Pennsylvania is moving forward with seeking approval by the federal government for its Healthy PA plan to reform the Medicaid system and expand Medicaid eligibility in the Commonwealth. The Pennsylvania Department of Public Welfare accepted comments on the plan in its current form as a concept paper.
When he announced the Healthy PA plan in mid-September, Governor Corbett made it clear that he did not view it as Medicaid expansion, but instead, Medicaid reform. The plan proposes to consolidate the existing Medicaid benefit packages in the state into two alternative benefit plans mirroring commercial-like coverage. While the plan does call for an expansion of Medicaid eligibility for individuals up to 138% of the federal poverty level, new Medicaid beneficiaries would be enrolled in private health insurance plans offered through the Marketplace. The Pennsylvania plan contains other controversial proposals such as requiring a work-search requirement, attaching a monthly premium, and imposing a $10 co-payment for “inappropriate” emergency room usage.
Pennsylvania advocates expressed grave concern about the legality and impact the proposed plan would have on individuals:
In its comments, Community Legal Services (CLS) identifies issues with the plan’s proposal to attach a monthly premium on individuals making as little as 50% of the federal poverty level (less than $6000/year). Additionally, CLS cites guidance from CMS regarding its position on imposing barriers to eligibility including work-search requirements.
Echoing many of the concerns expressed by CLS, the Consumer Sub-Committee of the Medical Assistance Advisory Committee (MAAC), under its counsel, the PA Health Law Project, expressed concerns with the monthly premium, emergency use co-payment, and work-search requirements of the plan. The Consumer Sub-Committee and the Disability Rights Network also called for clarity regarding the process of defining “medically frail” under the proposed plan.
The PA Coalition of MCOs’ 12-page list of questions illustrates the considerable need for clarity regarding the plan’s proposals. The Coalition’s comprehensive list of questions range from inquiring about the state’s timeline to the range of benefits and options that will be available to Medicaid-eligible individuals enrolled in private health insurance plans.
The next procedural step Pennsylvania must take in order to implement an alternative Medicaid expansion plan is seeking CMS approval of a Section 1115 waiver. Once the waiver is drafted, Pennsylvania must hold public hearings and have a formal notice and comment period of at least 30 days. To date, the only state to receive approval by CMS to implement an alternative Medicaid expansion plan is Arkansas.
Links to other organizations’ submitted comments: