Props to the 79 organizations who prepared an excellent letter to Secretary Sebelius in response to the request for comments on Proposed Rule “Medicaid, Children's Health Insurance Programs, and Exchanges: Essential Health Benefits in Alternative Benefit Plans, Eligibility Notices, Fair Hearing and Appeal Processes for Medicaid and Exchange Eligibility Appeals and Other Provisions Related to Eligibility and Enrollment for Exchanges, Medicaid and CHIP, and Medicaid Premiums and Cost Sharing”
In a nutshell, the proposed rule could potentially saddle Medicaid beneficiaries with higher co-pays and fees. The rule gives states the choice in what Medicaid benefits to cover, so long as the packages include coverage in the 10 Essential Health Benefit categories outlined in the health law. "
Of particular note to the Children's Mental Health Network in the letter to Secretary Sebelius was the section on "Definition of Medically Frail." From the letter:
- Definition of Medically Frail
We are very supportive of the proposal in Section 440.315(f) to revise the definition of “medically frail” to specifically include “individuals with disabling mental disorders (to include children with serious emotional disturbances and adults with serious mental illness), individuals with serious and complex medical conditions, individuals with a physical, intellectual or developmental disability that significantly impairs their ability to perform one or more activities of daily living, or individuals with a disability determination, based on Social Security criteria, or in states that apply more restrictive criteria than the Supplemental Security Income (SSI) program, as the state plan criteria.”
This should help ensure that all people with disabilities are included in the medically frail definition and therefore eligible for enrollment in the state’s traditional Medicaid program through the exemption process. We also support that individuals with a substance use disorder also be added to the definition of “medically frail.”
We seek clarification and further guidance on the enrollment and selection process for “medically frail” beneficiaries. It will be critical for those who qualify to be able to select the benefit plan that best meets their health care needs. Depending on the circumstance this could be either the traditional Medicaid package or the Alternative Benefit Plan but will depend on individual need and state benefit designs. We want to ensure that “medically frail” beneficiaries will not be forced into a plan that provides fewer benefits be that the ABP or the traditional Medicaid package.
Remember, states have choice in what Medicaid benefits to cover, so long as the packages include coverage in the 10 Essential Health Benefit categories outlined in the health law. Frankly, it is up to us to make sure that decision-makers are aware of the choices that work best for youth with serious emotional challenges and their families.
Read the letter here. A "must read" for Network faithful.