Advocates' Comments to EOHHS on 1115 Proposal
In July 2017 EOHHS released for public comment proposed amendments to the MassHealth 1115 demonstration. The proposals among other things would lower the income standard for parents/caretakers and other non-disabled adults, deny MassHealth to non-disabled adults with access to Student Health Insurance Plans or Employer Sponsored Insurance, restrict the scope of MassHealth secondary "wrap" coverage for non-disabled adults with Premium Assistance, move the remaining eligible parents/caretakers from Standard to CarePlus, and change pharmacy benefits to a closed formulary. Comments to EOHHS were due August 21. Attached are comments objecting to these changes from MLRI, HCFA, GBLS and DLC, HLA, CHLPA, AAC and a sign-on letter from multiple other organizations.
What's next? EOHHS will review the comments & we hope modify their proposals. To proceed with any 1115 amendment, EOHHS will next submit its formal request to CMS and CMS will provide another opportunity for public comment before acting on the state request. Many of the proposals will also require state legislation in addition to an approved 1115 amendment. In June, the Governor asked the legislature to make the necessary amendments to state law as part of the FY 18 budget, but the legislature twice declined. However, it promised to take a more careful look at ways of reducing MassHealth spending and may have its own bill in the fall.
UPDATE: EOHHS submitted its 1115 request on Sept 8. It dropped the proposal to deny MassHealth to non-disabled adults with access to Student Health Insurance Plans or Employer Sponsored Insurance, & to restrict the scope of MassHealth secondary "wrap" benefits for non-disabled adults with Premium Assistance. However, it is seeking to go forward with the remaining cuts. It also promised improvements to ConnectorCare but these promised changes are not included in the proposal it submitted to CMS. CMS has posted the request and is accepting comments until Oct 20, 2017.
MassHealth has posted the narrative portion of its Sept 8 Request & the public comments submittted in August on its Draft Request at the weblink below
The full request and information on how to file comments with CMS are posted on the federal website: medicaid.gov
|MLRI final comments 8-21-17 1115.pdf (207.51 KB)||207.51 KB|
|CHLPI 1115 Waiver Comments Final.pdf (235.01 KB)||235.01 KB|
|DLC & GBLS 1115 comments.pdf (202.32 KB)||202.32 KB|
|HCFA Comments 1115 Waiver Amendment FINAL 8-18-17.pdf (330.69 KB)||330.69 KB|
|HLA 1115 Waiver Comments FINAL 8.21.pdf (443.58 KB)||443.58 KB|
|1115 waiver amendment sign-on comments FINAL 8-18-17 (1).pdf (354.54 KB)||354.54 KB|
|1115 AAC Comments Letter.pdf (178.8 KB)||178.8 KB|