Implementation Guide No. 2
States can use this section to learn more about the seven CME features shown in Figure 1. For each feature, the guide describes decision points and tradeoffs identified by the CHIPRA quality demonstration States (go to Appendix B for a description of the specific design features that Maryland, Georgia, and Wyoming selected for their CMEs).
Design Feature 1: Funding Mechanisms
CMEs can be funded by one or more child-serving agencies. Agency directors typically decide if they will help fund CME services, although political leaders (for example, the governor) or court mandates can also direct agencies to participate. Child-serving agencies initiating the CME design process can use strategies outlined in Part 3 of this guide to encourage other agencies to contribute funding.
- CMEs funded by multiple agencies often can serve a larger number of youth, provide more support to youth they serve, or both. Moreover, agencies contributing funding are more likely to engage actively in the CME design process, and the additional funding may help with long term CME sustainability.
- However, when multiple agencies contribute funding, the CME management structure can be complex (see section on “Management Structure”).
To augment State-only funding, agencies can also seek Federal dollars to help support CME services. Federal funding sources include programs with matching Federal dollars (for example, Medicaid in which the Federal government pays for a percent of program expenditures), Federal block grant dollars (such as mental health block grants), and other Federal grant programs (for example, SAMHSA System of Care grants).
- Seeking Federal funding may increase the number of youth a State is able to serve or the type of services the CME would be able to provide with State funding alone. For example, the Federal share of Medicaid funding would permit a State to free up State-only dollars to serve youth who do not qualify for Medicaid or to cover support services not funded by Medicaid.
- Using Federal funding to cover CME services, however, can limit CME design flexibility. The State should consider very carefully what Federal funding mechanisms are most appropriate because each option will affect how the CME can be structured. Specifically, the funding mechanism selected may affect:
- Who is eligible to be served by the CME.
- What services are available through the CME.
- How many providers and what types of providers are eligible to be a CME.
- The ability to pilot a CME with a limited number of youth or in a specific geographic location.
Design Feature 2: Management Structure
States will need to determine (1) the type of organization that will contract for and oversee CME services, (2) the level of management, and (3) the flow of funding from multiple agencies to the CME, if relevant.
Type of Organization Managing CMEs
Different organizations can contract for and oversee CME services, including:
- Child-serving State or local agencies.
- Medicaid managed care organizations.
- Cross-agency committees or purchasing collaboratives.
The type of organization responsible for contracting and oversight is closely related to how funding flows from the agencies to the CME.
If one agency is the only funding agency, it will typically use the same procedures in place for contracting with and overseeing other behavioral health or social services. For example, a Medicaid agency may contract directly with the CME, or it may leave contracting to Medicaid managed care organizations if behavioral health services are provided under a managed care arrangement.
If multiple agencies are funding a State’s CME, the State should consider selecting a cross-agency committee to oversee CME services. The advantage here is twofold: the managing organization represents all the agencies, thereby making them comfortable with how their funds are spent, and it is the single entity to which a CME reports, thereby simplifying the administrative logistics related to accountability. For administrative ease, the committee may choose to designate one agency to oversee day-to-day CME operations.
CHIPRA Quality Demonstration State Experiences: CME Management and Oversight Maryland’s statewide CME funded by multiple agencies is managed by the Children’s Cabinet, at the Governor’s Office for Children, a group with high-level representation from all child-serving agencies. Maryland’s Medicaid-funded CMEs will be managed at the county level to increase local control. |
Level of CME Management: State or Local
CMEs can be managed at the State or local level.
- By centralizing CME management at the State level (for example, by State agency offices), States may reduce administrative costs, simplify the referral and utilization review process, and decrease disruptions when youth move across the State. CMEs managed at the State-level, however, may face challenges overseeing care coordinators spread throughout the State and may be less familiar with local needs and available resources. To address these concerns, a State can (1) contract with multiple CMEs that specialize in different regions, (2) require CMEs to establish regional or local offices and hire local staff, and (3) facilitate meetings with the CME and local community members (for example, case workers, county attorneys, and community behavioral health providers).
- In contrast, local entities, such as county behavioral health offices, have a working knowledge of local needs and resources. Local entities may be better able to (1) identify youth who could benefit from CME services, (2) coordinate local home- and community-based providers, and (3) foster trust with youth, their families, and the community. However, under local contracting arrangements, a State may struggle to maintain fidelity to a single CME design, and as a result, it may need to implement a rigorous quality monitoring process. Moreover, localities with relatively few youth who qualify for CME services may need to pool together and create regional CMEs for the service to be financially viable.
