Dr. JudyAnn Bigby, Secretary
Executive Office of Health and Human Services
Commonwealth of Massachusetts
One Ashburton Place, 11th Floor
Boston, MA 02108
Dear Secretary Bigby:
On behalf of our collective memberships, the Massachusetts
Hospital Association (MHA), the Massachusetts Medical Society
(MMS), the Massachusetts Association of Behavioral Health Systems
(MABHS) and the Home Care Alliance of Massachusetts (HCA), share a
mutual concern with the commonwealth's proposed Medicare and
Medicaid dual eligible initiative. We hope you will consider this
letter a formal request for a joint meeting with you on this
important subject.
From the information that is available, we believe that the dual
eligible initiative holds promise to one day improve the healthcare
experience for these patients and produce cost savings for both the
healthcare system and government. As payments for this population
are made by two different programs, we also acknowledge that it is
currently difficult to appropriately coordinate effective and
efficient care. However, the commonwealth's January 28 proposal to
the Centers for Medicare and Medicaid Services (CMS) and its March
18 "Request for Information" (RFI) raise many important questions
that remain unanswered.
In particular, we understand that the proposed plan would
provide the state Medicaid office with management of both Medicaid
and Medicare funds with respect to the dual eligible population.
The EOHHS proposal states "MassHealth proposes that CMS provide
Massachusetts with Medicare funds for these individuals along with
the responsibility for ensuring provision of that care. CMS would
provide MassHealth with a negotiated Medicare payment per
participant…MassHealth plans to provide a global payment that
reflects the full set of covered services, as well as
administrative and care management costs."
Because of the great disparity between Medicare and Medicaid
payment levels in Massachusetts, this proposed change raises
significant concerns for hospitals, physicians, behavioral health
facilities and home health providers. Under the existing dual
eligible process, the healthcare providers we represent are
currently predominantly paid by the Medicare program for this
population. We are concerned that under this new demonstration
program, MassHealth (or its contractors) could set reimbursement
rates much lower than currently paid by Medicare. Adoption of
Medicaid payment rates for services for this population would be
unacceptable as it would exacerbate the severe Medicaid
underpayment problem for hospitals, physicians, behavioral health
facilities and home health providers.
We are also greatly concerned on the potential impact on
patients. The EOHHS proposal does not indicate whether this
initiative will be voluntary or mandatory for the approximately
115,000 dual eligible beneficiaries. Given the unique circumstances
of this population, we believe any new initiative must be designed
in a manner that incentivizes and educates patients toward
voluntary participation. And as the healthcare needs for this
population can be intensive and complex, it will be imperative to
preserve their access to and relationships with their healthcare
providers. The administration will also have to carefully delineate
which benefits - including provider access - may be forfeited under
a single program that operates differently than the current
Medicare and Medicaid programs.
We look forward to the opportunity to meet with you to discuss
these important concerns. We hope that the availability of
additional informational on the dual eligible initiative will allow
us to convey our support for this program to our federal delegation
and the administrators at CMS without reservation.
Sincerely,
Lynn Nicholas, FACHE, President & CEO
Massachusetts Hospital Association
Lynda M. Young, M.D., President
Massachusetts Medical Society
Patricia Kelleher, Executive Director
Home Care Alliance of Massachusetts
David Matteodo, Executive Director
Massachusetts Association of Behavioral Health Systems
