PROS has not yet arrived but the New York State Office of Mental Health (OMH) still says it is coming. During the past six months, OMH has continued its work to move hundreds of programs and thousands of consumers into the Personalized Recovery Oriented Services, i.e. PROS. This article will provide an update as to the status of the development of the PROS programs and some significant concerns or questions.
OMH is requiring the counties and New York City to complete a planning process that will identify which programs will become PROS programs, the size and type of program, develop projected program budgets and require each locality to submit to OMH a local plan on how PROS will develop in each area. The planning process should be completed in the next two or three months. The information will provide a clearer picture as to the numbers of people to be served, overall costs, where services will be located and potential problems.
OMH is also working to complete the regulations for PROS and publish the regulations for the required comment period. OMH has published draft regulations that are available on the OMH website or directly from OMH. Once the regulations are issued, providers will be required to submit applications to become licensed to operate a PROS program. It is not yet clear as to when the regulations will be issued and when the application process will start. OMH has stated that it has planned to begin issuing licenses so some PROS programs starting in July 2004. For New York City, PROS will likely start in July 2005.
Consumers and providers have identified a number of concerns about the effect PROS could have on consumes and providers. Some concerns have been identified previously and have not been addressed by OMH and other concerns have emerged as the OMH materials have been further studied.
Two areas that will directly affect consumers are requirements that will force consumers to choose one specific primary program to enroll in and that providers will not be paid for serving a consumer who has chosen a different provider. Effectively, consumer choice will be limited if providers cannot be paid for providing services. A second concern is the effect a Medicaid-funded program will have on those consumers who do not have Medicaid, i.e., people who have only Medicare or receive VA benefits. OMH states the Medicaid rates for PROS will be sufficient to cover the costs for providing services to people who do not have Medicaid, yet a number of providers who have completed financial analysis do not agree with OMH. Indeed, a number of providers who have analyzed the PROS financial model are finding that PROS rates are inadequate and that it is likely that programs will close and services will be lost.
Some program services that are currently being provided using community support or Reinvestment funds, such as education, job development, employment support services and some aspects of job coaching, will not be reimbursed by Medicaid. It is not clear how these services will continue to be provided. Other concerns about the reliance on Medicaid and the current discussions about the high cost of Medicaid programs have raised many questions about the wisdom of changing at this time the financing mechanism for hundreds of mental health programs.
It is clear that consumers and providers will continue to try to make changes in the way PROS is being designed. What is not clear is how responsive OMH will be.