Flow of funding from multiple agencies
If multiple agencies are funding CME services, States have two options for managing the flow of funds:
Braided funding. In braided funding, each contributing agency pays the CME individually. The agencies can put limits on how their dollars are used and can track how they are spent. A given agency might pay for a subset of children receiving CME services. For example, Medicaid could pay for Medicaid-eligible youth, and juvenile justice could pay for youth not eligible for Medicaid. Or, one agency would pay for particular services provided by the CME (for example, Medicaid could pay for Medicaid-reimbursable services, and social service funding could be used to cover additional services).
Blended funding. In blended funding, agencies contribute funding to a single “bucket,” and then all of the funds are paid to the CME. The CME can use the dollars to cover any service for any youth served by the CME.
- Agencies relying on braided funding have more control over how their respective funds are used and should be able to account for how their funds are spent. However, funds are typically designated for particular youth or certain services, so CMEs have less flexibility to spend available funds to cover any services required.
- In contrast, CMEs funded through a blended funding approach have more control over how funds are spent. However, agencies using a blended funding approach may face more administrative challenges in linking the source of funds and the services delivered and therefore may want to institute more intensive monitoring processes.
Design Feature 3: Eligibility Criteria
CMEs typically enroll youth who are served by at least one of the CME funding agencies. These agencies often target youth with complex behavioral health needs who would otherwise be served in out-of-home placements.9 For example, if Medicaid is funding the CME, it generally targets youth who are eligible for care in a hospital or residential treatment center. Juvenile justice funding, as another example, may be used to serve youth who would otherwise be placed in juvenile detention centers.
In addition, a State could open up enrollment to other youth at risk for greater system involvement or with high costs or high service needs. These youth could include, for example, individuals with frequent emergency room use for behavioral health concerns, those using multiple psychotropic medications, or youth in alternative school settings.
- Limiting CME services to youth who qualify for out-of-home placements is administratively straightforward, assuming a State has an effective process in place for identifying and screening these youth. In addition, by substituting CME services for out-of-home care, the State is most likely to demonstrate cost savings for this population.
- Expanding the criteria for entry into a CME increases the number of youth in the State who can receive CME services and may prevent out-of-home placements or other adverse outcomes. However, expanding the eligibility criteria may reduce the cost effectiveness of CMEs. States can analyze utilization data and work with stakeholders to determine additional populations that may benefit from CME services. Before expanding the CME population, a State should consider the capacity its CME has available to serve more youth and any additional training CMEs may need to serve new populations.
CHIPRA Quality Demonstration State Experiences: CME Participant Identification Maryland and Wyoming use The Child and Adolescent Service Intensity Instrument (CASII) and the Early Childhood Service Intensity Instrument (ECSII) to identify youth who qualify for or are at risk for residential treatment. In addition, Maryland is providing CME services to youth identified by schools as at risk for greater system involvement based on an ongoing history of expulsions, suspensions, absences, and poor academic performance. |
After selecting the eligibility criteria for CME services, the State will need to establish a process to identify and refer youth to CMEs. States can rely on referrals from the community, use administrative data to identify eligible youth, or both.
- Community referrals can come from a variety of organizations including physical and behavioral health providers, case workers, courts, family advocacy organizations, and schools. In some States, families and youth can also self-refer for CME services. Once a youth is referred, an organization (such as a State agency or a utilization review vendor) determines if the youth qualifies for services. To help ensure an accurate referral process, States should consider using a standard assessment tool administered by an organization other than the CME and its vendors. In addition, States may need to educate potential referral organizations about the CME so they understand and trust the model; otherwise they may be hesitant to refer youth for services, or they may refer youth who are not eligible for CME services.
- States can also use administrative data to identify youth who may qualify for CME services based on prior service use. This strategy may help States identify the first cohort of youth to target for CME enrollment. However, this method may be ineffective if service-use data and contact information are out of date or inaccurate or if families are not receptive to “cold calls” from the CME.
CHIPRA Quality Demonstration State Experiences: Referral Process Community providers in Georgia use a standard form to refer youth for CME services. |
Design Feature 4: Services
As noted in Part 2, all CMEs provide intensive care coordination for youth. The National Wraparound Initiative sets standards for high fidelity wraparound, such as the frequency of child and family care team meetings and the composition of child and family care. States can require CMEs to follow the standards outlined in that model.
