance standard.
Kaiser Permanente is the only health plan in California that actually counts the wait time for every initial appointment. DMHC does not require any other plan to demonstrate actual wait time data.
However, DMHC through its survey determined that the previous approved standard was not adequate. DMHC then penalized Kaiser Permanente for using the same compliance standard that the department expressly approved in 2011. It imposed an excessive fine, even though the department’s own clinical reviewers did not find fault with the quality of care Kaiser Permanente provides to its members.
Although we believed the DMHC’s conduct was unfair, almost two years ago, Kaiser voluntarily implemented more rigorous access monitoring standards. Kaiser Permanente continues to count the percentage of actual appointments booked within the wait time standards. Again, this is more rigorous monitoring than DMHC requires of any other plan.