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The 2019-20 May Revision: Governor's May Revision Medi-Cal Budget
The 2019-20 May Revision: Governor's May Revision Medi-Cal Budget
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( Update 5/29/19: For our comments on changes to health realignment, see our consolidated post: Updates to the Governor's 1991 Realignment Proposals .)
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May 14, 2019
The 2019-20 May Revision
Governor s May Revision Medi-Cal Budget
Overview. The Governor s May Revision includes Medi-Cal spending of $19.7 billion from the General Fund ($93.4 billion total funds) in 2018 19 and $23 billion from the General Fund ($102.2 billion total funds) in 2019 20. As shown in Figure 1, the May Revision reflects a net decrease of about $850 million (General Fund) combined across 2018 19 and 2019 20, relative to previous estimates released in January. As will be described in more detail below, about half of the reduction in estimated spending in 2018 19 reflects a shift of costs in Medi-Cal to a different budget item, rather than a true reduction in estimated program costs. After accounting for this shift, the May Revision is about $350 million below January estimates across 2018 19 and 2019 20.
Figure 1
Administration’s January and May Revision Medi-Cal Estimates
General Fund (In Millions)
2018-19
2019-20
January proposal
$20,679
$22,877
May Revision
19,680
23,018
Change in Estimated Spending at May Revision
-$999
$141
Major May Revision Budget Adjustments
Below, we describe the major factors that contribute to adjustments to estimated General Fund spending in 2018 19 and 2019 20 in the May Revision.
Estimated General Fund Costs in 2018 19 Down by Nearly $1 Billion. The major factors that contribute to the nearly $1 billion reduction in estimated General Fund spending in 2018 19 include:
Shift of Federal Repayment out of Medi-Cal Budget. The administration s January estimate included a projected repayment of almost $500 million from the state to the federal government for incorrectly claimed enhanced federal funding on behalf of certain children in enrolled in Medi-Cal. In light of significant uncertainty about the timing and final amount of this repayment, the May Revision removes this repayment from the Department of Health Care Services (DHCS) budget and instead budgets this payment in a separate account for contingencies in 2019 20. This reduction represents a transfer within the budget and therefore does not represent a real reduction in Medi-Cal costs.
Various Adjustments Related to Updated Estimates and Timing Shifts. The May Revision reflects various adjustments, both costs and savings, in 2018 19 that are related to updated estimates or timing shifts. These adjustments include such things as federal reimbursement for claims that were eligible for enhanced federal funding but were incorrectly claimed at the traditional rate, retroactive managed care payments to reflect finalized rates, and the shift of certain regular repayments to the federal government into 2019 20. On net, these changes result in net savings in the low hundreds of millions of dollars in 2018 19 relative to the January estimate.
Reduced Caseload. The May Revision reflects savings in the low hundreds of millions of dollars in 2018 19 related to lower estimated caseload compared to the January estimate.
Estimated General Fund Costs in 2019 20 up by About $140 Million. The $141 million increase in estimated General Fund spending in 2019 20 reflects the net effect of the following:
Reduced costs to expand coverage to all young adults regardless of immigration status, reflecting a later implementation date and lower estimated new enrollment.
Greater than previously estimated increases in per-capita managed care costs.
The shift of various costs and savings from 2018 19 to 2019 20.
Savings related to lower projected caseload compared to the January estimate.
Caseload Estimates. The May Revision projects that the Medi-Cal caseload will decline 2.4 percent to an average of 13,006,700 enrollees each month in 2018 19 relative to 2017 18. The May Revision further projects that the Medi-Cal caseload will remain essentially flat in 2019 20 at an average of 13,009,068 enrollees each month. In our view, these caseload estimates are cautious. The Medi-Cal caseload may decline in 2019 20, as it has in recent years, raising the possibility that Medi-Cal spending may be less than assumed in the May Revision. However, in light of uncertainty in caseload projections and other aspects of the Medi-Cal budget, we do not recommend adjusting the Medi-Cal budget to reflect lower caseload assumptions at this time.
