Workgroup debates behavioral health investment benchmark as staff pursue HPD analyses and confront data gaps

Debbie Lindis shifted the meeting to an update on behavioral health spending analyses and a discussion of key decisions for a behavioral health investment benchmark. She said OKA plans HPD analyses on variation across markets, age and geography, drivers of spending growth (price versus utilization), and the potential impact of including claims with secondary behavioral-health diagnosis codes.

Lindis framed two distinct tasks: measuring total behavioral health spending as required by statute and separately designing a benchmark as a policy instrument that may target outpatient and community-based services. She presented options for benchmark units (percent of TME versus per‑member‑per‑month), structure (incremental, long-term, or both), timeline, and whether the benchmark should be uniform across markets or tailored by line of business.

Workgroup members raised several concerns and recommendations. Beth stressed the absence of reliable data on out-of-pocket cash payments for behavioral health and noted that county behavioral health spending is visible while private-market cash spending is not. "We just don't have any data source that anybody has explained to me that says how much consumers pay cash for and so the HPD doesn't have it," Beth said, urging staff to surface those gaps.

Participants (Katherine, Sarah Arquist, Amy, Offsell and others) recommended that OKA run PMPM analyses by market and population segments (children, adults, seniors, duals), analyze impacts of carve-ins/carve-outs (pharmacy, behavioral health carve-outs), and consider tailored benchmarks because commercial, Medicare Advantage, and medical managed care have different benefit structures and capacities. Staff noted they are coordinating with DHCS to measure medical behavioral health spending that falls outside managed-care plans and will present HPD results for commercial and Medicare Advantage in coming months.

Debbie asked for input on timing and focus; several speakers favored creating tailored benchmarks for different markets rather than a single uniform target. Attendees also suggested benchmarks include both an incremental improvement component and a long-term target analogous to OKA's primary care benchmark.

Why it matters: staff and participants agreed that behavioral health benchmarking presents measurement and policy challenges distinct from primary care because of carve-outs, capitation, missing non-claims data, and a lack of consensus about the 'right' funding level. Workgroup members repeatedly called for clear disclosure of methodological choices and sensitivity tests in the technical appendices that will accompany any benchmark recommendation.

The session closed with staff promising additional HPD analyses, future meetings to discuss decisions in more depth, and an August 19 follow-up meeting date. No formal benchmark decision was made at this meeting.