Important Issues

To: Lisa Truitt, Director, Health Care Delivery and Management Association, Department of Health Care Finance

From: Patricia Quinn, VP of Policy and Partnerships, DC Primary Care Association
Justin Palmer, VP, Public Policy & External Affairs, DC Hospital Association
Mark LeVota, Executive Director, District of Columbia Behavioral Health Association
Robert Hay Jr., Executive Vice President, Medical Society of DC
Veronica Sharpe, President, District of Columbia Health Care Association
Kurt Gallagher, Executive Director, DC Dental Society
Ian Paregol, Executive Director, DC Coalition of Disability Service Providers
Re: Recommendation for Centralized Medicaid Provider Credentialing

Date: November 19, 2024

CC: Melisa Byrd, Senior Deputy Director, Medicaid Director, Department of Health Care Finance
Ruth Pollard, President and CEO, DC Primary Care Association

The DC Primary Care Association, our member health centers, and our partners in the health care delivery system including the DC Hospital Association, the DC Behavioral Health Association, the Medical Society of DC, the DC Health Care Association, the DC Dental Society, and the DC Coalition of Disability Service Providers are grateful for the support of the Department of Health Care Finance (DHCF) as we work to solve issues impacting patient access and provider sustainability. As initially described in our February 2023 memo, the process to credential providers for participation in Medicaid managed care networks is burdensome, lengthy, and often opaque. Credentialing delays significantly impact our ability to address current well-documented workforce shortages, and we urge DHCF to take regulatory steps to improve the timeliness and clarity of credentialing process.

In the District, providers must submit documents to no fewer than five separate entities in order to be credentialed by all Medicaid payers. To ease provider burden, DHCF should centralize credentialing, requiring a single standardized process at the District level instead of an individual process with each MCO. Some state examples include:

1. In Ohio, a Managed Care Procurement division of Medicaid runs the Centralized Credentialing program, contracting with Maximus, Inc to serve as a single point of contact (Centralized Verification Organization or CVO) and to develop agreements for delegated credentialing arrangements with health system

2. In North Carolina, a 2018 Centralized Credentialing “concept paper” led to the development of centralized provider enrollment via the NCTracks system. North Carolina reports processing turn-around statistics on their NCTracks website.

3. In Mississippi, providers are credentialed by the Medicaid agency, pursuant to language updated in their 2022 managed care contracts and following 2021 legislation requiring a uniform process.

DCPCA and our partners at DCHA, DCBHA, MSDC, DCHCA, DC Dental, and DC Coalition also recommend that DHCF implement specific credentialing requirements consistent with Maryland’s insurance statute 15-112 that would significantly improve the credentialing process for providers including:

• Requiring notice to providers within 10 days of submission of incomplete applications and steps to remediation
• Requiring notice within 30 days of submission presumptive intent to credential, allowing provisional billing to begin
• Mandating transferal of credentialing status when providers change employer

DHCF has an opportunity to act expeditiously in support of providers facing well-documented post-pandemic workforce and fiscal pressures. We look forward to working in partnership to implement needed changes to the District’s credentialing processes before the close of 2024