Governor s May Revision Does Not Propose to Extend the MCO Tax Package
Background. For several years, the state has imposed a tax on managed care organizations (MCOs) that leverages significant federal funding. In combination with a package of associated tax changes, the existing MCO tax package generates a net General Fund benefit of around $1.5 billion. Under state law, the MCO tax package expires at the end of 2018 19. Extending the MCO tax past 2018 19 would require statutory reauthorization from the Legislature and approval from the federal government. Based on the recent federal approval of a similar tax in Michigan, we believe federal approval of a reauthorized California MCO tax package is likely. For more information, see our recent report, The 2019 20 Budget: Analysis of the Medi-Cal Budget .
Governor s Position Unchanged on Allowing the MCO Tax Package to Expire . . . The Governor s May Revision does not include a proposal to extend the MCO tax package in 2019 20. Allowing the MCO tax package to expire would forego a significant General Fund benefit. The administration still has not laid out a convincing rationale for not seeking an extension of the tax package. Accordingly, we recommend the Legislature to seriously consider renewal of the MCO tax package and explore the trade offs of renewing the MCO tax package in its current or a modified form.
Update on Governor s Drug Pricing Initiative
As we describe in our report, The 2019 20 Budget: Analysis of the Carve Out of Medi-Cal Pharmacy Services From Managed Care , Governor Newsom signed an executive order to transition by January 2021 the pharmacy services benefit in Medi Cal from managed care to entirely a fee-for-service benefit. A principal rationale for the transition is to generate General Fund savings. At the time of the Governor s budget, however, the administration did not release a precise fiscal estimate of the General Fund savings under the transition. The May Revision includes an estimate of $393 million in annual General Fund savings that would be realized by 2022 23. The administration has released detail on the fiscal estimate that identifies some of the major assumptions behind the estimate. Since no legislative action needs to be taken for the 2019 20 budget, we plan to assess the fiscal estimate for both reasonableness and to better understand the impacts of the transition on major Medi-Cal stakeholders in the coming weeks or months.
Improving Medi-Cal Fiscal Estimates and Budget Transparency
Earlier this year, we provided our assessment of the Governor s proposal to (1) provide increased staff at DHCS to improve the department s ability to track cash flows and reconcile Medi-Cal spending to budget projections and (2) create a special fund to smooth the impact of drug rebates on the Medi-Cal budget. In the May Revision, the Governor s staffing proposal is unchanged, but the Governor proposes depositing $172 million in the drug rebate special fund.
Lack of Transparency and Large, Unanticipated Budget Adjustments a Significant Concern. As we noted earlier this year, significant, unanticipated changes to the Medi-Cal budget have become routine. For example, the May Revision reflects a $3.3 billion reduction in estimated General Fund spending in 2018 19 compared to the 2018 19 Budget Act approved last June . Figure 2 shows the amounts by which Medi-Cal estimates from the annual budget act were later adjusted in recent years. Considering the Medi-Cal program is a major General Fund expenditure, large, unanticipated budget adjustments in Medi-Cal can interfere with the Legislature s ability to formulate and pursue longer-term fiscal plans in alignment with its priorities. Complexity and lack of transparency in the Medi-Cal budget also creates challenges for the Legislature to independently oversee operations of the program.
Recommendations. In addition to continuing to recommend the approval of the Governor s staffing proposal and the creation of the drug rebate special fund, we recommend that the Legislature take the following actions:
Require DHCS to Share Key Information Gained From Improved Monitoring With Legislature. We recommend that the Legislature require DHCS, in connection with approval of the requested positions, to share key information from monitoring of the Medi-Cal budget with the Legislature. In the near term, regular updates on cash flows that would compare actual spending to estimated budget amounts would be a reasonable first step.
Require DHCS to Begin Inclusive Process to Plan for Longer-Term Structural Changes to Promote Sound Estimates and Budget Transparency. The DHCS has indicated that it intends to continue assessing possible long-term solutions to address these challenges. To continue moving forward on these issues and to ensure appropriate legislative oversight, we recommend that the Legislature require DHCS to develop and present to the Legislature a longer-term plan with changes to budgeting, accounting, and information technology systems to promote sound estimates and budget transparency. We further recommend that the Legislature direct DHCS to initiate a legislative stakeholder process that would include the Legislative Analyst s Office and other legislative staff in order to identify possibilities for future changes. This would help ensure that changes developed by the department promote transparency and facilitate increased oversight of the Medi-Cal budget.
