Report 2023-103 Recommendations

To ensure effective program oversight and to acknowledge that nearly all Medi-Cal members use managed care plans, Public Health and Health Care Services should, by January 2025, collaborate to update regulations related to the perinatal program. The regulations should include, at a minimum, a clarification of the roles and responsibilities of each department and adjustments to the current monitoring and oversight systems as described individually below to ensure that the departments provide sufficient oversight of the perinatal program.

To improve its current Medi-Cal monitoring and oversight systems, Health Care Services should do the following:
- Require managed care plans to conduct quality assurance reviews on perinatal service providers, such as OB-GYNs, at least once every three years, beginning by January 2025. If necessary, Health Care Services should seek resources to facilitate this change.
- Include the perinatal program in its risk assessment when determining where to target its annual medical audits.

To ensure that the State informs all Medi-Cal members of the perinatal program and the enhanced services available to them, Health Care Services should, by June 2024, update its Medi-Cal template and guidance to managed care plans to require that all member handbooks describe the enhanced perinatal program benefits. At a minimum, this language should include information on pregnancy-related health education, nutrition counseling, and assessments and referrals for basic health needs and mental health care.

To ensure that providers are adequately trained on the requirements of the perinatal program, beginning in January 2025 Health Care Services should require that managed care plans ensure and document that providers have received training as appropriate. At a minimum, this training should include what services are available and how to document that providers offered those services.

To ensure the efficient and effective provision of perinatal services throughMedi-Cal, the Legislature should modify state law to assign the primary perinatal
program administration and oversight responsibilities to Health Care Services, and direct Health Care Services to develop a system of oversight to ensure that providers are aware of and offer program services to all pregnant and postpartum Medi-Cal members. As part of this update, the Legislature should consider whether to assign additional data collection duties to Health Care Services, for example by requiring the department to create and use a version of the perinatal services data form mandated by state law. Such a form could track data on perinatal services that would also make possible the department's analysis of utilization rates. To the extent necessary, Health Care Services should then contract with Public Health to maintain any services or program oversight functions best conducted by Public Health.

To ensure effective program oversight and to acknowledge that nearly all Medi-Cal members use managed care plans, Public Health and Health Care Services should, by January 2025, collaborate to update regulations related to the perinatal program. The regulations should include, at a minimum, a clarification of the roles and responsibilities of each department and adjustments to the current monitoring and oversight systems as described individually below to ensure that the departments provide sufficient oversight of the perinatal program.

By December 2024, Public Health should develop and implement a system to sufficiently verify the survey responses provided by fee-for-service providers. For example, Public Health could conduct chart reviews annually on a selection of fee-for-service providers who have completed its survey to ensure the accuracy of responses. To the extent that such oversight could be provided through a partnership with Health Care Services, Public Health should seek such a collaboration.

To ensure that providers are knowledgeable about the services the perinatal program requires, by December 2024, Public Health should require that all fee-for-service perinatal program providers attend training on administering the perinatal program.

To comply with state law, Public Health should develop and implement a data form for use by providers to collect comprehensive information on perinatal services offered and used, the results of which should be sent to Health Care Services to gather necessary information on the program's usage and effectiveness. At a minimum, this form should include whether providers are rendering perinatal services to Medi-Cal members. Based in part on information collected by local health coordinators during their reviews, we developed a sample form to illustrate the type of information Public Health should collect, as shown in Appendix A.