1. Behavioral Health www.SBCounty.gov Medi-Cal Managed Care CMS 42 CFR 438 - Workplan Presented by: Sarah Eberhardt-Rios, MPA San Bernardino County, Department of Behavioral Health August 2016 CBHDA: Medi-Cal Policy Committee

2. www.SBCounty.gov Slide 2 Behavioral Health  CMS 42 CFR 18 Areas of Impact What has changed? Impacts  Note on CMS “Sub-Regulatory” Guidelines  Workgroup Members & Next Steps Presentation Roadmap

3. www.SBCounty.gov Slide 3 Behavioral Health CMS – 42 CFR Published Date Effective July 5, 2016 https://federalregister.gov/a/2016-09581

4. www.SBCounty.gov Slide 4 Behavioral Health  Summary from CMS “This final rule modernizes the Medicaid management regulations to reflect changes in the usage of managed care delivery systems. The final rule aligns, where feasible, many of the rules governing Medicaid managed care with those of other major sources of coverage, including coverage through Qualified Health Plans and Medicare Advantage plans; implements statutory provisions; strengthens actuarial soundness payment provisions to promote the accountability of Medicaid managed care program rates; and promotes the quality of care and strengthens efforts to reform delivery systems that serve Medicaid and CHIP beneficiaries. It also ensures policies related to program integrity. This final rule also implements provisions of Children’s Health Insurance Program Reauthorization Act of 2009 (CHIPRA) and addresses third party liability for trauma codes.” CMS – 42 CFR Source CMS website: “Federal Register, Vol. 81, No. 88, 27498”

5. www.SBCounty.gov Slide 5 Behavioral Health Draft Workplan – See Handout

6. www.SBCounty.gov Slide 6 Behavioral Health Timeline – Immediate What is changing?  DHCS assumes responsibility for monitoring if MHPs/PIHPs meet accreditation standards in a process implemented by DHCS or an approved accreditation entity.  FFP rate EQRO administrative match = 50% Require contracting relationship between State and PIHP [MHP] to the standards that are at least as stringent as standards used by private accreditation. Nationally identified PIP topics. Adoption of Medicaid managed care rating system. Published technical report by April 30 th of each year by EQRO IMPACT: Increase in State responsibility; decrease in FFP to fund the increased responsibility of DHCS. Impact #1 – EQRO –Decrease in FFP § 438.370

7. www.SBCounty.gov Slide 7 Behavioral Health Timeline – September 2016 (60 Days) What is changing?  Information Standards: Cultural Competency & Informing Materials  CMS is replacing current standards with a more organized clear set of standards for beneficiary notification and to account for electronic information Large print 18 pt. – Already a CA standard. Taglines of how to request materials in threshold languages; information required in provider directories – Already a CA standard. Including the section 508 guidelines from the U.S. Access Board for web content: https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards Beneficiary education standards upheld in this section apply to all plans regardless of authority, including waivers or demonstration projects. IMPACT: More web presence & ADA web compliance. Impact #2 – Quality Measurement: Basis, Scope, Applicability § 438.310

8. www.SBCounty.gov Slide 8 Behavioral Health Timeline – September 2016 (60 Days) What is changing?  In the definition: “We also proposed to modify the definition of ‘quality’ as it pertains to EQR to reflect that professional knowledge must be evidence-based and supported by current science. Consistent with the revised definition, states and their plans will be expected to stay up-to-date on the latest scientific findings and translate those findings into effective practices, as many states and plans already attempt to do. We also proposed to modify the definition of quality by including performance measure trends and performance improvement outcomes.” Impact #3 – Quality Measurement: Definitions (a) § 438.320

9. www.SBCounty.gov Slide 9 Behavioral Health  “We also are adding a definition of ‘health care services’ in § 438.320 of the final rule to mean all Medicaid services provided by an MCO, PIHP [MHP], or PAHP under contract with the State Medicaid agency in any setting, including but not limited to medical care, behavioral health care, and LTSS.” IMPACT: Transitioning to national metrics, such as recommended “Endorsed Measures” from the National Quality Forum.  Measures Database from NQF: http://www.qualityforum.org/QPS/QPSTool.aspx http://www.qualityforum.org/QPS/QPSTool.aspx The contracted EQRO (BHC) may need to add additional criteria for accreditation review and network adequacy into its evaluation. DHCS to ensure that the contracted EQRO meets any new outlined standards. New definition of health services bringing MHPs to a new quality “table top.” Impact #3 – Quality Measurement: Definitions (b)