Approve Transfer of Drug Rebates to Special Fund Consistent With May Revision Proposal. We have reviewed the amounts proposed to be deposited in the drug rebate special fund and find them reasonable. Consistent with our previous recommendation to approve the creation of a drug rebate special fund, we recommend that the Legislature approve the transfer as reflected in the May Revision.
Significant Changes to the Governor s Proposition 56 Multiyear Spending Plan
The May Revision proposes a variety of changes related to the use of Proposition 56 funding in Medi-Cal over the next several years. For background on the use of Proposition 56 funding in Medi-Cal and the Governor s related January proposal, see our report: The 2019 20 Budget: Using Proposition 56 Funding in Medi-Cal to Improve Access to Quality Care .
Background
Proposition 56 (2016) Raised State Taxes on Tobacco Products and Dedicates Most Revenues to Medi Cal on an Ongoing Basis. Medi Cal began receiving Proposition 56 funding in 2017 18. Funding from Proposition 56 is intended to ensure timely access to quality care within the Medi Cal program. Proposition 56 currently provides about $1 billion annually to Medi Cal. Proposition 56 funding in Medi-Cal has been used for two main purposes: (1) augmenting the program, such as by increasing Medi-Cal provider payments, and (2) offsetting General Fund spending on underlying cost growth in Medi-Cal.
Governor s January 2019 20 Budget Proposal
The Governor s January budget proposed to use all Proposition 56 funding on provider payment increases, thus eliminating the General Fund offset (which applied to cost growth in Medi-Cal). In addition, the Governor stated an intent to make most of the Proposition 56 funded provider payment increases permanent. Finally, the Governor proposed new provider payment increases including a value-based payment program and incentive payments for developmental and trauma screenings.
May Revision Proposes Significant Changes to the Use of Proposition 56 in Medi-Cal
As we describe below, the Governor s May Revision proposes a variety of major changes to the use of Proposition 56 funding in Medi-Cal over the next several years.
Sunsets All Policy Augmentations Using Proposition 56 Funding Halfway Through 2021 22. Most significantly, the May Revision proposal would sunset all Proposition 56-funded policy augmentations in Medi-Cal as of January 1, 2022. Accordingly, all Proposition 56-funded provider payment increases and other policy augmentations would be eliminated beginning at the halfway point of 2021-22. Rather than funding these augmentations, Proposition 56 funding in Medi-Cal would support cost growth in the program, thereby offsetting General Fund costs. The Governor s primary rationale for eliminating these augmentations is to prevent a budget-wide structural deficit that the administration projects would otherwise arise beginning in 2021-22. Eliminating the Proposition 56 augmentations, in conjunction with eliminating several other augmentations in the Health and Human Services area, is intended to address this structural budget deficit. As displayed in Figure 3, we estimate that the sunset of Proposition 56 funding for Medi-Cal policy augmentations will reduce General Fund spending in Medi-Cal by around $300 million in 2021-22 and around $750 million in 2022-23.
Revises Proposition 56 Revenues for Medi-Cal Upward by $263 Million on a One-Time Basis. Additional funding available for Medi-Cal results from a one-time reconciliation that found that an additional $263 million in Proposition 56 revenue should have been allocated to Medi-Cal in 2017-18. The May Revision proposes dedicating this additional funding to the following one-time purposes beginning in 2019-20:
Additional $120 Million for Medi-Cal Physician and Dentist Student Loan Repayment Program. In the 2018 19 spending plan, $220 million in Proposition 56 funding was dedicated to create a physician and dentist student loan repayment program. The program financed with one time funding available over multiple years will help repay the student loans of physicians and dentists who serve significant numbers of Medi Cal patients. The Governor s May Revision would increase total Proposition 56 funding for this program to $340 million, with $290 million going to physicians and $50 million going to dentists.
Additional $70 Million for Value-Based Payment Program. In January, the Governor proposed establishing a limited-term value-based payment program using $180 million in annual Proposition 56 funding from 2019-20 through 2021-22. The May Revision would provide an additional $70 million in 2019-20. However, the proposed sunset of Proposition 56 policy augmentations in Medi-Cal at the end of 2021 could result in reduced funding for the value-based payment program in 2021 22, the final year of the limited-term program. According to the administration, it is uncertain how much Proposition 56 funding would be provided to the value-based payment program in 2021-22 under the Governor s multiyear spending plan.
