From Brian Rosman:
The Administration filed its first health reform implementation update with the legislature today. You can download and read it here.
The report includes a good summary of the provisions of Chapter 58, the health reform statute. The chart on pages 27-28 lists 90 separate implementation projects being tracked by the administration’s inter-agency management committee. An early task of this committee is to develop a list of “technical corrections” to the statute to submit to the legislature. The report lists a number of these proposed changes, and we understand some have already been shared with legislative leadership.
Overall, it’s clear the administration is working aggressively to implement health reform. All of the myriad of Medicaid expansions and benefit restorations are on track to be implemented on July 1. EOHHS officials are talking daily with federal CMS authorities, and the report is cautiously optimistic that CMS will approve the plan on time with only minor modifications.
Looking over the report, a few items did jump out:
Connector Board membership – the report states that the administration proposes to add the EOHHS secretary as an 11th voting member of the Connector Board. We’re doubtful the legislature will accede to adding yet another administration vote.
Pool Continuation? – the report states that CMS is concerned about the provision that continues Free Care Pool eligibility for people below 200% of poverty. The concern is that people eligible for subsidized Commonwealth Care plans will opt out of coverage and use Pool services instead. They also worry that the insurance plans’ benefit restrictions could be circumvented if the Pool wrapped around and covered medically necessary care not included in the plan, as it does now for eligible insured people. The administration will be proposing a technical amendment on this point, too.
This issue could be a flash point, as the legislature was explicit in keeping the safety net in place for the transition period. Hospitals and health centers will also weigh in on this issue, as they could be stuck with no source of payment for services provided to people who don’t sign up for coverage plans.
Rate increases for all – Chapter 58 calls for replacing the lost federal funds now going to the Medicaid health plans operated by Boston Medical Center and Cambridge Health Alliance. The report states that the Administration will also raise rates paid to the other two Medicaid managed care plans “to avoid market distortion and unfair competitive disadvantage.” As a result, rather than costing $87 million, some $111 million will go for increased Medicaid managed care payments.
Implementation push-backs – the administration proposes to delay until July 1, 2007, implementation of a number of the provisions of the bill now scheduled to take effect earlier, including the changes to the small group market (scheduled for 1/1/07), start-up for Connector-sold affordable coverage (4/1/07), young adult plans (now), and the requirement for “section 125 cafeteria plans” that facilitate pre-tax purchase of coverage (1/107). Coordinating these dates may make sense, since the pieces all go together in a package.
Regulation speed-ups – while proposing to delay some provisions, the administration is in a hurry to get regulations done before it goes out of business this December. The regulation timetable calls for completing the Uncompensated Care regulations by September 2006, even though the statute prohibits any changes until October, 2007.