10. www.SBCounty.gov Slide 10 Behavioral Health Timeline – September 2016 (Not flagged by DHCS – CBHDA policy issue & question for DHCS) What is changing?  Proposed regulation would allow MCOs and PIHPs [MHPs], to pay institutions of mental disease (IMDs) using funds received from Medicaid to provide services to their beneficiaries as an in lieu of service, and sets requirements about how to consider the utilization and costs of covered services rendered in an IMD in developing the capitation rates. Up to 15 Days/Month Impact #4 – IMD Exclusion (a) § 438.60

11. www.SBCounty.gov Slide 11 Behavioral Health IMPACT:  Since county MHPs are not paid on a capitated basis, this proposed policy change would not impact MHPs in terms of providing counties access to additional resources for inpatient psychiatric care provided in IMDs.  However, this provision would make clear that MMC plans can: Receive a monthly capitation payment from the state for an enrollee receiving short-term treatment in an IMD OR PIHPs [MHPs] can engage in discussions with DHCS regarding modified or blended payment rates with capitation as a possibility.  CAL MHSA Fiscal & Delivery System Pilot: http://www.cbhda.org/wp-content/uploads/2014/12/CalMHSA-Fiscal-Pilot-Phase-1a-Results.pdf Impact #4 – IMD Exclusion (b)

12. www.SBCounty.gov Slide 12 Behavioral Health Timeline – 7/1/2017 What is changing?  States must enroll all network providers of MCOs, PIHPs [MHPs], and PAHPs that are not otherwise enrolled with the state to provide services to FFS Medicaid beneficiaries: Provider screening, providers must disclose information on ownership and control Screening of licensure may overlap with credentialing process States must revalidate enrollment of providers every 5 years. Credentialing must include education regarding compliance as screening, compliance training are the precursors to enrollment as a provider. Under FFS, provider is then loaded in claim adjustment system and able to receive payment electronically according to the required NPI. States may set-up a separate category for network providers if they wish, but the same screening, compliance education is required. Rapid Network Development: States may execute network provider agreements pending the outcome of screening process for 120 days Denial or Termination: MCP must terminate such network provider immediately and notify affected enrollees the provider is no longer participating in the network. Impact #5 – State Monitoring Requirements (a) § 438.66

13. www.SBCounty.gov Slide 13 Behavioral Health IMPACT:  Closer view of provider network adequacy, timeliness & access standards  CMS requiring State to have a combined monitoring process for all CA Medicaid providers, including MHP providers.  Impact the DHCS Provider Enrollment Division CMS recognizes this may place additional administrative burden on the State. CMS cautions using a 3 rd party to meet the administrative for quality and consistency. Impact #5 – State Monitoring Requirements (b) NOTE

14. www.SBCounty.gov Slide 14 Behavioral Health Timeline – 7/1/2017 What is changing?  MCPs are required to submit encounter data in accordance with § 438.242. MSIS (Medicaid Statistical Information System) encounter data reporting standards as a condition for receipt of FFP: https://www.medicaid.gov/medicaid-chip-program-information/by- topics/delivery-systems/downloads/medicaid-encounter-data-toolkit.pdf https://www.medicaid.gov/medicaid-chip-program-information/by- topics/delivery-systems/downloads/medicaid-encounter-data-toolkit.pdf  Propose that PIHPs [MHPs] submit data at a level of detail specified by CMS:  Enrollee and provider identifying information; service, procedure and diagnosis codes; allowed/paid, enrollee responsibility, and third party liability amounts; and service, claim submission, adjudication, and payment dates.  States may use various methods to ensure the accuracy and completeness - protocol defining the optional External Quality Review (EQR) activity for Encounter Data Validation. Impact #6 – Data Quality (MISIS, Increased Reporting Amount & Frequency) (a) §438.242, 438.330

