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August 05, 2016 (Cleveland)

The Center Submits Comments to CMS on Healthy Ohio Program

Comment letter on the Healthy Ohio WaiverOn August 5, The Center submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the Healthy Ohio program, voicing its concerns with the proposal and the impact it would have on healthcare delivery in the state. The comments, which mirror those submitted to the Ohio Department of Medicaid (DOM) this spring, examine the stated goals of the program in comparison to the criteria outlined by CMS under the Section 1115 Demonstration Waiver guidelines. Additionally, The Center’s comments highlighted the potential consequences of the proposal, including:

  • Limiting access to healthcare.
    In order to maintain their coverage, Medicaid beneficiaries will be required to make monthly contributions to a Health Savings Account. If a beneficiary is unable to make a payment, coverage will be terminated. This creates an unnecessary barrier to healthcare coverage and will deprive hundreds of thousands of Ohioans access to the care they need.
  • Disrupting healthcare delivery.
    Caring for patients whose coverage has lapsed will limit the ability of providers to effectively manage the health of their patients. Inconsistent coverage, like that which would result from the Healthy Ohio waiver, does nothing to promote coordinated care in the right setting at the right time.
  • Increasing costs for patients, providers and the state.
    Monthly premium payments and expenses that beneficiaries would incur as a result of becoming uninsured would increase costs for patients. For providers, the elimination of the 90-day retroactive billing period under the current Medicaid program would cost hospitals millions of dollars. Lastly, the proposal would increase the cost of administering the Medicaid program, which would have to be paid for by the state.

The federal comment period, which ended on August 8, marks the final stage of public comment for the Healthy Ohio program. Since both the ODM and CMS have held mandatory 30-day public comment periods, the proposal is now under review by the Secretary of Health and Human Services. While the timeframe is always subject to change, a decision on whether or not to implement the Healthy Ohio program is expected within the next several months.

For questions about the Healthy Ohio program or The Center’s comments to the ODH, please contact Tony Gutowski, government relations manager, via email or by telephone at 216.255.3610.


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