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Moore submits testimony on the Division of Health Care Finance and Policy's proposed regulations for health safety net eligible
services
August 22, 2007...Today, Sen. Richard T. Moore, chairman of the Joint Committee on Health Care Financing and one of the architects of the state's new health care reform law, submitted written testimony to Division of Health Care Finance and Policy Commissioner Sarah Iselin on her agencies proposed regulations for "eligible services" under the state's new health safety net, formerly the Uncompensated Care Pool (UCP). "While the goal of the reform of the safety net is to incentivize people to acquire coverage rather than continue to use the UCP, what must be avoided is placing more of a burden on the hospitals and inadvertently discouraging patients from seeking medical care," Moore said.. His testimony outlined several items from the newly drafted regulations that were of concern to Uxbridge lawmaker. "I urge the Division to reconsider [these issues] when finalizing these regulations," Moore said. The text of Sen. Moore's testimony is below: August 22, 2007 Commissioner Sarah Iselin Dear Commissioner Iselin, I am writing to express my deep concern with several aspects of the Division's proposed regulations for health safety net eligible services set forth in 114.6 CMR 13.00. While the goal of the reform of the safety net is to incentivize people to acquire coverage rather than continue to use the UCP, what must be avoided is placing more of a burden on the hospitals and inadvertently discouraging patients from seeking medical care. I have outlined several items from the newly drafted regulations below that I urge the Division to reconsider when finalizing these regulations. No safety net eligibility for unenrolled Commonwealth Care and MassHealth eligible patients. During this transitional phase of trying to provide all Massachusetts residents with health insurance coverage, it is important to remember that the Safety Net needs to remain an uncompensated care reimbursement system for those who cannot pay for coverage for themselves. Unfortunately, many unforeseen expenses can arise which make it impossible for low income patients to make timely payments. Many of these patients have no discretionary income which makes monthly payments much more difficult when emergency expenses arise. People who have actively pursued enrollment and coverage through these programs should not be penalized because of failure to make timely payments. Furthermore, we must be careful not to shift this burden to the hospitals. Deductibles for those earning between 100% to 150% FPL. While creating a standard measure of uniformity across the Commonwealth Care program and the Safety Net is a laudable goal in theory, in practice the effect may be to deter patients from seeking medical care. While the cost of $35 for a hospital visit is not unreasonable, the inequity in what $35 covers for a hospital patient versus a Commonwealth care enrollee is vast. Commonwealth Care enrollees who pay the $35 deductible have access to regular check-ups, treatment when sick or injured, prescriptions, vision care, and mental health or substance abuse treatment, while uninsured hospital patients will be required to pay $35 for their first visit and $35 each month in between their first and second visit and only receive hospital care. Additionally, the accumulated deductible (although capped at $420) may discourage patients from seeking care. No co-pay or deductible required for patients who visit CHCs unless they operate under a hospital license. There should be no differential treatment among hospital licensed community health centers and independent community health centers. There are about eighteen hospital licensed community health centers and most of them are in Boston. One happens to be in my hometown of Uxbridge. We need to encourage the use of CHCs and HLCHCs as much as possible, not deter their use. Furthermore, this promises to be very confusing to consumers as they cannot easily distinguish between CHCs and HLCHCs. Please remember that the implementation of the Massachusetts Health Care Reform Law (C.58 of the Acts of 2006) is still in its early phase. There have been many significant changes implemented, and we are continuing to review the implementation process which could require us to make additional changes in policies and procedures in order to ensure a smooth transition. The shift from the Uncompensated Care Pool to Safety Net Care may result in some confusion despite our best efforts to inform patients and providers. We need to continue to keep our focus on the protection of patients while maintaining the financial stability of the hospitals. One of the primary objectives of health reform was to reduce the cost shifting that has occurred in the past, and I am concerned that an unintended consequence of some aspects of the proposed regulations that I have mentioned, will create new cost shifting to patients and/or hospitals. I urge you to take into account these concerns as the final version of the regulations are promulgated. Sincerely, |