15. www.SBCounty.gov Slide 15 Behavioral Health IMPACT:  Add enrollee encounter data standards that would have to be incorporated in all PIHP [MHP] contracts.  This is a DHCS requirement for State-level data to  CMS. If the State is unable to make the submission compliant within the time allowed: defer and/or disallow FFP for the PIHP [MHP] contract in question. CMS is reviewing QAPI, HEIDIS, NQF and other metrics and states “Should we elect to identify national performance measures under the authority of the final regulation, there will be consideration during a public notice/comment process.” Impact #6 – Data Quality (MISIS, Increased Reporting Amount & Frequency) (b) NOTE

16. www.SBCounty.gov Slide 16 Behavioral Health Timeline - 7/1/2017 What is changing?  Authorizes CMS to make Federal mandates on specific PIP topics on areas that all States must participate in addition to State or MHP identified PIPs.  Quality measurement and improvement is an area of significant focus in the current SMHS waiver period (2015-2020). The special terms and conditions of the waiver renewal require the state to develop a much more robust system of performance measurement for MHPs, including the development of a dashboard for each MHP based on performance data and a system for tracking and measuring timeliness of care, including wait times to assessments and wait time to providers. Impact #7 – Quality Assessment & Performance Improvement Program (a) §438.330

17. www.SBCounty.gov Slide 17 Behavioral Health IMPACT:  It is likely that one of the two required MHP PIPs could be determined by DHCS/CMS. Likely this effort will be influenced by the “Health Insurance Marketplace Quality Improvement Strategy, Technical Guidance & User Guide” as well as the NQF measures and a focus on Access/Timeliness Standards.  It will be important to consider how this work will align with the proposed state quality rating system and comprehensive quality strategy. There may be an opportunity to more closely align quality measures across systems in California (MMCs and MHPs). Impact #7 – Quality Assessment & Performance Improvement Program (b) Health Insurance Marketplace QI Guide: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment- Instruments/QualityInitiativesGenInfo/Downloads/Draft-QIS-Technical-Guidance-and-User-Guide-for-the-2017-Coverage-Year.pdfhttps://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment- Instruments/QualityInitiativesGenInfo/Downloads/Draft-QIS-Technical-Guidance-and-User-Guide-for-the-2017-Coverage-Year.pdf

18. www.SBCounty.gov Slide 18 Behavioral Health Timeline - 7/1/2017 What is changing?  Align certain processes for appeals and grievances that would reduce confusion for beneficiaries who are transitioning between private health care coverage, MA coverage, or Medicaid managed care plans, including those in MHP care.  Changes identify distinctions between MCP/MHP local processes to create more consumer access to these processes first, state systems become a last resort for grievances & appeals. Impact #8 – Grievance System (a) §438.402

19. www.SBCounty.gov Slide 19 Behavioral Health New Timelines & Definitions  Grievance: Enrollees may file a grievance any time about any concern (past or present, except for adverse benefit determination). Grievance may be oral or written (MCP’s are advised to treat them equally) and both require follow-up in writing by MCP with the State to determine criteria for written follow-up within 60 days (Note: CMS gives up to 90).  Appeal changes from 45 to 30 days: Expedited resolution of an appeal at plan level is 72-hours.  Extension: up to 14 calendar days, if additional information is needed and a delay is in the enrollee’s interest, to include prompt notice to beneficiary.  Adverse Benefit Determination: “First, we proposed to replace the term ‘‘action’’ with ‘‘adverse benefit determination.’ The proposed definition for ‘adverse benefit determination’ included the existing definition of ‘‘action’’ and revisions to include determinations based on medical necessity, appropriateness, health care setting, or effectiveness of a covered benefit. (§438.400(b)) Impact #8 – Grievance System (b) §438.402, 438.404, 438.408

20. www.SBCounty.gov Slide 20 Behavioral Health Timeline – State Fair Hearing  Timeframe for enrollee to request SFH is extended from 90 days to 120 days from adverse benefit determination.  The enrollee must complete the appeal with the MCP prior to requesting a SFH so they navigate hearing process in a consecutive manner. No beneficiary direct access to SFH without appeal to MCP.  Expedited State Fair Hearing: 3 working days Impact #8 – Grievance System (c)

21. www.SBCounty.gov Slide 21 Behavioral Health IMPACT:  Timeline compliance Weekend responsiveness and coverage for 72-hour, expedited reviews.  Plan may decide to expedite: Plans must have an expedited review process if the plan determines or provider indicates that a standard resolution could seriously jeopardize life, health or ability to attain, maintain or regain maximum function.  Important to be discussing this with your managed care plan partners about their process so as not to create confusion for beneficiaries. Impact #8 – Grievance System (d)