For CMEs to effectively deliver this model, a State needs (1) a sufficient network of home- and community-based service providers and family and youth supports and (2) an established utilization management process to help ensure youth receive these services over more costly or less effective options.24 State agencies, the CME, or another utilization management organization can take on responsibility for developing, managing, and paying for these services. Specifically, States can make CMEs responsible for:In the second year of their contract, the CME in Wyoming will take on financial risk and be required to coordinate, administer, and reimburse all behavioral health services with the exception of pharmacy. The State decided to not require the CME to take on financial risk in the first year so the CME had time to develop its network and start enrolling youth.
Identifying gaps in service availability and encouraging providers to offer new services.
- Managing a discretionary fund that can be used to support a variety of youth and family needs by helping families pay for household necessities, modest recreational activities, or services otherwise not covered by their insurance.a
- Contracting and paying for a limited number of services, such as crisis response or family support.
- Taking on financial risk for some or all behavioral health and social services provided by CME funding agencies.
CHIPRA Quality Demonstration States Experiences: Additional Service Requirements In the second year of their contract, the CME in Wyoming will take on financial risk and be required to coordinate, administer, and reimburse all behavioral health services with the exception of pharmacy. The State decided to not require the CME to take on financial risk in the first year so the CME had time to develop its network and start enrolling youth. |
There are benefits and drawbacks to asking CMEs to take on one or more of these additional services.
- CMEs may be better positioned to take on these responsibilities than the State or another organization because they are more familiar with the service needs of the enrolled youth, and their staff work closely with community providers.
- CMEs assigned these additional responsibilities have more accountability for the full range of service needs and can exert more control over service delivery. With more control, CMEs may more easily coordinate services, potentially improving outcomes while decreasing costs to the State. However, the State may have to increase its monitoring and oversight efforts to ensure the CME does not shift costs from CME funding agencies to agencies that do not contribute funding.
- Requiring CMEs to provide other services may limit the pool of CME providers, since not all organizations qualified to provide high fidelity wraparound have the capacity to take on additional responsibilities. States could consider helping CMEs build capacity to take on these responsibilities, phase in increased responsibilities over time, or both.
a Depending on the CME funding agencies, CMEs can cover youth with private or public insurance or uninsured youth. Discretionary funds can be used to cover services included in the youth’s care plan that are not otherwise covered by their insurance policy.
Additional Information on National Wraparound Initiative Standards |
Design Feature 5: Eligibility and Training to be a CME
CME Eligibility
Different types of organizations can serve as CMEs, including managed care organizations, community-based nonprofits, and behavioral health provider organizations. The number of CME contracts a State holds can vary widely, depending on the size of the geographic area covered, the number of youth in the area who qualify for services, and the number of youth CMEs can serve. In consultation with stakeholders, States can determine how many CMEs to contract with, set minimum requirements for CMEs, and define selection criteria for participation.
Prior experience or certification. States can require providers to have experience, specialized training, or certification delivering high fidelity wraparound or other care management services, such as targeted case management.
- Having CMEs with previous experience providing intensive care coordination reduces the need for initial training and allows CMEs to get up and running faster. This may save time and costs. However, certain requirements (for example, requiring CMEs to have prior experience coordinating care across all child-serving agencies) may limit the pool of potential CMEs.
- Without the requirement of prior experience or certification, a State will likely have to make additional investments—both short term and long term—in training and capacity building to ensure CMEs are prepared to deliver services according to the high fidelity wraparound model.
CHIPRA Quality Demonstration States Experiences: CME Provider Eligibility In the second year of their contract, the CME in Wyoming will take on financial risk and be required to coordinate, administer, and reimburse all behavioral health services with the exception of pharmacy. The State decided to not require the CME to take on financial risk in the first year so the CME had time to develop its network and start enrolling youth. |
Provision of direct services. To minimize the risk of providing unwarranted services, States could exclude organizations that provide direct services, such as mental health counseling, from consideration as CME vendors.
- CMEs that only provide high fidelity wraparound may be better positioned to build trust with community providers because they will not be viewed as competition. In addition, these CMEs may have a more balanced view of available services and will not have a financial incentive to authorize more direct clinical services or encourage families to use their services over those of another provider.
