Disengagement / Realignment Plan

I. PURPOSE 

In an effort to improve behavioral health services in our community, Mecklenburg's Board of County Commissioners seeks to realign with Alliance Health to manage our residents' behavioral health services funded by federal and state dollars, including Medicaid.

On November 4, 2020, Mecklenburg County's Board of County Commissioners voted unanimously to authorize the County Manager to begin exploring disengagement from Cardinal Innovations Healthcare as outlined in 10A NCAC 26C .0702.  On June 01, 2021, the Mecklenburg County Board of County Commissioners voted to adopt a disengagement from Cardinal Innovations and realign with Alliance Health.  Alliance Health is a Local Management Entity/Managed Care Organization (LME/MCO), which is a governmental entity that manages mental health, intellectual/developmental disability and substance use services for residents in Durham, Wake, Cumberland, and Johnston Counties.

Mecklenburg County's behavioral health services are currently managed by Cardinal Innovations Healthcare. Cardinal Innovations' provision of services has not adequately met the needs of Mecklenburg County residents.  Alliance Health's vision to ensure highly effective, community-based support and care and maintain commitments to stakeholders, more closely aligns with Mecklenburg County's vision and strategic planning. Mecklenburg County believes this realignment will better serve the community and its needs.

To minimize disruption of the behavioral health system in our county, this "Mecklenburg County LME/MCO Disengagement Plan" has been developed to ensure a smooth and seamless transition for all involved.

Our primary focus is to carry out this process with transparency, commitment to our community, and the involvement of those who will be impacted by the change. This plan primarily outlines the process for the County's disengagement from Cardinal, but it also necessarily   includes the process by which engagement will occur between Mecklenburg County, Alliance Health, and all relevant stakeholders.  Alliance Health has committed to working collaboratively with Mecklenburg County and Cardinal to ensure a smooth transition for all involved. Mecklenburg County has every confidence and expectation that Cardinal will also work collaboratively and cooperatively throughout the transition process.

II. BACKGROUND 

North Carolina General Statutes and the North Carolina Administrative Code authorizes and prescribes the process by which a county may seek permission to disengage from one LME/MCO and realign with another.  

Cardinal Innovations became the LME/MCO for Mecklenburg County in April 2014.  Since that time, there have been numerous concerns regarding the behavioral health services for Mecklenburg County residents.  Over this period, Mecklenburg County along with other community stakeholders have engaged in various meetings and developed various plans to address the concerns about the delivery of behavioral health services.  These meetings and plans did not result in lasting improvements.  In October 2020, Mecklenburg County, along with Forsyth County, sent a letter to the North Carolina Department of Health and Human Services' Secretary outlining the concerns and requesting a Plan of Action.  Cardinal developed a Plan of Action which did not adequately address Mecklenburg County's concerns. 

On November 4, 2020, Mecklenburg County's Board of County Commissioners voted unanimously to authorize the County Manager to explore disengagement from Cardinal as an option to address the concerns.  Mecklenburg County considered several options for improving the behavioral health system. Some of these options included continued working with Cardinal to develop and revise policies and procedures with a goal of improving Cardinal's service delivery. These efforts did not result in the desired outcomes for improvement; the problems persisted. There was also a request to establish a separate LME/MCO for Mecklenburg County, which was not approved. 

After much effort to improve delivery of services, on June 01, 2021, the Mecklenburg County Board of County Commissioners voted to officially initiate disengagement from its current LME/MCO, Cardinal Innovations Healthcare, and to realign with Alliance Health. The resolution is attached and is also on our website at www.MeckNC.gov where other information on this process (including this Disengagement Plan) will be immediately posted.

The Manager will immediately prepare and send a Letter of Intent to disengage to the NCDHHS Secretary, the counties in the regional areas of both Cardinal and Alliance, and the Co-Chairs of the Joint Legislative Oversight Committee on Health and Human Services as required by law.

III. RATIONALE 

Mecklenburg County is committed to ensuring the best behavioral health system is available to residents in the community. We believe that transitioning to the model of service provision and community engagement operated by Alliance Health will best accomplish that goal. As we have engaged in analysis and review of the Alliance Health model of operations, we have concluded that it is one of intentional community engagement at multiple levels within the counties that they serve. Leadership and staff throughout Alliance are engaged in relationships within their communities, actively collaborating with stakeholders, providers, consumers and others to meet the challenges faced.