22. www.SBCounty.gov Slide 22 Behavioral Health Timeline - 7/1/2017 What is changing?  Propose that states must enroll all network providers of PIHPs [MHPs] that are not otherwise enrolled with the state to provide services to FFS Medicaid beneficiaries. This does not prevent MCP from declining to enter into a network provider agreement, nor does it prevent the MCP from terminating one.  Proposal would apply to providers that order, refer, or furnish services in the context of Medicaid managed care to ensure that there are no `safe havens' for providers who, though unable to enroll in Medicaid FFS programs, shift participation from managed care plan to managed care plan to avoid detection. “Subcontractor” – Any individual or entity must comply with Medicaid laws. Impact #9 – Program Reporting: State Monitoring Requirements for PIHPs [MHPs] (a) §438.602

23. www.SBCounty.gov Slide 23 Behavioral Health Impact #9 – Program Reporting: State Monitoring Requirements for PIHPs [MHPs] (b) DHCS Provider Enrolment Division: FFS DHCS Providers: Health and BH Tier I & II DHCS Medi- Cal Managed Care Plans: Providers: Health and BH Tier I & II DHCS PIHPs Mental Health Plan: Providers: BH Tier III, SUD No Safe Haven – One Provider List Eliminate shifting participation to avoid detection.

24. www.SBCounty.gov Slide 24 Behavioral Health IMPACT  Increased cost and responsibility for DHCS: Adds compliance monitoring expectation between DHCS division that generally oversee FFS Managed Care (PED-DHCS) and those who oversee Medicare Managed Care so that provider lists are cross referenced with DHCS Provider Enrollment, Medi-Cal Managed plan enrollment, and Mental Health plan enrollment. Increased monitoring by DHCS:  How will DHCS structurally and technologically navigate this monitoring with 3 separate divisions and millions of providers? Exception: Out-of-network providers under single case agreement are not network providers and not subject to 438.602. Impact #9 – Program Reporting: State Monitoring Requirements for PIHPs [MHPs] (c) NOTE

25. www.SBCounty.gov Slide 25 Behavioral Health Timeline - 7/1/2017 What is changing?  Extends core compliance structures and activities to sub- contractors and requires them to hone certain structures and policies/practices within their organization. For non-profit or FFS MHP providers this may be a change.  The MCO plan must include subcontractors in corporate compliance program to the extent the subcontractor is delegated responsibility by the MHP for coverage of services and payment of claims under the contract between the state and MHP. Impact # 10 – Program Standards: Fraud, Waste & Abuse (a) §438.608

26. www.SBCounty.gov Slide 26 Behavioral Health IMPACT:  Impact & potentially increased costs needs to be evaluated at the plan level; scope-of-work will be based-on extent to which plan compliance programs currently include subcontractors.  Final Rule “Compliance program must include:” Written policies, procedures, and standards of conduct that articulate the organization’s commitment to comply with all applicable federal and state standards and requirements under the contract; The designation of a Compliance Officer; the establishment of a Regulatory Compliance Committee on the Board of Directors; Effective training and education for the organization’s management and its employees; and provisions for internal monitoring and a prompt and effective response to noncompliance with the requirements under the contract. Impact # 10 – Program Standards: Fraud, Waste & Abuse (b)

27. www.SBCounty.gov Slide 27 Behavioral Health  Office of Inspector General, 7 Elements of a compliance program: https://oig.hhs.gov/compliance/compliance-guidance/ https://oig.hhs.gov/compliance/compliance-guidance/ Open lines of communication Appropriate training and education Standards and procedures Chief Compliance Officer Disciplinary Standards Response to detected problems Internal auditing and monitoring  CA MHPs will already have this in-place. Impact # 10 – Program Standards: Fraud, Waste & Abuse (c)