- However, if a State has a limited supply of direct service providers that can treat youth, inclusion of CMEs with this capacity may actually improve timely access to treatment. If CMEs are allowed to provide direct services, a State should consider increased oversight and monitoring of CME service delivery patterns and costs — either directly or through a utilization review vendor.
CHIPRA Quality Demonstration States Experiences: Contracting for CME Services Requests for Proposals and Statements of Need for CME services in CHIPRA quality demonstration States are available at the national evaluation web site. |
Local versus out of State organizations. States may consider contracting with an out-of-State vendor for CME services, especially if the State has limited prior experience with high fidelity wraparound and State regulations allow it to contract with such vendors.
- An organization already operating within a State is likely to have experience with the service delivery system and have relationships with local providers. However, if a State has limited experience with high fidelity wraparound, organizations in the State may not meet other CME eligibility criteria.
- Although out-of-State organizations may have less direct experience with local providers and the service delivery system, they can bring their expertise as CMEs and help build capacity within the State’s system of care. To ensure that out-of-State organizations are successfully integrated with local providers, a State may require CMEs to establish an in-State office, contract with local vendors for care coordination services (as opposed to hiring care coordinators directly), or develop local advisory boards. These requirements can add administrative complexity and may increase initial costs to set up the CME.
CHIPRA Quality Demonstration States Experiences: Out-of-State CME Providers Wyoming contracted with an out-of-State organization for CME services because no local organizations responded to their request for proposals. Some community providers were initially reluctant to refer youth for services. The CME and State are holding local-level stakeholder meetings to build trust in the community. |
Training CME Care Coordinators
Regardless of a CME provider organization’s experience serving youth with complex behavioral health needs, States should expect to offer at least some initial and ongoing training to CMEs and care coordinators.
Additional Resources on CME Staff Training Training, Coaching, and Supervision for Wraparound Facilitators: Guidelines from the National Wraparound Initiative33 |
High fidelity wraparound training should include a fairly in-depth introduction to its key components. Potential training modules include:
- Intensive care coordination.
- Integration of primary and behavioral health care.
- Working with the courts and social workers.
- Youth and family engagement.
- Referral to crisis services.
- Quality improvement and assurance.
- Administrative and technology systems
- Financial management and controls.
As a State monitors CMEs (described under Design Feature 7), it can adjust the training curricula as needed to address emerging service gaps or quality issues.
State agencies involved in funding or managing CMEs can (1) develop and coordinate the training themselves; (2) collaborate with a local organization, such as a university; or (3) seek training services from a more experienced State or organization.
States that coordinate the training themselves or collaborate with a local organization may have more flexibility to adapt the CME training to meet evolving needs in the State. However, States may want to seek external assistance if CMEs or the high fidelity wraparound care planning model are new in the State. One way to leverage the experience of others while building internal training capacity is to consider a “train the trainer” approach. Under this approach, trainers with experience in other States train a cohort of individuals who then train and coach other care coordinators in the State.
CHIPRA Quality Demonstration States Experiences: Training Maryland is introducing CME services as the highest tier of service offered by existing targeted case management providers. While these organizations are experienced at providing care coordination, the State is requiring intensive high fidelity wraparound training so they are prepared to deliver this approach to care coordination. The State collaborates with the Institute for Innovation & Implementation at the University of Maryland’s School of Social Work to develop and provide CME training. In addition, the Institute has helped train providers in other States. |
Design Feature 6: Payment Model and Rate
All CMEs are reimbursed for intensive care coordination services. CMEs may also be reimbursed for other behavioral health or social services if they are responsible for contracting for and managing those services. In addition, States often provide CMEs a limited discretionary fund that can be used to help families pay for household necessities, modest recreational activities, and behavioral health services not covered by insurance.
Payment model
States can align the CME reimbursement model with the prevailing reimbursement models in the State or use a different model. States can:
- Use a fee-for-service (FFS) model and reimburse CMEs for the time they spend providing services (for example, in 15 minute units for care coordination or family support services).
- Use a case rate under which the CME will receive a set payment for each youth enrolled and receiving services from the CME regardless of the time or resources they spend on services. The payments can be made daily, weekly, or monthly. CMEs that are responsible for managing and paying for behavioral health or social services are typically paid using this approach.
