| Advisory Opinion regarding post-employment restrictions applied to a Program Manager of OBH seeking employment as a Crisis Liaison for the Louisiana Crisis Response System. |
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Annette Arthur is currently a Program Manager 2 with the Office of
Behavioral Health ("OBH"), Louisiana Department of Health. Ms. Arthur is contemplating
retiring soon and applying for a position with one of the Managed Care
Organizations ("MCOs") contracted with Medicaid. She is considering a position as
a Crisis Response Liaison with an MCO.
In addition to the crisis intervention service offered
within the Mental Health Rehabilitation (MHR) array of services, a new set of
voluntary crisis services were developed via the implementation of the
Louisiana Crisis Response System ("LA-CRS"). These services are available for
Medicaid adults age 21 and older, and are provided to form a continuum of care
offering relief, resolution and intervention through crisis supports and
services to decrease the unnecessary use of emergency departments and inpatient
hospitalizations for members whose needs are better met in the community. These
services are comprised of Mobile Crisis Response (MCR), Behavioral Health
Crisis Care (BHCC), Community Brief Crisis Support (CBCS), and Crisis
Stabilization (CS).
MCOs shall have a fully operational network of behavioral
health crisis response providers offering a complete array of crisis services.
Crisis services shall include an on-call, 24-hour crisis hotline to provide crisis
counseling, crisis intervention and follow up, linkage to ongoing behavioral
health management and intervention. The MCO may also coordinate with community
resources to expand the crisis response.
As a Crisis Response Liaison with an MCO, Mr. Arthur's duties will
include:
1. Support day to day operations as a subject matter expert
for the MCO Behavioral Health Market Team;
2. Assess and interpret customer needs and requirements;
3. Manage escalated concerns/cases to resolution;
4. Coordinate with community resources, including, but not
limited to, law enforcement, emergency departments, statewide and regional
crisis coalitions, dispatch call centers, and emergency management service
organizations to expand the crisis response; and
5. Assist in Crisis
Services Reporting to the MCO and the Health Plan Management section of
OBH.
Ms. Arthur has never worked in the Health Plan Management Section of OBH. She has only worked in the Behavioral Health/Community Programming section. The Health Plan Management section works with Medicaid on projects like the development of the Crisis Response System with the MCOs.
Ms. Athur has never had any job duties related to the LA-CRS or
staff within OBH that have been associated with the development of the LA-CRS companion
guide which directs the MCOs on how to set up the LA-CRS. She has never worked
in the My Choice Louisiana program operated through OBH that is mentioned in
the LA-CRS companion guide.
Ms. Arthur's current duties include supervising the person over
homeless programs, and to supervise and assist with the writing and management of
contracts associated with treating individuals who experience their first
episode of psychosis in outpatient clinics in the community. The programs with
which she was involved are not associated with the MCOs Crisis Response system.
Ms. Arthur asks if it would be a violation to accept a position as a Crisis Response Liaison.
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The MCO Crisis Response system companion guide is attached to this agenda item.
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La. R.S. 42:1121B(1) provides that no former public employee shall,
for a period of two years following the termination of his public employment,
assist another person, for compensation, in a transaction, or in an appearance
in connection with a transaction in which such former public employee
participated at any time during his public employment and involving the
governmental entity by which he was formerly employed, or for a period of two
years following termination of his public employment, render, any service which
such former public employee had rendered to the agency during the term of his
public employment on a contractual basis, regardless of the parties to the
contract, to, for, or on behalf of the agency with which he was formerly
employed
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Adopt the proposed advisory opinion.
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| Assigned Attorney: |
Mallory Guillot |
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