DCS Comprehensive Health Plan

Member Information Requirement

Health Coordination08/31/202308/31/2023

Statement/Purpose

This policy establishes requirements for DCS Comprehensive Health Plan (DCS CHP) regarding member information and the approval process for member information materials developed and used by DCS CHP. This policy applies to oral and written communication disseminated to DCS CHP members and caregivers, and to the content of DCS CHP webpages.

Definitions

Communications: Written and/or scripted verbal messages intended for general use for DCS CHP members; e.g. phone scripts, letters, brochures, post-cards, advertisements, newsletters, and flyers. (This does not include letters to members about specific occurrences or individual situations).

DCS Office of Communications: DCS unit that has responsibility for an array of services including managing the DCS website, media relations, community relations, and graphic design.

Member Information Materials: Any materials given to the Contractor’s membership. This includes, but is not limited to member handbooks, member newsletters, provider directories, surveys, on hold messages and health related brochures/reminders and videos, form letter templates, and website content. It also includes the use of other mass communication technology such as email and voice recorded information messages delivered to a member’s phone.

Member Information - File and Use: A process whereby DCS CHP submits qualifying member information materials to AHCCCS prior to use and can proceed with distributing the materials without any expressed approval from AHCCCS.

Member Information - Vital Materials: Written materials that are critical to obtaining services which include, at a minimum, the following:

• Member Handbooks

• Provider Directories

• Consent Forms

• Appeal and Grievance Notices

• Denial and Termination Notices

Policy

DCS CHP members/caregivers receive oral and written health plan member information material in a manner and format that is easily understood and readily accessible. DCS CHP provides member support and education through caregiver outreach and coordination, consistent with confidentiality requirements, to enhance a ‘whole child’ and family approach to healthcare service delivery for children in out of home care.

DCS CHP promotes members’ interest and involvement in their own health care, through the dissemination of information that:

• Informs members/caregivers of health plan operations and activities;

• Complies with State and Federal confidentiality statutes, rules, and regulations to protect personal health information that may identify a particular member or subset of members;

• Provides timely notification of changes in benefits, providers and services;

• Educates members/caregivers regarding appropriate utilization behavior; and

• Receives appropriate internal and regulatory approval.

DCS CHP reviews all materials to ensure compliance with:

• DCS Administrative Policy, DCS 11-11 Form Creation and Revision

• ACOM Policy 404 for Member Information requirements;

• ACOM Policy 405 for requirements regarding Cultural Competency, Language Access Plan and Family/Patient Centered Care;

• ACOM Policy 406 for requirements regarding the Member Handbook and Provider Directory;

• ACOM Policy 425 for requirements regarding Social Networking activities;

• ACOM Policy 433 for requirements regarding Member ID Cards.

Procedure

DCS CHP and its contracted MCO develop member information materials for dissemination in a manner and format that may be easily understood and is readily accessible by members/caregivers. Members/caregivers are informed that information is available upon request, in paper form and without charge. Member information materials are mailed to members within five (5) business days from the request.

DCS CHP and its contracted MCO collaborate to:

• Identify and describe the specific need for the communication;

• Propose the type of communication/notification required to meet the need;

• Define communication objectives;

• Define the audience(s) for the communication;

• Determine the most appropriate communication modality;

• Track delivery of information;

• Evaluate effectiveness of communication;

• Review draft material and ensure the information:

  • meets the defined objective(s);

  • is appropriate for the target audience; and

  • complies with regulatory requirements.

• Secure appropriate content review by DCS Communications Unit when necessary.

Requirements and Restrictions for General Member Information Material

DCS CHP complies with the file and use review process as outlined in ACOM 404 for all member information materials developed by DCS CHP and/or its contacted MCO. If a 15-day notice is not possible, DCS CHP may request an expedited review that is clearly marked as expedited, and includes the reason for the shortened timeframe.

The 15-day timeframe begins upon submission of member information materials to AHCCCS from DCS CHP.

Member information material may be disseminated upon the expiration of the 15-day time period, unless AHCCCS notifies DCS CHP otherwise. Member materials submitted outside of standard business hours are considered received the following business day. State holidays that fall on business days are not counted as part of the 15-day review period.

Member information materials that are a component of new initiatives, special projects, (e.g., new member portal, health education initiatives, etc.), or are comprised of a bulk submission (e.g., booklet, magazine, multiple materials in one submission, multiple submissions in a short time frame, etc.) may require additional review time.

Surveys are not subject to the file and use review process.

Materials Not Requiring Submission to AHCCCS

Customized letters for individual members are not submitted to AHCCCS for review and approval.

Health related brochures developed by an AHCCCS recognized organization (see ACOM policy 404, Attachment A, Organizations Recognized by AHCCCS), do not require submission to AHCCCS as long as the informational material provided by an approved organization does not reference services that are not medically necessary, are not Medicaid covered benefits, or do not align with AHCCCS and/or DCS policy. In these instances, DCS CHP may use the organization’s material only as a reference to develop its own member information materials.

Member information materials previously created by the contracted MCO and approved by AHCCCS for lines of business outside of DCS CHP are subject to additional approvals from DCS CHP and AHCCCS prior to use.