28. www.SBCounty.gov Slide 28 Behavioral Health Timeline - 7/1/2017 (Not flagged by DHCS – CBHDA policy issue & question for DHCS) What is changing?  State Review and Approval of MCOs, PIHPs [MHPs], and PAHPs: New section proposes that as a condition of entering a contracting relationship with a state, MCOs, PIHPs [MHPs], and PAHPs undergo a review on the basis of performance in accordance with standards that are at least as stringent as the: First option for states is a state review and approval process that would be at least as stringent as that used by a private accreditation entity. Second option would allow a state to elect to use evidence that an MCO, PIHP [MHPs], or PAHP has obtained accreditation by one of the CMS-recognized private accrediting entities to deem compliance with the review and approval standard  See “Health Insurance Marketplace: Quality Improvement Strategy : https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/QualityInitiativesGenInfo/Downloads/Draft-QIS-Technical-Guidance-and-User- Guide-for-the-2017-Coverage-Year.pdf https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/QualityInitiativesGenInfo/Downloads/Draft-QIS-Technical-Guidance-and-User- Guide-for-the-2017-Coverage-Year.pdf Impact # 11 – State Review & Approval of PIHPs §438.332

29. www.SBCounty.gov Slide 29 Behavioral Health Timeline - 7/1/2017 What is changing?  Propose the addition of a new mandatory EQR-related activity in paragraph (b)(4), the analysis of which would be included in the annual MHP EQR offsite report in accordance with § 438.364. “Under § 438.364(a)(3), EQR technical reports will include recommendations on how the state can use the goals and objectives of its managed care quality strategy to support improvement in the quality, timeliness, and access to care for beneficiaries.”  This proposed EQR-related activity, would validate MCO, PIHP [MHP], or PAHP network adequacy during the preceding 12 months to comply with the state standards developed in accordance with § 438.68. Impact # 12 – Network Adequacy: Certify Networks & Publically Report (a) §438.68; 438.364

30. www.SBCounty.gov Slide 30 Behavioral Health IMPACTS:  Adds new EQRO requirement for network adequacy for MHPs; to a certain level, EQRO process may change. The network adequacy and timeliness standards for MHPs are already benchmarked to the federal regulations, which is heavily cited in the MHP contract. DHCS will need to assure that any changes / additions to the standards align with the MHP contract provisions and CBHDA/MHPs would need to be aware of any costs as a result of this.  New provision would require states to adopt time and distance standards to measure the adequacy of provider networks. DHCS: EPSDT POS, Performance Measures Taskforce OAC: Intersections for timeliness/access studies. Impact # 12 – Network Adequacy: Certify Networks & Publically Report (b)

31. www.SBCounty.gov Slide 31 Behavioral Health Timeline - 7/1/2017 What is changing?  Modernize Regulatory Standards - Availability of Services, Assurances of Adequate Capacity and Services, and Network Adequacy Standards:  “… To that end, propose to set standards to ensure ongoing state assessment and certification of MCO, PIHP [MHP], and PAHP networks, set threshold standards for the establishment of network adequacy measures for a specified set of providers, establish criteria for developing network adequacy standards for LTSS programs, and ensure the transparency of network adequacy standards.” Impact #13 – EQRO: Validation of Network Adequacy (a) §438.358

32. www.SBCounty.gov Slide 32 Behavioral Health Impact #13 – EQRO: Validation of Network Adequacy (b) §438.364 –Network Adequacy Standards §438.358 will only apply to MHPs that provide through contracts an LTSS benefit, then the broader network adequacy standards apply to LTSS services.

33. www.SBCounty.gov Slide 33 Behavioral Health Timeline - 7/1/2017 What is changing?  External Quality Review Results: Propose states contract with a qualified EQRO to produce the final EQR technical report (that is, we clarify that there is no other entity which may produce the EQR technical report) and we propose that this report be completed and available for public consumption no later than April 30th of each year.  Impact on existing schedule is unclear: CA EQRO Schedule  2015/2016: http://www.caleqro.com/data/california_eqro_resources/CalEQRO-MHP-Review-Schedule_FY2015- 16_SSG_jo_v7_WEB.pdf http://www.caleqro.com/data/california_eqro_resources/CalEQRO-MHP-Review-Schedule_FY2015- 16_SSG_jo_v7_WEB.pdf  2016/2017: http://www.caleqro.com/data/california_eqro_resources/CalEQRO-MHP-Review-Schedule_FY2016-17- FINAL_JO_051316_v1.pdf http://www.caleqro.com/data/california_eqro_resources/CalEQRO-MHP-Review-Schedule_FY2016-17- FINAL_JO_051316_v1.pdf Impact #14 – EQRO: Technical Reporting §438.364