$60 Million Over Three Years to Train Providers on Trauma Screenings. The Governor s budget proposed using Proposition 56 funding to expand the use of trauma screenings in Medi-Cal. It is our understanding that, today, formal screening for trauma is relatively rare among physicians and other health care providers. As such, the May Revision proposes using $60 million in Proposition 56 funding, spread out over three years, to train health care providers on the use of formal trauma screening tools.
Restores Optician and Optical Lab Services. In addition to the above one-time augmentations and the other augmentations and extensions proposed in January, the May Revision proposes using $11 million in Proposition 56 funding to restore optician and optical lab services in Medi-Cal benefits which were cut during the recession in 2009. The restoration would be effective no sooner than January 1, 2020. As with all other Proposition 56 augmentations, however, the restoration would be eliminated as of January 1, 2022.
Assessment
Proposed Sunset of Proposition 56 Policy Augmentations Raises Concerns
While Making Most Proposition 56 Provider Payment Increases Limited Term Has Policy Merit . . . As we noted in our previous analysis of the Governor s January Medi-Cal budget proposal, to date, we are aware of no analysis that has been released showing that the existing Proposition 56 provider payment increases have been effective in improving access to quality care in Medi Cal. Thus, making most Proposition 56 provider payment increases limited term would allow their effectiveness to be assessed before they are made permanent. For this reason, we recommend that the Legislature keep most Proposition 56 provider payment increases limited term and direct the administration to produce a report on their efficacy in improving access to quality care.
. . . Sunsetting the Provider Payments for Fiscal Management Reasons Raises Concerns. As we note in our office s Initial Comments on the Governor s May Revision , the Governor sunsets a variety of budget-year proposals in order to maintain a balanced budget through the forecast period ending in 2022-23. We raise a number of concerns with the Governor s approach, finding that the May Revision understates the true ongoing cost of its policy commitments.
Outstanding Questions About the Cost-Effectiveness of the Value-Based Payments Proposal
As we describe in this section, we have outstanding questions about the cost-effectiveness of the administration s approach for many of the value-based payments being proposed.
DHCS Plan to Strengthen Oversight of Clinical Outcomes in Medi-Cal Managed Care. Recently, the administration released a plan (and an associated funding proposal) to significantly increase its oversight over the quality of care that Medi-Cal managed care plans deliver to their members. (Around 80 percent of Medi-Cal beneficiaries are enrolled in managed care.) These efforts include holding managed care plans accountable for meeting significantly higher standards on a variety of performance measures related to clinical care. These performance measures include, for example, the proportion of children receiving recommended preventive well child visits and the proportion of children who have received all recommended vaccinations. Failure to meet these higher Medi-Cal standards is to result in Medi-Cal managed care plans being placed on corrective action plans and, potentially, immediate sanction. To help Medi-Cal managed care plans meet these higher standards, it is likely that the state will have to increase capitation funding for plans.
Value-Based Payment Program Has Significant Overlap With Measures That Managed Care Plans Will Be Accountable to Improve . . . Figure 4 shows that the proposed Proposition 56 value-based payment program would provide supplemental payments for many of same measures for which Medi-Cal managed care plans are being held accountable and likely funded through capitation to significantly improve. In one case, the value-based payment program would offer supplemental payments for activities (well-child visits) for which physicians already receive Proposition 56 supplemental payments.
Figure 4
Value Based Payment Program Would Pay Providers to Improve Clinical Quality Measures That Managed Care Plans Are Separately Responsible for Improving
Activities That Trigger a Proposition 56 Supplemental Payment
Managed Care Clinical
Quality Measures
Value Based Payment Measure
Adult influenza vaccine
All childhood vaccines for two year olds
Blood lead screening tests
Colocation of primary care and behavioral health services
Control of persistent asthma
Controlling high blood pressure
Dental fluoride varnish
Diabetes care
Management of depression medication
Postpartum birth control
Postpartum care visit
Postpartum depression screening
Prenatal care visit
Prenatal pertussis vaccine
Screening for clinical depression
Screening for unhealthy alcohol use
Tobacco use screening
Well child visits for three to six year olds
Well child visits in first 15 months
Proposed New Prop 56 Supplemental Payment
Developmental screenings
Existing Proposition 56 Supplemental Payment
Well child visits for children of all ages
. . . Raising Questions About the Cost-Effectiveness of Parts of the Value-Based Payment Plan. As a result of this significant overlap, we have outstanding questions about the cost-effectiveness of parts of the value-based payment program, which could potentially result in the state paying twice for the achievement of very similar outcomes. (Such questions also motivated our recommendation of alternative approaches to the Governor s proposal to provide supplemental payments for developmental screenings, which we describe in our report: The 2019-20 Budget: Governor’s Proposals for Infants and Toddlers With Special Needs .)
