Kentucky HEALTH 1115 Medicaid Waiver

I have officially sent in my comments to the Federal Government, on Bloodshed Bevin's Kentucky HEALTH medicaid waiver. The comment period is open until October 8, 2016 @5pm. Please go to this link to enter your comments against the waiver. I'll post my comments here, please feel free to use them as a guide for your own. Let's nip this waiver in the bud, y'all!

Kentuckians Against Matt Bevin stands firmly in opposition of this waiver. Matt Bevin ran for Governor on a platform which included the repeal of Medicaid expansion in Kentucky. Since roughly 72% of Kentuckians prefer to keep the expansion as is, he can't repeal it outright. Instead, he's purposely submitted a plan which is likely to be rejected so that he can repeal the expansion, then blame it on the Obama administration. Bevin has already laid the groundwork by insisting that it's now in CMS's hands, and saying that there will be no expansion in KY if his plan is rejected. On the off chance his plan is approved, it'll still be a win, because it's a plan that appeals to his far right base, while simultaneously eliminating or reducing access for tens of thousands of Medicaid recipients. First and foremost, this waiver is designed to help Matt Bevin further his political career and secure a future presidential bid. Medicaid is supposed to help low-income Americans access much needed healthcare, not help an ideological zealot further his political career.

KY Medicaid expansion created more than 12,000 jobs in 2014, and is estimated to create more than 40,000 by 2021, each with an average salary of about $41,000. KY hospitals saved $1.15 billion in uncompensated care costs in the first 3/4 of 2014 alone. According to my research, the move to MCOs has saved the Commonwealth $1.3 billion, and is estimated to have a positive cumulative fiscal impact $819.6 million by 2021. Along with all the previously mentioned financial benefits, states have realized further savings by transitioning pre-ACA medicaid eligible individuals (of which the state pays 30% of costs) to new expansion eligibility categories (of which the state currently pays 0 costs, and will transition to paying a maximum of 10% of costs.) Bevin claims that the expansion is financially unsustainable, however, according to the available data, that's simply untrue.

Another Claim Bevin has made, is that health outcomes for the expansion population have not changed. That claim is also untrue. Under expanded Medicaid, there've been significant reductions in skipping meds due to cost, a 40% reduction in unmet medical need due to cost, an increase in low-income adults visiting healthcare providers for diagnosis and treatment, as well as a larger share of individuals with a PCP than those in non-expansion states. The KY expansion population utilize common preventive care services , such as medication monitoring and cholesterol screenings, at much higher rates than traditional Medicaid recipients. We have a large increase in chronically ill individuals receiving regular care, a significant increase in outpatient utilization & preventive care, reductions in ED use, and improvements in healthcare quality & self reported health. Obviously, Medicaid expansion has had a positive impact on the health outcomes of Expansion eligible individuals. As one of the most chronically ill and poorest populations, before Expanded Medicaid, we cannot afford to go backwards. If Bevin's Expansion waiver is approved, that's exactly where we'll go.

According to the waiver application, Kentucky HEALTH would result in 17,000 recipients losing coverage in year 1, and nearly 86k by year 5. However, it would likely cause many more to lose coverage, and cause a huge reduction in utilization and quality of care for the remaining expansion population. An expansion family of four makes up to $33,465/year, while an expansion individual makes up to $16,242/year. Premiums of $1 - 37.50/month may sound inconsequential to the Governor, however it's a pretty penny for those of us living in poverty. These premiums will force vulnerable people to have to choose between putting food on the table, or paying for healthcare. Given the choice, healthcare always takes a backseat to feeding yourself or your family. When recipients fail to pay premiums, they'll be locked out of their plan for 6-months. How does cutting off access to care improve health outcomes? Hint: it doesn't. Uninsured adults are more likely to die prematurely than are insured adults. Cutting off access to healthcare puts lives in danger, and not just their own, but their children's as well. Research shows that when parents lose their healthcare their children lose access too, regardless of enrollment status. These premiums, and subsequent lock-out periods, present a real danger to the health, well-being, and lives of everyday Kentuckians whose only crime is being poor. It's a dangerous precedent to set for something that's supposedly a safety net. If one ultimately decides the premiums are acceptable, we must then question who collects them. Do providers collect them? MCOs? The state? How do we fund the administrative costs to collect them? How do recipients pay them? Will they need access to a bank account or the internet? Many people in poverty don't have access to bank accounts, or a reliable source of internet. How will they make premium collection accessible enough to prevent interference with recipients access to care? This administration still hasn't ensured Benefind is working properly, I have serious qualms about their ability to implement a working premium collection system. Sounds like a lot of red-tape and extra cost, for essentially very little benefit, other than forcing Medicaid recipients off of Medicaid.