- Use a combined approach in which some services (such as care coordination) are included in a case rate and other services (such as family support) are reimbursed on a fee-for-service basis.
There are tradeoffs to these different reimbursement approaches.
- Under the FFS model, a State can more easily track what services are provided. In addition, a State can incentivize the use of preferred home- and community-based providers by, for example, offering a higher reimbursement rate for services that follow evidence-based practices. This reimbursement model, however, can be less flexible than case rates. If using the FFS model, a State should carefully consider what services need to be reimbursed to allow the CME to operate effectively. For example, a State may want to offer reimbursement for both in-person and telephonic care coordination so the CME can provide the most appropriate service.
- In contrast, case rates provide CMEs more flexibility. Case rates also increase a State’s ability to predict and manage total program costs and utilization. However, the State may lose the ability to drill down in their data to analyze service utilization. Additionally, States using case rates should consider implementing additional reporting and quality controls to ensure that beneficiaries receive clinically appropriate services and to confirm the adequacy of the case rate.
Payment rate
The payment rate for CME services will depend on the characteristics of the target populations and the services covered by the CME. The rates for intensive care coordination and family support services will depend on the time required to provide these services and the providers’ salaries. States can set different rates for different populations based on their levels of need. The reimbursement rates for youth with the highest need who meet eligibility criteria for out-of-home placements are typically much higher than other care coordination rates in the State, but they are generally lower than the cost of out-of-home placements.34 Engaging agency leadership and other stakeholders (for example, managed care organizations) in the CME design process may help avoid stakeholders questioning the appropriateness of the rate after the CME is implemented.
Setting the reimbursement rate is more complicated if the State uses a case rate that includes behavioral health and social services. The State can hold the CME accountable for any services overseen and paid for by agencies funding the CME. The State can set the case rate by reviewing the target population’s historical costs for the services managed by the CME. CME payment rates may include:
- Home- and community-based support services.
- Outpatient and inpatient behavioral health services.
- Psychotropic medications.
- Residential stays at psychiatric facilities.
- Services provided at juvenile detention centers.
- Foster care placements.
- Family and youth peer support services.
States may choose to include all services managed by a given funding agency in the case rate or carve out some services. States may want to carve out services that (1) fall outside the direct purview of the CME (for example, specialty physical health services), (2) are managed by a different organization (for example, family advocacy organizations may manage peer support services), (3) are billed through separate administrative data systems and therefore can be difficult to distinguish using real time administrative data (for example, psychotropic medications), or (4) a State wants to closely track (often easier to do with separate fee-for-service claims).
In addition to direct services, CMEs will need to be reimbursed for reasonable general and administrative or overhead expenses, such as training costs and office rental. These expenses can either be embedded in the payment rate or paid to the CME separately. A newly contracted CME may initially have higher overhead expenses since it will need to build an infrastructure to provide services, and it will likely start off serving a smaller population. Over time, a State may consider reducing reimbursement for overhead expenses as efficiency increases.
Additional Resources on CME Case Rates and Reimbursement Models Case Rate Scan for Care Management Entities34 National Conference on State Legislatures: Medicaid Payment Reform35 |
Design Feature 7: Quality Monitoring and Evaluation
In addition to using data to help design the CME (see Part 3), States should plan how to use data to monitor and evaluate the CME once it is operational. This section provides guidance on (1) what data to collect on CMEs, (2) how to use the data to drive quality improvement, (3) how to use the data to evaluate impact, and (4) who can do the work.
Data Collection on CMEs
States should consider measuring model fidelity (how well the CME delivers services according to the National Wraparound Initiative model), youth and family outcomes, and service costs (Table 2).
Table 2: CME Quality Monitoring and Evaluation – Example Measures, Methods, and Tools used by CHIPRA Quality Demonstration States
Area to track
Table 2, States may collect and analyze data from CME records, surveys and focus groups with youth and their families, and multiple administrative systems.
- CME Records. CMEs submit process data to the State. States can require CMEs to use an electronic system to collect and submit this information or allow the CME to manually report. Electronic reporting can be more accurate and timely than manual reporting, but implementing an electronic system can be time consuming and costly for the CME. In either case, the State will need to work closely with the CME to review data submissions, identify data gaps or inaccuracies, and work to improve data entry and transmissions.
Example measures | Example data collection methods | Example tools | |
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Model fidelity |
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Youth and family outcomes |
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Costs |
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Source: Interviews with staff in CHIPRA quality demonstration States.
