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June 2, 2022
Contact: OHA External Relations, OHA.ExternalRelations@dhsoha.state.or.us
Salem – On May 31, 2022, the Oregon Health Authority (OHA) notified Trillium Community Health Plan (Trillium) that it had satisfactorily met the requirements of its corrective action plan (CAP) for service deficiencies in the Tri-County service area.
Trillium was placed on a CAP in September 2020, concurrent with its entry into the Tri-County service area. The CAP was imposed after Trillium’s failure to adequately address OHA’s concerns around the plan’s expansion into the Tri-County service area. The CAP was comprised of four main finding areas: (i) network development, (ii) health equity & language access, (iii) community engagement, and (iv) intensive care coordination.
OHA has worked with Trillium continuously to monitor and ensure progress towards meeting the requirements of the CAP. With the May 31 notice, subject to a final review, the various notices associated with the CAP are considered resolved and no further action is required from Trillium. The letter to Trillium can be found here.
In the four main finding areas, Trillium has demonstrated it has resolved the initial and subsequent issues. Below is a summary of the original findings and the demonstrated resolution of the issues.
Network adequacy:
Trillium was notified that it must ensure that its members have the same access to certain services as other patients in the service area. In addition, Trillium must have sufficient in-network hospitals, primary care providers, specialists, and pediatric oral health providers to meet the time and distance standards in the foregoing rules and regulations, and Trillium must ensure that it has a sufficient network to provide an array of services, including (i) urgent care within 72 hours, (ii) well-care visits within four weeks, (iii) emergency oral care within 24 hours, (iv) urgent oral care within one week or as indicated in the initial screening, (v)routine oral care within an average of eight weeks (vi) routine oral care for pregnant women within an average of four weeks (vii) and urgent behavioral health care immediately.
Trillium demonstrated resolution of the original findings based on the following:
- A methodology to gather provider capacity attestations across provider types within its provider network; and
- Infrastructure to monitor utilization across provider types to ensure its network has adequate capacity to meet its membership's needs and to identify and address gaps.
Health Equity and Language Access:
Trillium was notified that it was required to develop and implement a Health Equity Plan designed to address the cultural, socioeconomic, racial, and regional disparities in health care that exist among members and communities in the Tri-County service area. And with regard to language access, Trillium was required to provide culturally and linguistically appropriate services and supports to members.
Trillium has demonstrated resolution of the original findings based on the following:
- Expanded access to language services within its network, including training for providers on accessing language services and a methodology for the ongoing monitoring of language access services;
- A utilization review methodology that includes data stratification by member demographic information and service type; and
- Meaningful engagement of community partners and stakeholders to address the cultural, socioeconomic, racial, and regional disparities in health care among members and communities in the Tri-County service area.
Community Engagement
Trillium was notified that it was required to (i) establish a Community Advisory Council to ensure the health needs of Tri-County members are being addressed, (ii) draft a Community Health Assessment, and (iii) Community Health Improvement Plan with key partners.
Trillium has now demonstrated resolution of the original findings based on the following:
- Establishing the North Service Area Community Advisory Council, including robust consumer-member representation and bi-directional feedback between the CAC and Trillium Community Health Plan North Board of Directors;
- Meaningful engagement of community partners and stakeholders to address the cultural, socioeconomic, racial, and regional disparities in health care among members and communities in the Tri-County service area; and
- Meaningful progress towards creating the draft Community Health Assessment and the Community Health Improvement Plan in partnership with the Healthy Columbia Willamette Collaborative.
Intensive Care Coordination
Trillium was notified that it is required to automatically screen all members of Prioritized Populations for ICC services and to make ICC services available to all members of Prioritized Populations who qualify for them.
Trillium has now demonstrated resolution of the original finding based on the following:
- Tracking engagement of members identified as potentially eligible for Intensive Care Coordination to ensure that ICC screenings, assessment, and enrollment occur in a timely manner in accordance with OAR 410-141-3870.
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