OCA proposes focused behavioral‑health investment benchmark emphasizing outpatient and community services

OCA staff presented a straw‑model approach for a behavioral‑health investment benchmark that distinguishes two concepts: (1) measurement of total behavioral‑health spending as a component of total health care expenditures, and (2) a focused benchmark intended to drive investment toward specific services and care settings.

For measurement of total behavioral‑health spending, staff proposed to start with payer data for commercial and Medicare Advantage plans (claims and non‑claims payments) and eventually incorporate Medi‑Cal managed‑care organization data as that reporting is further developed. Staff emphasized that total spending measurement and the benchmark are separate: total spending uses a broad definition that can include inpatient, residential, emergency and long‑term services, while the proposed benchmark would focus on a subset that advances policy goals.

The benchmark straw model staff proposed would promote “timely, high‑quality and culturally responsive care in more appropriate settings with less out‑of‑pocket spending” by focusing on covered, in‑network, outpatient and community‑based behavioral‑health services. Staff described community‑based services as including mobile clinics and supportive services delivered outside traditional clinical settings, and said the benchmark could exclude pharmaceutical spending for benchmark calculations while still measuring it in the overall behavioral‑health spending picture.

Staff cited policy alignment with existing statewide initiatives: Proposition 1’s Behavioral Health Services Act and Behavioral Health Infrastructure Bond, Senate Bill 855 (parity and out‑of‑network coverage when in‑network access is insufficient), and SB 221 (timely access standards for non‑physician mental‑health providers). The staff and the investment & payment work group noted these related laws and said the benchmark should complement — not duplicate — Proposition 1 infrastructure spending and county investments.

Work‑group feedback included broad support for an outpatient/community focus, strong interest in including screenings and assessments in the measurement definition, and debate about how to treat diagnoses such as autism, dementia and self‑harm (the work group favors including behavioral‑health services for those diagnoses but is mixed on including medical services for dementia and adverse self‑harm events). Staff said they will continue refining diagnostic and service definitions with the work group and will return with a recommendation to the board in July; they extended the internal timeline to allow more time for work‑group recommendations.

Committee members raised operational questions about network adequacy, the difference between in‑network telehealth and app‑based providers, continuity of care across therapists and levels of care, and how to monitor whether the benchmark achieves improved access and quality; several members urged tying benchmark implementation to HPD and claims data analyses.