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Kaiser Permanente Statement

We have been fully engaged for more than a year in the work to improve the timeliness
of initial, non-urgent appointments and recordkeeping. Each of the findings in the 2012
DMHC survey has already been corrected, or is very far along toward resolution. For
example, the handful of outdated or incomplete brochures and other materials describing
our mental health services identified in the survey were updated or removed last year.
We have taken several additional steps, and those are described below.

We respect the regulatory process, and we appreciate that it can help create
opportunities to improve performance. However, in light of the steps we have taken over
the past year to improve timely appointments and oversight, and the significant progress
we have made, the amount of the proposed penalty is unwarranted and excessive, and
is unnecessary to ensure our corrective actions. We will review this with the DMHC.


We worked actively and constructively with the California Department of Managed

Health Care (DMHC) in its survey of mental health services in early 2012.

Importantly, the DMHC survey did not identify shortcomings with members’ ability to
receive urgent or emergency mental health care. Further, the survey did not identify
problems with the quality of mental health care that our professionals provide to our
members. In fact, the quality of the care provided by Kaiser Permanente clinicians
continues to be recognized and commended by independent organizations across the

The DMHC’s 2012 survey findings matched our own investigation, and the work to make
improvements has been underway for more than a year. As a result, since the DMHC
survey, we have improved the rigor of our oversight and improved the wait times for
these initial, non-urgent therapist appointments. With all four DMHC findings already
addressed or being corrected, we have been looking forward to a follow-up review with
the DMHC in the fall, to confirm the progress that has been made. For example:
• Since the beginning of 2012, Kaiser Permanente has hired new providers, and is
recruiting for more.
• The most recent data shows that the vast majority of the requests for initial non-
urgent appointments with therapists are booked within 10 business days.
• Access committees and local area leadership regularly review data, recommend
changes when needed, and require action plans to improve performance.
• We have put processes in place to oversee informational materials to ensure we
provide accurate, up-to-date information for our members and patients.
• In March 2011, the Department approved a method for measuring timely access
based on Average Days Wait of 10 business days or fewer for initial non-urgent,
non-physician appointments. Kaiser Permanente met that DMHC-approved
standard. During the 2012 survey, the DMHC set aside the previously approved
standard and asserted that Kaiser Permanente should use a Percentage of
Appointments Booked within Standard measure. Rather than dispute the change
from the original compliance standard, we embraced the new measurement
approach. As a result, Kaiser Permanente has enhanced the monitoring of wait
times for mental health services. We now also use a more stringent monitoring
standard – we look at the percentage of appointments that occur within the
regulatory standard.
• As we have since the inception of the timely access regulations, Kaiser
Permanente requires its contracted Permanente Medical Groups to count the
actual days between a request for each appointment and the scheduled
appointment. Our health plan oversight is based on transparent, actual wait time
data. We are not aware of the DMHC requiring similar rigor from other California
health plans.

Providing high-quality mental health care is part of Kaiser Permanente’s mission to take
care of our members’ total health. We are committed to continuous quality and
performance improvement as we work to fulfill that mission.
Kaiser Permanente will continue its ongoing performance improvement efforts, and our
talented caregivers will not be distracted by today’s DMHC announcement. We are
fortunate to have such skilled and dedicated mental health professionals working every
day to provide a wide range of high-quality care and services for our members.