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CHIPRA Quality Demonstration State Experiences: CME Record Data Maryland is working to adapt and implement WrapTMS, an electronic system to track care coordination services and authorize services coordinated by the CME. |
- Youth and Families. Youth and families are the only source of data for several important quality metrics. To minimize the cost and potential burden of data collection, States may:
- Carefully consider how often the State collects data from families and youth, weighing the need for ongoing followup data against the burden and expense of collecting it.
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Provide incentives to youth and their families for participating in surveys and focus groups.
Make reauthorization of services dependent on completion of critical surveys (for example, youth functioning assessments).
- Administrative systems. Refer to Part 3 of this guide for strategies for improving administrative data systems.
Additional Resource on Measuring Outcomes and Improving Quality |
Using Data to Drive Quality Improvement
CMEs and the organizations managing and overseeing their services can use data to improve quality and operational efficiency. The organization overseeing CME quality should work collaboratively with the CMEs in the State to identify what measures and strategies are most useful for improving quality. Using a collaborative strategy to drive improvement may encourage CMEs to participate actively in the process and make positive changes. The State can consider several strategies to drive quality improvement including:
- Providing feedback reports to CMEs that cover model fidelity, youth and family outcomes, and costs. The feedback reports can track outcomes over time and benchmark CMEs against national wraparound standards or, if relevant, other CMEs in the State. A State should aim to provide timely feedback at regular intervals so it and the CME can quickly identify opportunities for improvement and assess the effectiveness of quality improvement strategies.
- Holding regular, frequent quality improvement meetings with CME leadership. During these meetings, the State and the CME can discuss challenging cases, policy developments, data issues, and training needs.
- Providing incentive payments to CMEs that demonstrate improvement on quality metrics. (States may also consider punitive action if CMEs consistently perform poorly.)
- Holding refresher courses or developing new training modules to address identified quality difficulties.
- Hosting learning collaborative sessions or other forums to encourage CMEs to learn from each other, if more than one CME exists in the State.
CHIPRA Quality Demonstration State Experiences: State Experiences: Quality Improvement Georgia used CHIPRA quality demonstration funds to develop a new CME quality improvement process that involves regular quality feedback to CMEs and quality council meetings between the CME, State agencies, and staff at Georgia State University who monitor CME quality. |
Using Data to Evaluate Impact
States can also use data to demonstrate CME impacts. One way to approach and help focus evaluation planning is to identify the information needs and expectations of the key stakeholders in the State, such as policymakers and agency leadership who decide if CMEs should be continued or expanded. To that end, a State could use the stakeholder engagement strategies (described in Part 3) to help determine what program evaluation questions stakeholders have and how they might use or act on any answers they receive.
States can compare actual performance with past or projected performance. If stakeholders need to be able to make inferences about cause and effect with a high degree of confidence, the State might also consider using an experimental or quasi-experimental design. This requires a comparison group to estimate the difference between the outcomes for youths referred to CME services and the outcomes for youth referred to alternative services. Specifically, the evaluator might seek data on the population of youth served by CMEs and compare their experiences, utilization, and costs to a similar population of youth not served by a CME. If a State is implementing a CME for the first time, it may consider piloting the program. Evaluating the impacts of the program on youth in a specific geographical area (for example, city, county, or region) or limited population will allow the State to test the CME approach and refine it before going statewide.
CHIPRA Quality Demonstration State Experiences: Piloting CMEs In the first year of implementation, Wyoming piloted their CME in a seven county region. It plans to refine and then expand the model statewide. |
Who Monitors Quality and Conducts the Evaluation
States can develop and implement the quality monitoring and evaluation processes or contract with an external organization, such as a family advocacy organization or university, for some or all of these services.
- If a State has access to both data and analytic expertise, it may want to consider using State resources. These resources can be located in agencies funding or managing the CME or in other agencies. State staff may have a more complete understanding of CME implementation and may be able to provide more timely feedback that reflects State priorities.
- Alternatively, using an outside organization can augment analytic capacity and provide additional credibility for some stakeholders. Since external evaluators are not involved with CME implementation or invested in its success, external audiences may be more likely to trust their findings. Moreover, external evaluators may feel more comfortable sharing and discussing findings with the project team that show no impact or unintended negative consequences of the CME.
CHIPRA Quality Demonstration State Experiences: Evaluation
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