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May 16, 2016 (Cleveland)

The Center’s Comment Letter: Healthy Ohio Waiver Contrary to Demonstration Waiver Goals



Comment letter on the Healthy Ohio WaiverToday, after extensive review and discussion with hospital members over the last month, The Center for Health Affairs formally submitted its concerns regarding the Healthy Ohio waiver in a comment letter to the Ohio Department of Medicaid (ODM). Underscoring the implications for hospitals and the patients they serve, The Center strongly urged ODM to reconsider several provisions of the Healthy Ohio waiver request that stand to undo the recent progress of the Medicaid program. 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 letter was written in response to a waiver request made by ODM on April 15, which aims to change many aspects of the state’s current Medicaid program. The proposal, which was mandated by the Ohio General Assembly during the last biennial budget process, will be submitted to the Centers for Medicare and Medicaid Services (CMS) at the end of the required 30-day comment period. Following the comment period, which ends on May 16, ODM is required to compile the input received from the public prior to sending its application to CMS. Once the request is received by CMS, there will also be a mandatory federal comment period of 30 days. Shortly thereafter, CMS will begin its decision-making process and determine whether or not it will accept all, some, or none of the Healthy Ohio waiver. The timeframe for that process can fluctuate from three months to over a year.

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