Language, Readability, and Oral Interpretation Requirements

DCS CHP and its contracted MCO make every effort to ensure that all information prepared for distribution is written in an easily understood language and format. Every effort is made to maintain the information at a sixth-grade reading level as measured on the Flesch-Kincaid scale. Font sizes are no smaller than 12 point. Information materials are also available in alternative formats and in an appropriate manner that takes into consideration the special needs of those who, for example, are visually limited, have other disabilities, or who have limited reading proficiency. Large print materials are made available using a conspicuously visible font size.

All member information material includes taglines in the prevalent non-English languages in Arizona and include large print (conspicuously visible font size) explaining the availability of written translation or oral interpretation services with DCS CHP’s toll free and Text Telephone Devices (TTY/TDD) telephone numbers for customer service which is available during normal business hours.

Vital materials as defined above are made available in the prevalent non-English language spoken for each Limited English Proficient (LEP) population. Oral interpretation services are not substituted for written translation of vital materials. DCS CHP is responsible for ensuring that translation is accurate and culturally appropriate.

All written materials for members are translated into Spanish regardless of whether or not the materials are vital.

Oral interpretation services are available to DCS CHP members at no cost including interpretation of documents written in English into the member’s preferred language. This applies to American Sign Language and all non-English languages, not just those identified as prevalent. DCS CHP ensures interpretative services including the use of auxiliary aids such as TTY/TDD are made available.

Value-Added Services

Value-added services may be non-Medicaid covered services, benefits, or positive incentives that promote healthy lifestyles and improve health outcomes among members. DCS CHP may offer value-added services that promote healthy lifestyles and improve health outcomes. Value-added services such as incentive items are not exchangeable for items prohibited as specified in ARS 46-297. Value-added services are offered in a culturally sensitive, unbiased, and equitable manner.

DCS CHP does not receive compensation for value-added services and does not report the cost of value-added services as allowable medical or administrative costs.

Member Newsletter Content and Requirements

DCS CHP and its contracted MCO follows the member newsletter content requirements outlined in ACOM 404.

DCS CHP and its contracted MCO develop and distribute, at a minimum, two Member Newsletters during each contract year. The newsletters are produced in an electronic format with written notice to members of the availability of the newsletter. The Member Newsletter is submitted to AHCCCS in the form of an initial mock-up version of what the member will be receiving in addition to the individual articles referencing readability levels and shall be submitted as specified in Contract. Member newsletters are reviewed in accordance with AHCCCS and DCS policies.

The Member Newsletter is excluded from the 15-day file and use review process.

Website Content and Requirements

DCS CHP maintains a website as specified in ACOM 404. Webpages are designed in a manner that members/caregivers can easily find and navigate from the DCS home page. Information is maintained in a format that can be printed by members/caregivers.

AHCCCS reviews the Medicaid content on the DCS CHP webpages to ensure compliance with ACOM 404, Attachment B, Contractor Website Certification Checklist.

Member Rights and Responsibilities

Information outlining Member Rights and Responsibilities, prepared by AHCCCS or the Centers for Medicare and Medicaid Services (CMS), is disseminated to DCS CHP members and subcontractors. DCS CHP is responsible for all costs related to dissemination of the information.

Member Rights and Responsibilities which include non-discriminatory language and instructions on how to report unfair treatment, are published in the Member Handbook. Changes to Member Rights and Responsibilities are communicated timely and in writing as determined appropriate.

DCS/CHP monitors compliance of Member Rights and Responsibilities through:

• Grievance program;

Quality of Care complaints; and

• Satisfaction surveys.

Notifying Members of Operational Changes

Members are notified of changes in benefits, operational procedures, services, healthcare providers or provider locations at least thirty (30) calendar days prior to the change, unless a provider is terminated from the network. When a provider is terminated from the network, the member is notified within fifteen (15) days after the receipt or issuance of the termination notice. Notification consists of a letter mailed to the DCS Specialist on behalf of the member.

When changes involve healthcare providers or their locations, the health plan Network Management, Provider Relations, Medical Management, Member Services and Enrollment Services teams collaborate to identify the provider who is the most appropriate for continuity of medical care and, ultimately, re-assignment of the member.

When changes involve health plan benefits, DCS CHP collaborates with its contracted MCO as appropriate to determine which members appropriately require notification.

Member Notifications

Member specific notification is sent to DCS Specialists for members/caregivers about specific occurrences (e.g., over- or under- utilization of specific services). Other health plan departments may contribute to the identification of members who require notification. These member-specific notifications do not require regulatory review and approval.

Draft member notifications that are components of a material change within the health plan, even if previously submitted as member information material, are submitted to AHCCCS for approval.

Member Outreach/Resource Coordination

Additionally, the DCS/CHP Resource Coordination function area provides telephonic outreach to newly enrolled members. Outreach activities include, but are not limited to:

• Instructions on how to access the member handbook and provider directory;

• Instructions and confirmation of receipt of member ID card and appropriate use;

• Availability of care management services and how to obtain them;

• Assistance with scheduling EPSDT well-visits, dental preventative visits, behavioral health services, and transportation;

• Navigation of caregiver and member resources within and outside of DCS;

• Referrals to community-based resources including family/peer to peer support agencies/organizations.

Reporting

DCS CHP and its contracted MCO submit an annual attestation to AHCCCS indicating compliance with member information requirements as outlined in ACOM Policy 404, by signing and submitting ACOM Policy 404, Attachment C, Member Information Attestation Statement as outlined in contract.