September 22, 2016

Commissioner Monica Bharel, MD, MPH

Massachusetts Department of Public Health

250 Washington Street

Boston, MA 02108

Re: 105 CMR 173.000- Mobile Integrated Health Care and Community EMS Programs

Dear Commissioner Bharel,

On behalf of Blue Cross Blue Shield of Massachusetts (“BCBSMA”), I am writing in strong support of the Department of Public Health’s (“DPH”) proposed regulations governing Mobile Integrated Health Care (MIH) and Community EMS. As a member of the Mobile Integrated Health Advisory Council, we are proud to support regulations that provide a solid, but flexible framework to promote innovative programs that seek to address gaps in delivery of services, minimize the duplication, and reduce the overall cost of health care.

Our mission at BCBSMA is to make quality healthcare affordable. We believe that MIH has the potential to further that mission by providing high quality, cost effective care in a mobile setting. MIH and Community EMS initiatives have the potential significantly improve access to care, especially for those in need of behavioral health or substance use disorder services. We also anticipate benefits for patients with chronic conditions, and in areas of the commonwealth with limited services.

The regulations appropriately do not seek to address every possible scenario that may occur in an MIH setting. Instead, they establish a set of flexible guardrails and appropriate protections that will help foster innovation in this space. The regulations appropriately emphasize the need for clear medical direction, and adherence to important state and federal privacy protections. We eagerly anticipate the development of new alternative models of care under the MIH umbrella that seek to reduce unnecessary Emergency Department visits, and provide high quality, individualized care in low cost settings.

The development of such programs presents an opportunity for patient education, including them in the care planning process, and creating the infrastructure to foster engagement with the out-of-hospital supports. BCBSMA applauds the work taken to ensure these regulations optimize patient outcomes, and hope this further promotes a value-driven system of care, under the clear delineation of the operation standards and medical direction outlined for MIH and Community EMS Programs.

As with any emerging service, we expect the MIH landscape to change significantly over the next few years. For that reason, we encourage the Department to consider a sunset provision on these regulations two years from the effective date. This will necessitate a new public hearing after the MIH landscape has had the chance to further develop. Such a hearing will give all stakeholders to revisit the guideposts set forth today to ensure that the regulations keep pace with innovation that could further the goal of providing high quality, cost-effective care in a mobile setting.

Thank you for the opportunity to provide this testimony. Please do not hesitate to contact me at any time at (617) 246-3499.

Sincerely,

Michael T. Caljouw