P&P April Issue 2018

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to tackle one of these barriers and provide some clarity around state and federal law requirements related to exchanging behavioral health information. The SHIG evolved over an eight- month period and an Agile approach was imperative for a successful product. This approach fostered intense collaboration by not only the development team but also by the stakeholders who were highly engaged. The development team had daily scrum meetings, ensuring clear communication and expectations. There were monthly sprint review meetings covering particular content areas with advisory group members who faced issues in the field on a daily basis. This ensured the SHIG captured the essence of the issues and described solutions in a useful way. SNAP measure the wrong outcomes, stressing process compliance rather than actual employment, and also hamper state innovation. APHSA and its affinity groups have developed extensive reauthorization papers on both TANF and SNAP that amplify these primary points. 9 There is also always the concern about what penal- ties should be imposed on clients who willfully and without good cause fail to comply and whether these penal- ties will have ramifications that could make the cure worse than the problem. In a February webinar held by APHSA on expanding work require- ments, I moderated a panel including Robert Doar, from the American Enterprise Institute, LaDonna Pavetti from the Center on Budget and Policy Priorities, and David Stillman, APHSA Board Chair fromWashington State. 10 Their thoughts, both pro and con, on the issue, while often different, were wise and instructive as well as mutually respectful about the best avenues to help more adults on public benefit programs get the proper help

providing clarity to ambiguous, and sometimes, conflicting laws. Although the SHIG is a thorough analysis and interpretation of laws and regulations that support coordinated care and exchanging behavioral health information, the SHIG does not replace legal advice from agency counsel. The SHIG is published on the CalOHII website at http://www.chhs. ca.gov/OHII/Pages/shig.aspx . Reference Note 1. https://www.chcf.org/wp-content/ uploads/2017/12/PDF- FinePrintExchangingBehavioral.pdf Elaine Scordakis is the Assistant Director of the California Office of Health Information Integrity within the California Health and Human Services Agency. 3. Information about Section 1115 Demonstration Waivers is available at https://www.medicaid.gov/medicaid/ section-1115-demo/about-1115/index.html 4. https://www.medicaid.gov/federal-policy- guidance/downloads/smd18002.pdf 5. http://files.kff.org/attachment/Issue-Brief- Medicaid-and-Work-Requirements-New- Guidance-State-Waiver-Details-and-Key- Issues 6. https://www.clasp.org/sites/default/ files/publications/2017/04/The-Evidence- Builds-Access-to-Medicaid-Helps-People- Work.pdf 7. http://familiesusa.org/blog/2018/02/six- reasons-work-requirements-are-bad-idea- medicaid 8. https://innovation.cms.gov/initiatives/ mipcd 9. The Future of SNAP—A Modern and Responsive Program and TANF at 20— Time for Rational Changes can be found on APHSA’s Center for Employment & Economic Well-Being webpage. 10. A recording of the webinar can be gov-trump-work-requirement-housing- voucher.html

Complete transparency was required to develop trust among such a diverse stakeholder environment. As you can imagine, a diversity of opinions and perspectives was apparent and appreciated. CalOHII communicated at every step with stakeholders, asso- ciations, and privacy and patient advocacy groups what they were doing, the approach, what had been decided, what was within and out of scope, and why. The SHIG is a first step to advance appropriately sharing behavioral health information and does not address other types of information that need to be exchanged to help facilitate the coordination of care (i.e., minors, criminal justice). The SHIG helps to pave the future of behavioral health information sharing by addressing complex and confusing issues and on a path to employment. As a state administrator of these programs, Stillman captured the dilemma effec- tively, stating, “I recognize the critical value and dignity of work, but worry about the effects of conditioning benefits solely on compliance.” The panel demonstrated that we need to set aside the polarizing points of view both in Congress and among the public that those who can work and are participating in health and human services programs are either victims with obstacles to work beyond their control or opportunists simply taking advantage of public largesse and unwilling to work. Both extremes are inaccurate and will not lead to actually helping those most in need to better their own or their family’s social and economic futures. Reference Notes 1. https://www.urban.org/sites/default/files/ publication/95821/work-requirements-in- public-housing-authorities.pdf 2. http://www.governing.com/ topics/health-human-services/

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accessed from APHSA’s Center for Employment & Economic Well-Being webpage.

April 2018   Policy&Practice 35