Data governance for CalAIM: Do you have a plan?

The California Advancing Innovation in Medi-Cal (CalAIM) initiative represents one of the most ambitious efforts to overhaul a state’s Medicaid program in recent memory. Just over one year into the five-year rollout, stakeholders are gearing up for the next round of implementation milestones in 2023 and beyond. This summer, one of CalAIM’s core service delivery improvements, Enhanced Care Management (ECM), will go live for new, at-risk populations (e.g., children and youth). County jails and youth correctional facilities will begin building the health technology infrastructure to deliver first-of-its-kind health and social services to individuals reentering the community. And many counties participating in CalAIM’s behavioral health initiative, the Behavioral Health Quality Improvement Program (BHQIP), will implement new electronic health record (EHR) platforms or leverage new integrations with their regional health information exchanges (HIE).

The success of these CalAIM initiatives is dependent upon robust and secure data exchange among stakeholders. Early lessons from CalAIM implementation through California’s managed care plans (MCPs) consistently demonstrated that local providers and community-based organizations (CBOs) lacked the technical and operational support to facilitate meaningful connections to critical health and social service information for CalAIM.[1],[2] In addition, stakeholders face a complex web of new and oftentimes conflicting state and federal regulations governing the exchange of health information and other types of sensitive data (e.g., social needs, behavioral health).

New state laws like Assembly Bill 133 (AB 133) sought to provide a safe harbor from existing California regulations for CalAIM stakeholders[3] by permitting broad exchange of health and social service records. However, AB 133 does not preempt more stringent federal rules governing the exchange of substance use disorder (SUD)[4] or Homeless Management Information System (HMIS),[5] two types of data that are crucial to painting a picture of the “whole person” within Medi-Cal’s enormous delivery system.

Given the scope and complexity of CalAIM’s data sharing objectives, stakeholders have a growing to-do list before data is ever exchanged. There are regulations to interpret. Policies and procedures to amend. Agreements to review and revise, then review again. Readiness assessments of existing data systems and organizational practices. The list goes on.

We learned from our early CalAIM implementation work with MCPs and community stakeholders that the available guidance from the state isn’t enough, despite the best of intentions. Many organizations may opt to err on the side of caution when it comes to data exchange, undermining the foundational goal of CalAIM: leverage cross-sector data sharing to upend the status quo for vulnerable, at-risk Californians. It’s no surprise that stakeholders need certainty as they wade into a still-evolving landscape for cross-sector data sharing.

In February 2023, the Department of Health Care Services (DHCS) launched the Providing Access and Transforming Health (PATH) technical assistance (TA) marketplace to connect CalAIM stakeholders – CBOs, providers, county agencies – with experts who can provide critical support with implementation of ECM and community supports. Intrepid Ascent’s Policy Innovation Group (PIG) has developed 9 unique products and services for the TA marketplace specifically designed to meet the needs of CalAIM stakeholders as they establish a new data governance framework for CalAIM.

Our team of policy consultants crafted these products and services based on industry-leading experience in information privacy and data governance from real-world clients, including our recent work with Whole Person Care (WPC) and CalAIM clients. Each product or service ensures that your organization has a plan for meeting statewide data sharing requirements, while aligning with the fundamental vision for a more data-driven, whole-person centered Medicaid delivery system in California.

To learn more, visit our website or find us on the PATH TA Marketplace.

[1] HealthNet.

[2] CHCF.

[3] See Civ. Code § 56 et seq (Confidentiality of Medical Information Act), WIC § 5000 et seq (Lanterman–Petris–Short Act), WIC § 10850.7

[4] 42 CFR Part 2.

[5] 24 CFR § 578.57.