Consumer Advocates Submit Comments on Maryland’s State Innovation Model Proposal

Recently many behavioral health organizations, representing both providers, consumers, and family members submitted comments to Maryland Department of Health and Mental Hygiene related to their CMS sponsored State Innovation Model proposal. Two years ago Maryland received a planning grant of more than $2M from CMS to develop a proposal for future funding. CMS required that Maryland utilized a stakeholder process to develop the plan and to allow for public comments. Unfortunately, due to the time constraints DHMH was not able to accept public comments until after the proposal was submitted. They have committed to distilling the comments and using them for future iterations of the proposal once CMS has released the announcement of funding availability.

The proposed model is a community health model, which builds on the patient centered medical homes currently in place in Maryland, and proposes to provide funding for various community supports that will address needs that cannot met in the medical home. The model is a regional model, leveraging the work of local health departments and local health improvement coalitions. You can read the entire SIM proposal and get more information on the process used to develop it. Of note for behavioral health consumers and providers is the proposed expansion of BHIPP to more than just pediatricians. Also important is the heavy dependence on community health workers. There is little mention in the proposal of how these outreach workers will be trained, including whether they will be adequately prepared to work with behavioral health consumers. Finally, of critical importance is the need for added security and privacy protections for protected health information. Because this model builds on the patient centered medical home and increases the need for data sharing across providers and community supports, it will be necessary to educate and inform consumers about the risks and benefits of allowing their data to be shared.

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