Legislature Could Consider Scaling Back Value-Based Payment Program to Account for Overlap. We strongly agree with the administration s goal of improving the quality of care in Medi-Cal. In particular, we support the administration s efforts to improve the quality of care through strengthened oversight of Medi-Cal managed care given that (1) 80 percent of Medi-Cal beneficiaries are in managed care and (2) that holding plans accountable for meeting high standards of care through the use of corrective action plans and sanctions reflects a prudent approach to improving outcomes. In light of these parallel quality improvement efforts, the Legislature could consider scaling back funding for the value-based payment program in areas where there is significant overlap with managed care quality improvement efforts. Any freed up funding could be used to (1) support other provider payment increases, (2) offset General Fund spending on cost growth in Medi-Cal, or (3) held in reserve. This latter option could help prevent the state from having to eliminate all Proposition 56 augmentations midway through 2021-22 to forestall a budget deficit, as is proposed in the May Revision.
Medi-Cal Expansion for Undocumented Young Adults
The May Revision maintains the Governor s proposal to expand full-scope Medi-Cal coverage to undocumented adults ages 19 through 25. The updated May budget proposes to make two significant revisions to the January proposal. Figures 5 and 6 summarized how the General Fund costs of the expansion have been revised between the January budget and the May Revision.
Figure 5
Projected 2019 20 Cost of Full Scope Expansion for
Undocumented Adults Ages 19 Through 25
New Full Scope
Enrollees
General Fund Cost (In Thousands)
Medi Cal
IHSS
Total
January budget
119,000
$194,250
$1,300
$195,550
May Revision
83,000
72,150
770
72,920
IHSS = In Home Supportive Services.
Notes: IHSS May Revision estimate is an LAO estimate.
Figure 6
Projected Ongoing Cost of Full Scope Expansion for
Undocumented Adults Ages 19 Through 25
Average Monthly
Caseload
General Fund Cost (In Thousands)
Medi Cal
IHSS
Total
January Budget
136,000
$255,000
$33,000
$288,000
May Revision
104,000
180,000
26,000
206,000
IHSS = In Home Supportive Services.
Notes: All estimates are LAO estimates.
Moves Back Implementation Date From July 1, 2019 to January 1, 2020. The May Revision moves back implementation of the expansion from July 1, 2019 to January 1, 2020, resulting in one-time General Fund savings relative to the January budget of about $100 million in 2019-20. We believe half-year implementation makes sense in light of the administrative activities that DHCS will have to undertake to effect the transition to full-scope coverage.
Significant Downward Revision to Projected Caseload, Lowering Projected Ongoing Costs. The May Revision features a significant reduction in the projected ongoing caseload from around 150,000 average monthly enrollees to about 100,000 average monthly enrollees. In our Analysis of the Medi-Cal Budget , we recommended a reduction in projected ongoing caseload of around 10 percent due to what we found to be an implausible estimating assumption. The May Revision revises downward the projected ongoing caseload by over 30 percent to reflect updated information about size of the low-income, undocumented young adult population. We project that this adjustment results in about $80 million in ongoing General Fund savings relative to the January budget. At the time of this analysis, we do not yet have a clear understanding of the causes of this significant reduction to the projected ongoing caseload. While we do not have any major concerns, we recommend that the Legislature ask the administration during upcoming budget proceedings about what explains the significant downward revision in projected ongoing caseload.
Changes to Health Realignment
Key Updates to January Proposal
In the May Revision, the Governor makes several key changes to his January proposal, described below.
Treat Yolo County as Part of CMSP for Purposes of Redirection. For most CMSP counties, the Governor s proposed redirection was limited to a predetermined amount for each county referred to as jurisdictional risk. The remaining redirection for these counties would come from the CMSP board. However, for Yolo County, which joined CMSP in 2011, the Governor s proposal would have redirected a larger amount of funding, as though Yolo did not belong to CMSP. The Governor s revised proposal would now treat Yolo County in the same manner as other counties that previously joined CMSP, such that Yolo County s redirection would be limited to its jurisdictional risk amount.