Next, they seek to force recipients to volunteer or work for 20hrs/week. Most of the expansion population already works, they just lack a living wage or decent benefits. That could be fixed by increasing minimum wage, however Bevin has resisted and repealed every such measure in our state. It's almost as if he doesn't actually care about workers, so much as he cares about corporate profit. There has been concern expressed by KY non-profits that they don't have the money or resources to waste on training people who're only volunteering to access healthcare. I live in SE KY, where we don't have an abundance of jobs or volunteer opportunities; we essentially live in a jobs desert. How are the Medicaid recipients in SE KY, and other similarly poor & vulnerable areas, supposed to participate in a jobs program without jobs available? Not to mention the great distances we must travel to get anywhere; twenty minutes to a grocery store, sixty to a decent one. Many people in poverty, especially those in my area, lack reliable transportation. You cannot work 20hr/week without a means to get there, which brings me to my next issue, the elimination of NEMT. In my county, NEMT is Daniel Boone Transit. In addition to getting people to doctor appointments, you can pay a fee to get you other places, such as the aforementioned grocery store. For many people in Rural parts of the state, NEMT is the only form of reliable transportation available to them. How do you get to the doctor, pharmacy, or dentist if you don't have transportation available to do so? This provision will be devastating to the health and well-being of many in my area, and other rural parts of the state, where public transit is not available.

One of the most widely discussed provisions of this waiver, is the making dental & vision into a "reward." Dental & vision are important to your overall health and well-being. Diabetes, heart disease, and glaucoma are just a few of the diseases that are often diagnosed and monitored by dentists and ophthalmologists. Healthy teeth and good glasses can not only improve your overall health and quality of life, but they can also be the difference between a low and high paying job. To purport that these benefits, health & otherwise, should be a "reward" is just absurd! Matt Bevin should be ashamed for hawking this scheme. Most reward programs sit unused, because they're too complicated and because most people are unaware of them, or how to utilize them. This "reward" program is complicated in structure, with minimum benefits & maximum penalties. Many of the rewards require access to the internet, something that's not as easy to come by in rural areas, where internet is unreliable and cell phone service is almost non-existent. The penalties for non-emergency usage of the ED are stiff, starting at $25 and quickly increasing to $75, for something that's ultimately decided on the whim of whoever is working triage at the ER that day. The costs of basic dental & vision far outweigh what can be earned through the "reward" program. Factor in lockouts from your "rewards" due to failure to pay premiums, and the program is essentially worthless. Lastly, I'd like to address the condescending manner with which Matt Bevin refers to this "reward" program, saying it's "a mix of carrots and sticks." The fact that he would speak about his constituents in such a derogatory manner, as though we're nothing but animals, should give you all the insight into this so-called rewards program, nay this entire waiver, that you need.

In addition to the "rewards" account, this plan is further complicated by the addition of a $1000, fully funded, deductible account. You must use the deductible account to get a better understanding of commercial insurance. How that extra red tape is supposed to reduce poverty is beyond me. It's just another one of those provisions added to "educate" the ignorant Medicaid recipients. Speaking of complicated, they've eliminated retroactive coverage, and given you a specific date at the end of the year by which you must re-enroll or you'll be locked out of your coverage. They really love those lock-out periods! After you're locked out, you must re-enroll within 3-months, or you'll be forces to wait another 6-months to re-enroll, or take a health or financial literacy course. That will particularly complicated for those Medicaid recipients who happen to be illiterate, dyslexic, or suffering from other learning impairments!

For those Medicaid recipients who're employed at a place that offers sub-par employer-sponsored health insurance plans, they will be forced to sign up for their employer-sponsored plans. The waiver claims that the state will send the recipients monies to cover their employer-sponsored insurance, minus the aforementioned Medicaid premium payments, which they can then use pay use to pay themselves back for their premium payments made to their employer-sponsored plans. If anything isn't covered under their employer plan, that is under Kentucky HEALTH, Medicaid will cover the uncovered service. If this sounds really complicated and unnecessarily cumbersome, that's because it is! There's no evidence to show how or if this would work, and I'm banking on it wouldn't. This is designed to push recipients off of Medicaid, plain and simple!

Kentucky HEALTH is a misnomer, more like Kentucky unHEALTH. Everything about this plan is designed to reduce access, eliminate access, and create red-tape and hoops. The point of Medicaid is to help low-income individuals become healthy enough to work, get a higher paying job, and eventually transition off this invaluable safety-net service. Kentucky HEALTH puts so many barriers in place that it will keep people sick, and in poverty. This plan is bad for KY, bad for health, and bad for poverty. If you care about our health and well-being, you'll just say no to Kentucky HEALTH. Thank you.