We believe that Alliance Health is a better fit for Mecklenburg County because the LME/MCO was designed to serve urban, metropolitan communities such as Wake, Cumberland, and Durham counties. Their model of service delivery and design better fits the needs of Mecklenburg County and its population of more than 1.1 million.

Alliance works in collaboration with county government officials and local stakeholders to develop plans to invest their taxpayer-provided funds on mutually developed projects.  They provide a transparent accounting of uses of those funds to county leadership and respond to wishes of the county to target the funding to desired projects. Mecklenburg County is pursuing this relationship with Alliance with the intention of completing the transition prior to Alliance's launch as a Tailored Plan (if awarded a contract) as part of North Carolina's Medicaid Transformation.

Alliance's goal is to "ensure that individuals seeking help receive quality services and supports they are eligible for to help them achieve their goals and live independently."  Alliance has an expansive network of behavioral healthcare providers.  Some of these providers are located in Mecklenburg County.  Mecklenburg County has always desired greater network capacity of service providers and greater levels of choice for county residents. Alliance's philosophy of an expanded network and not tightly limiting their network of service providers addresses both of these goals.

Mecklenburg County also agrees with Alliance's model of community priorities. Alliance utilizes its local networks of providers and community partners to effectively and efficiently serve individuals to promote healthier lives and improve the community.  Some examples of Alliance's priorities are as follows:

• Investment in crisis service continuum: The purpose of these services is to stabilize individuals experiencing behavioral health crises to reduce unnecessary trips to the emergency department (ED), hospitalizations, and incarcerations. For example, Alliance partnered with community stakeholders to create local crisis facilities in three of its four counties and opened two behavioral health urgent care centers across its service area to connect people with appropriate care and services before urgent situations become crises. 
• Building a community-based System of Care: This includes a network of local agencies and community partners to address social and environmental factors, including homelessness, food insecurity, lack of transportation, that particularly impact the overall health of individuals that lack health coverage.
• Organizing consistent community outreach and education initiatives: Alliance works with community partners to assist individuals in navigating the behavioral health system and utilizing available local resources.

 
Finally, Mecklenburg County seeks greater transparency and participation in decision making that directly impacts residents needing behavioral health services. Alliance is governed by a Board of Directors responsible for comprehensive planning, budgeting, implementing and monitoring of community-based services to meet the health needs of Medicaid recipients and individuals without insurance in its catchment area. Alliance has demonstrated that it will collaborate with county governments and stakeholders and explore innovative ideas to meet the vast behavioral health needs of Mecklenburg County residents.  Realigning with Alliance will provide Mecklenburg County an opportunity to partner with the Alliance Board of Directors to create additional opportunities that will benefit Mecklenburg County residents.

IV. TIMELINE 

Disengagement will be effective as soon as reasonable and as permitted by law. A proposed timeline for disengagement is attached hereto and will be published on our website,  www.MeckNC.gov. While the default effective date of nine-months is recognized, Mecklenburg County will seek to disengage and realign sooner to minimize any negative impact on Mecklenburg County consumers.  The official disengagement date will ultimately be determined by the Secretary of North Carolina's Department of Health and Human Services (NCDHHS).

To protect our residents in greatest need, disengagement with Cardinal will occur simultaneously with realignment or "engagement" with Alliance. The process will include a minimum of 60 days for the public to review and comment on this Disengagement Plan. Following the comment period and the 30 days of posting such comments, Mecklenburg County intends to have ready for submission the Request to Disengage documentation and will look for approval within the 90 days as outlined in the North Carolina Administrative Code.