No Longer Increase Redirection From Four Non-CMSP Counties. In response to concerns that the increased redirection would have reduced funding available for local public health activities in the four counties that do not participate in CMSP (Placer, Sacramento, Santa Barbara, and Stanislaus), the Governor s revised budget proposes to continue redirecting 60 percent (rather than 75 percent) of health realignment funding to the state for those four counties. The administration estimates that this change, along with changing how Yolo County is treated, reduces the overall redirection from counties to the state by about $5 million.
Continue Redirecting CMSP Board Funding. The Governor s revised proposal continues to propose redirecting 75 percent of health realignment funds from CMSP counties. As noted above, the amount redirected from the counties themselves is limited to the counties jurisdictional risk and most of the redirection for these counties comes from the CMSP board. As in the January proposal, this effectively redirects all of the CMSP board s annual funding, such that the board would continue to provide services using its substantial reserves. In contrast to the January proposal, the Governor s revised proposal would stop annual realignment funding to CMSP until its reserves reach a level consistent with a longer period of operations two years in response to concerns that three months of operating reserves as initially proposed was likely insufficient.
LAO Comments
Governor s Proposal Reflects Policy Decision to Increase County Funding Relative to Responsibilities in Selected Counties. In an earlier analysis of the Governor s January proposal, we noted that additional redirection from counties to reflect the expansion of Medi-Cal coverage was justified. However, we also noted that public health funding activities could be negatively impacted at the proposed 75 percent level in Yolo County and the four non-CMSP counties referenced above. By revising the proposal to (1) treat Yolo County as part of CMSP for purposes of the redirection and (2) no longer increase the redirection percentage for the four non-CMSP counties, the Governor s proposal eliminates the possibility that public health funding could be negatively affected in these counties. Since the four non-CMSP counties could still have reduced costs in light of the Medi-Cal expansion (depending on how much they spend on health care services for undocumented young adults that would now be covered by Medi-Cal), it is possible the Governor s revised proposal effectively increases funding in those counties by a small amount relative to their responsibilities. Ultimately, the fiscal relationship between health realignment revenues and county responsibilities is difficult to determine with precision. In our view, providing additional funding for these counties in this way represents a reasonable fiscal priority, but one that the Legislature should weigh against other priorities for funding in the state budget.
Redirecting CMSP Board Revenues Until Reserves Decline Makes Sense . . . As we noted in our earlier analysis, we find the Governor s proposal to redirect CMSP board revenues until reserves reach a lower level reasonable. We further find that two years is a reasonable target level for reserves before additional revenues would be provided to CMSP. Even with this higher targeted reserve level, it will likely take the CMSP board several years to spend down its reserve to this level.
. . . But 75 Percent Redirection From CMSP Likely Still Too High. By setting the redirection percentage for CMSP counties at 75 percent, the state would redirect all of the CMSP board s annual revenues, as described above. While it is reasonable to redirect these revenues until reserves decline, setting the redirection at 75 percent may mean that the CMSP would not receive any revenues even after its reserves are reduced. In other words, the effect of the 75 percent redirection is reasonable in the short run as a mechanism to redirect all of the CMSP board s revenues until reserves are reduced, but may not be a reasonable ongoing redirection percentage. The appropriate ongoing redirection percentage is highly uncertain, and will depend on the extent of CMSP responsibilities in several years once reserves are reduced.
No Need to Set Ongoing Redirection Percentage Now. Ultimately, the Legislature need not set an ongoing redirection percentage for CMSP counties now in order to achieve the goal of redirecting CMSP revenues until its reserves have reached a lower, more reasonable level. The Legislature could instead take the following three actions: (1) enact language that would specifically redirect all CMSP revenues until reserves reach a specified lower level (such as two years of operating expenses as proposed by the Governor); (2) leave the redirection percentage for CMSP counties at 60 percent; and (3) direct the administration to revisit the appropriate redirection percentage later, when CMSP reserves have fallen below the target level. The Legislature would be in a better position to assess the role and appropriate funding level for CMSP in light of conditions at that time.
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( Update 5/29/19: For our comments on changes to health realignment, see our consolidated post: Updates to the Governor's 1991 Realignment Proposals .)
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