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Special Examination 20-13

Behavioral Health Providers and Practitioners

Requested Information on Duplicative Administrative Practices

December 2020

 

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KEY RECOMMENDATIONS

DCH should:
  • Revise licensing requirements for non-residential DATEP facilities enrolled with DBHDD to shorten the licensing process.

  • Collect and analyze application processing information to identify areas for improvement.
DBHDD should:
  • Pursue methods to allow providers to electronically submit pre-qualifications documents.
The General Assembly should:
  • Consider revising statutory requirements related to DATEPs.

  • Consider expanding “Rap Back” legislation to other agencies (e.g., the Department of Juvenile Justice) that employ behavioral health care professionals to reduce the costs and burden of repeated background checks.

BACKGROUND

Based on the House Appropriations Committee’s request, we determined whether administrative requirements behavioral health care practitioners and providers must meet to work with Georgia Medicaid clients are duplicative and costly. We also identified actions that could reduce duplication and cost to the entities and determined whether licensure requirements were outside norms.

Georgia’s Medicaid population receives behavioral health services through entities that contract with the state. While processes differ depending on provider type and services offered, these entities must be approved through a multi-step process overseen by the Department of Community Health (DCH) and the Department of Behavioral Health and Developmental Disabilities (DBHDD).

 

KEY FINDINGS

While the administrative requirements that behavioral health care practitioners and providers must meet to serve Georgia’s Medicaid population are not overly duplicative, we identified several areas for improvement. Practitioners generally face requirements similar to those in other states. Providers go through a lengthier process, and inefficiencies likely increase their perception of burden. It should be noted that agencies have taken steps to address some of the issues.


Providers face a long process to become approved to offer services to Georgia’s Medicaid population.

  • Inefficiencies likely increase providers’ perception of a burdensome enrollment process. While agencies have taken steps to address some issues, additional action could be taken. For example, approvals could be shortened by 3 months if non-residential Drug Abuse Treatment and Education Programs (DATEP) overseen by DBHDD no longer required a license from DCH’s Healthcare Facility Regulation Division (HFRD).

  • Tracking application status through the enrollment process could help DCH identify additional efficiencies.

Medicaid provider enrollment is a lengthy and complex process


Providers and practitioners are subject to ongoing administrative costs associated with background checks.

  • Additional background checks for renewals and multiple agency checks can become burdensome and costly. For example, a provider that employs 15 practitioners serving populations from three agencies would have to pay approximately $2,340 for 45 background checks.

  • “Rap Back” legislation allows certain agencies to retain fingerprints with the Georgia Bureau of Investigation and receive criminal history updates.

Administrative requirements to become a licensed behavioral health practitioner are reasonable.

  • Requirements and fees for initial licensure and renewal for the behavioral health care professions reviewed are comparable to those in other states.

  • The state has joined three interstate compacts that permit professionals in good standing with their home state licensing board to practice in the new state and reduce additional steps.

  • Georgia’s fees do not exceed what one would pay in another state.