34. www.SBCounty.gov Slide 34 Behavioral Health Timeline - 7/1/2017 What is changing?  Comprehensive state quality strategy – A statewide managed care strategy.  “We are retaining the requirement in § 438.340 of the final rule that states contracting with MCOs, PIHPs [MHPs], and PAHPs, and PCCMs … will be required to draft and implement a quality strategy …we are revising § 438.310 in the final rule to reflect the basis and scope for this broader applicability of the Medicaid managed care quality strategy.” Impact #15 – Quality Strategy Plan (a) §438.340

35. www.SBCounty.gov Slide 35 Behavioral Health  “States contracting with MCOs or PIHPs [MHPs] currently maintain a written strategy for assessing and improving the quality of managed care services offered by all MCOs and PIHPs [MHPs].”  “Managed care plans to increase expenditures to improve the quality of care and meet certain quality standards while other activities may improve the quality of care and lead to a net decrease in benefit expenditures.” This includes PCCM entities, or Primary Care Case Management providers… Impact #15 – Quality Strategy Plan (b) § 438.340 NOTE

36. www.SBCounty.gov Slide 36 Behavioral Health IMPACT:  All entities need written plans.  Increased expenditures improve quality of care  Net decrease in cost expenditures.  CMS is now saying you cannot have one risk pool that adheres to quality strategy with delegated, full-risk pools outside this plan.  Things to watch: with inclusion of PCCM entity (Charter, Landmark, etc.) Delegated risk may require sub-contractors to inherit cost burden of the administrative expense for quality plan. Which could result in administrative costs shifted back to MCPs. Financial impact on delegated risk/populations and PMPM? Impact #15 – Quality Strategy Plan (c)

37. www.SBCounty.gov Slide 37 Behavioral Health Timeline - 7/1/2017 What is changing?  Compliance Monitoring  Covered under Impact #9 Impact #16 – Program Reporting: State Monitoring Requirements for PIHPs [MHPs] §438.602

38. www.SBCounty.gov Slide 38 Behavioral Health Timeline - 7/1/2017 What is changing?  Loss of FFP for non-compliance with Data Quality/Health Info System  Covered in Impact #6 Impact #17 – Enrollee Encounter Data

39. www.SBCounty.gov Slide 39 Behavioral Health Timeline – 3 Years after publication on Federal Register (2019) What is changing?  Medicaid Managed Care Quality Rating System  Covered in Impact #1 Impact #18 – Quality Rating System §438.334

40. www.SBCounty.gov Slide 40 Behavioral Health  “Until July 1, 2018, states will not be held out of compliance with the changes adopted in the following sections so long as they comply with the corresponding standard(s) codified in 42 CFR part 438 …States must begin conducting the EQR-related activity described in § 438.358(b)(1)(iv) (relating to the mandatory EQR- related activity of validation of network adequacy) no later than one year from the issuance of the associated EQR protocol. States may begin conducting the EQR-related activity …no earlier than the issuance of the associated EQR protocol.” Summary of Timeline – Special Note Federal Register, Vol. 81 No.88, 27499 NOTE Sub-regulatory Guidance… more to come

41. www.SBCounty.gov Slide 41 Behavioral Health  Roles and responsibilities  Goals and expectations  Determine appropriate communication forums for MHPs & providers Next Steps Workgroup Members DHCS Workgroup Members CBHDA Rachelle Weiss Karen Baylor Dina Kokkos-Gonzales Autumn Boylan Erika Cristo Michele Bennyhoff, CBHDA Laura Williams, Butte County Twylla Abrahamson, Placer County David Horner, Orange County Sarah Eberhardt-Rios, SB County Medi-Cal Policy Committee Chairs: Uma Zykofsky Suzanne Tavano Stephen Kaplan

42. www.SBCounty.gov Slide 42 Behavioral Health Questions?

43. www.SBCounty.gov Slide 43 Behavioral Health Thank you! Sarah Eberhardt-Rios, MPA Deputy Director Department of Behavioral Health San Bernardino County (909) 388-0812 seberhardt-rios@dbh.sbcounty.gov Linnea Koopmans Senior Policy Analyst CBHDA (916) 556 -3477, Ext. 6018 lkoopmans@cbhda.org Megan Daly, MHA Project Manager Department of Behavioral Health San Bernardino County (909) 388-0948 mdaly@dbh.sbcounty.gov