V. DISENGAGEMENT 

This Disengagement Plan serves as a guide for the first step in the process of transitioning from one LME/MCO to the other. While this plan should not be considered all-inclusive, we have made every effort to identify the areas on which we need to focus and the necessary steps to ensure that the needs of our residents are met. Both Mecklenburg County and Alliance are dedicated to carrying out this plan, as outlined in the following focus areas:

a. Transition Planning
To ensure active and robust community involvement in this transition and to facilitate input and feedback from subject matter experts, the Mecklenburg County Manager will form an LME/MCO Realignment Committee consisting of key County officials and agencies, Alliance, and other appropriate stakeholders. This will include the following, or their representatives, plus others as appointed by the County Manager:

1. Deputy County Manager
2. Mecklenburg County DSS Director
3. Mecklenburg County Community Support Services Director
4. Mecklenburg County Public Health Director
5. Mecklenburg County Criminal Justice Services Director
6. Mecklenburg County Finance Director
7. Mecklenburg County Attorney
8. Medic
9. Mecklenburg County Public Defender
10. Mecklenburg County District Court representative
11. Mecklenburg County District Attorney
12. Mecklenburg County Sheriff
13. Local Consumer and Family Advisory Committees representative
14. Provider representatives
15. Atrium HealthCare System representative
16. Novant HealthCare System representative
17. One or more Cardinal executives and directors
18. One or more Alliance executives and directors

This Committee will meet as needed to share information; to schedule listening and education meetings with key stakeholders (providers, consumers, advocates); to consult subject matter experts; and to assist the County and Alliance in whatever tasks are needed to ensure a smooth disengagement and transition.
b. Continuity of Services Plan
Mecklenburg County recognizes the importance of ensuring services for its community are uninterrupted and are provided with high quality, timeliness and a focus on community involvement. Therefore, a separate written Continuity of Services Plan is being developed and will be published shortly after this Disengagement Plan. Alliance has committed to ensure all current providers contracted and in good standing with Cardinal and serving our County will be contracted with Alliance as well, if not already. Likewise, Alliance intends to honor consumer service authorizations, annual plans and other documentation and decisions essential to ensure a smooth transition.

c. Notification of Stakeholders
Mecklenburg County and Alliance will collaborate to notify all stakeholders impacted by this transition. Additionally, a concentrated effort will be made to solicit comments, feedback and suggestions from consumers, advocates, self-advocates, providers, State and Local Consumer and Family Advisory Committees (CFACs), and all other interested parties. We will use our usual Mecklenburg County established communication methods, primarily our website along with mailings, stakeholder meetings, press releases, and social media messaging. All input is welcome and encouraged.

d. Community Initiatives
Mecklenburg County has ensured that Alliance is committed to becoming ingrained in our community and supporting our current community initiatives involving behavioral health, as it has in its other counties. A list of all current, planned and proposed projects/initiatives will be compiled and agreed upon prior to the transition effective date.

e. Distribution of Real Property Plan
In accordance with State law, a written Distribution of Real Property Plan must be developed during the LME/MCO realignment process. This disengagement involves no real property (land, buildings, etc.) to be distributed, so a Plan stating as much will be posted shortly after this Disengagement Plan.

f. Financial Liabilities
Mecklenburg County affirms that, to its knowledge, it has no outstanding financial liabilities to Cardinal, nor will the County have any within 30 calendar days of the request to disengage. Should Cardinal reasonably disagree, the County will work amicably and promptly with Cardinal to resolve equitably and if unable to do so, defer the matter to the NCDHHS Secretary for resolution. Alliance has agreed to work with the County to ensure its financial liabilities under maintenance of efforts requirements are not increased by realignment.

VI. NEXT STEPS/PUBLIC COMMENT 

The law requires Mecklenburg County to seek public comment on this Disengagement Plan. For 60 days from the posting of this Disengagement Plan on our website at www.MeckNC.gov, public comment is welcome and encouraged by email  to the following address: Realignment@MeckNC.gov or by mail to the following address:

ATTN: Mecklenburg County - LME/MCO Realignment
600 East 4^th Street, 11^th Floor
Charlotte, NC 28202

Following this public comment period, the County will post all responses for an additional 30 days. Mecklenburg County will take into consideration feedback received, will review all written plans, and submit a written request to disengage to the Secretary of NCDHHS for approval (details of which are outlined in the NC Administrative Code referenced below).
In keeping with our dedication to transparency, both Mecklenburg County and Alliance commit to keeping the public informed during this process, including public meetings, information and listening sessions with key stakeholders and groups, and more.

VII. AUTHORITY 

This Disengagement Plan has been developed in accordance with current state laws and regulations governing a counties' disengagement with an LME/MCO. Specifically, the following were used to create the plan and ensure compliance:

• North Carolina General Statute 122C-115 (a3)
• North Carolina Administrative Code 10A NCAC26C.0701-.0703