This message is from Ellen Pinnes and The Disability Coalition. You can contact Ellen at EPinnes@msn.com.
The Human Services Department has released a revised version of its draft application for renewal of the federal waiver authorizing the Centennial Care program. The changes proposed in the application would go into effect on January 1, 2019. If you’d like to review the full application, you can find it and other information relating to the waiver renewal on the HSD website, www.hsd.state.nm.us/centennial-care-2-0.aspx.
The department will hold four public meetings (plus a tribal consultation) this month to take public input on the proposed changes. One of the meetings will include an opportunity for people who can’t attend in person to make comments by phone. HSD also is accepting written comments. Dates and locations for the meetings and details on how to submit other comments are given at the end of this message. Comments are due by November 6.
The draft application mostly follows the proposals outlined in the Concept Paper that HSD released earlier this year, but a few changes have been made.
Issues of Concern
* Monthly premiums for some people with incomes above the federal poverty level (FPL), which this year is $12,060 for an individual and $24,600 for a household of four. Medicaid doesn’t currently charge premiums (monthly charges for insurance coverage). The charges would range from $10 to $25 a month in 2019, increasing to $20 to $50 a month in later years. The department also proposes to charge a flat rate of double the individual rate for households of more than one person, regardless of the number of people in the household, so those charges would range from $20 to $50 a month in 2019, and $40 to $100 a month in later years.
Not paying the required premium would result in loss of Medicaid coverage after a 90-day grace period that would be given to catch up on the payments. A person who loses coverage would be “locked out” and not permitted to re-enroll in Medicaid for three months.
Experience in other states has shown that even small premiums cause many people to drop off or not to enroll in Medicaid because they can’t afford to pay. Although HSD says premiums would promote personal responsibility and reduce program costs by shifting those cost to recipients, savings to the state will come primarily from people losing coverage because they can’t afford the premium.
* Co-pays when services are received. Earlier this year, HSD had proposed to add co-pays for many Medicaid recipients, but it dropped those plans and now intends to begin charging co-pays when the waiver renewal begins in 2019. Co-pays are problematic because they discourage people from getting the services they need. And HSD’s proposal to change to annual calculation of the cap on the amount of co-pays someone has to pay (no more than 5% of income) means that someone who uses services frequently – as many people with disabilities must do – might have to pay a very high percentage of their income in the first few months of the year before the cap on these charges kicks in.
* Fees for missed appointments. The department proposes to let providers charge a fee when a recipient misses three or more appointments, but gives few details on how this would work – apparently those decisions will be left to the managed care organizations. It appears that even when there’s a good reason the appointment was missed (like the van not picking a person up as scheduled), it could be counted and could subject the person to a penalty. It’s not clear what the consequences of not paying the fee would be.
* Changes to covered benefits. HSD proposes to reduce or even eliminate some Medicaid benefits. Habilitation services for adults are specifically mentioned as a service to be eliminated. The department also proposes to drop EPSDT coverage for 19- and 20-year-olds, other than those considered “medically frail”. And it may in the future end the limited current coverage for dental and vision services for adults and instead make this coverage available to purchase for an added premium.
HSD also proposes to limit the allowable amounts for some services in the self-directed community benefit (SDCB) – related goods and services would be capped at $2,000/year, non-medical transportation at $1000, and specialized therapies such as acupuncture, chiropractic, hippotherapy and massage therapy at $2,000.
* Eliminate retroactive eligibility that covers medical bills for health care services received in the three months before a person applies for Medicaid. It’s a long-standing rule of Medicaid that the program pays for services in the three months before applying for Medicaid – eliminating this will leaave individuals with medical debt and providers with unpaid bills.
Positive elements of the proposal
* Streamlined renewal of eligibility for “nursing facility level of care” (NFLOC) in some cases. NFLOC is the standard used to determine eligibility for home- and community-based services as well as facility care. We’ve argued to HSD for years that full annual reassessments of NFLOC for persons whose condition won’t change or improve is personally burdensome for the individual and an unnecessary administrative burden for the state. We’re pleased that the department has finally come to see that this change in procedure makes sense.
* Increased focus on social factors that affect health, such as housing, nutrition, etc. There’s little detail on how this would actually work but HSD’s recognition of the importance of addressing these issues is welcome.
* Promoting use of peer support and community health workers.
* Increasing the number of hours of respite for caregivers, from 100 hours a year to 300 hours. HSD had previously proposed this increase for people caring for kids with special needs, but now proposes to allow it for all who are receiving long-term services and supports through the Community Benefit.
* Providing a one-time allowance of up to $2,000 for start-up goods when a person moves to the self-directed community benefit (SDCB) from the agency-based model (ABCB), to cover things like a computer and printer that are needed to self-direct successfully.
* Improving care for justice-involved individuals by starting care coordination 30 days before the person is released from jail or prison, to ensure a smooth transition to care upon release. Many of these individuals have mental health or other chronic conditions and making sure they have prompt access to services upon release is important.
* Streamlining income eligibility determinations by using information already available to the state rather than putting the full burden on the individual to prove their income. This also will reduce administrative burdens for the state.
Opportunities for Public Input
Las Cruces – Thursday, October 12, 2017
Farm and Ranch Museum
4100 Dripping Spring Road
1:30 to 3:30 pm
Santa Fe – Monday, October 16, 2017 (as part of the Medicaid Advisory Committee meeting)
New Mexico State Library
1209 Camino Carlos Rey
1:00 to 4:00 pm
Las Vegas – Wednesday, October 18, 2017
Highlands University – Student Union Building/Student Center
800 National Avenue
1:30 to 3:30 pm
A toll-free phone line will be available for this event, for call-in participants to listen to the meeting and to provide comments by phone if they wish:
1-888-850-4523; participant code 323 675#
Albuquerque – Monday, October 30, 2017
National Hispanic Cultural Center – Bank of America Theater
1701 4th Street SW
5:30 to 7:30 pm
Also, a Tribal Consultation will be held at 9:00 am on Friday, October 20, at the Institute of American Indian Arts, 83 Avan Nu Po Rd in Santa Fe.
Submitting written comments to HSD
* By email to: HSD-PublicComment@state.nm.us
* Through the department’s website: Go to the Centennial Care 2.0 section of the HSD website at http://www.hsd.state.nm.us/centennial-care-2-0.aspx and scroll down to the bottom of the page, where you’ll find a form to fill out. You can also attach documents.
* By mail to:
Human Services Department
ATTN: HSD Public Comments
P.O. Box 2348
Santa Fe, NM 87504-2348
The deadline to submit comments is 5:00 pm on Friday, November 6, 2017.
Thanks for making the voice of the disability community heard!