ACT!! Coalition Member Organizations AARP Massachusetts Action for Boston Community Development AIDS Action Committee American Cancer Society Cancer Action Network American Heart Association / American Stroke Association Association for Behavioral Healthcare Boston Center for Independent Living Boston Children’s Hospital Boston Medical Center Boston Public Health Commission Cambridge Health Alliance Children’s Health Access Coalition Coalition for Social Justice Committee of Interns and Residents/SEIU Healthcare Community Catalyst Community Servings Disability Policy Consortium Episcopal City Mission Families USA Greater Boston Interfaith Organization Greater Boston Legal Services Health Care For All Healthcare for Artists Health Law Advocates Home Care Alliance of Massachusetts Joint Committee for Children’s Health Care in Everett JRI Health Massachusetts Academy of Family Physicians Massachusetts Association of Community Health Workers Massachusetts Association of Behavioral Health Systems Massachusetts Breast Cancer Coalition Massachusetts Building Trades Council Massachusetts Business Leaders for Quality, Affordable Health Care Massachusetts Chapter of the American Academy of Pediatrics Massachusetts College of Emergency Physicians Massachusetts Communities Action Network Massachusetts Council of Community Hospitals Massachusetts Immigrant and Refugee Advocacy (MIRA) Coalition Massachusetts Health Council Massachusetts Hospital Association Massachusetts Law Reform Institute Massachusetts League of Community Health Centers Massachusetts Medical Society Massachusetts Organization for Addiction Recovery Massachusetts NOW Massachusetts Public Health Association NARAL Pro-Choice Massachusetts National Association of Social Workers – Massachusetts Chapter Neighbor to Neighbor Partners HealthCare Public Policy Institute 32BJ SEIU New England 615 1199 SEIU United Healthcare Workers East Tobacco Free Mass Treatment Access Expansion Project UMass Memorial Health Care 5
178 Tremont Street, Boston MA 02111 I bostonabcd.org I P: (617) 348-6000 I TTY: (617) 423-9215 I F: (617) 357-6041 John P.lJ: \.lhlin Chair; Yvonne Jones, First Vice Chair; Sean Daughtry, Vice Chair; Marie Greig, Vice Chair; Edward Katz, Vice Chair; Andres Molina, Vice Chair; Jean M. Babcock, Treasurer; Patricia Washington, Assistant Treasurer; Julia Hardy Cofield, Esq., Clerk; John J. Drew, PresidenVCEO
July 15, 2016 Dear Assistant Secretary Tsai: Thank you for offering a comment period on the draft 1115 Waiver Proposal to CMS. The work that you, your colleagues and the entire Governor Baker administration has taken with regards to this work is creative, smart, innovative and incredibly focused on the needs of the state's most vulnerable populations. We applaud you for these efforts and we very much look forward to partnering with you to bring this progressive vision to a successful reality. The table below contains our feedback. Please do not hesitate to reach out for any clarity you need on any of the below. Best Regards, Christina Severin President & CEO Section Number Page number (of 92 pages) Waiver Content CCC's feedback Executive Summary 5 An MCO must demonstrate competencies and readiness in these areas before it takes on accountability for LTSS This option should also become available for high-performing B ACOs. Section 3 21 Additionally, MassHealth will establish an advocate and member advisory group to ensure that members will have an appropriate forum to provide input to support design, implementation planning and roll-out. Can the consumer representative on our board participate in this group for board education and development purposes? 4.1.2 25 All eligible members will enroll in a managed care option and select a primary care provider, as they do today. All eligible members will have the right and opportunity to select their health plan and PCP. We believe this should read, “All eligible members will have the right and opportunity to select their health plan and/or PCP”, since picking a Model B ACO is picking his/her PCP, but not a “heath plan”. 4.1.4.1 26 These tools may include options to take on more advanced We strongly desire for withholds to be available to 10 Gove St, East Boston, MA 02128 617-852-4709
payment models, including of prospective payment in which providers may elect to have some of their fee schedule payments reduced or withheld, and instead paid directly to the ACO. consenting providers upon go- live. This is critical to align incentives and make internal financial architecture work correctly. 4.1.4.2 27 If an ACO designates a referral circle, that MassHealth approves the enrolled member will not need a primary care referral for any services rendered by a provider in that ACO’s referral circle, making it easier for members to receive coordinated care. We do not believe that taking off all referral requirements is a good tool to promote care coordination. Although this might have theoretical merit, in reality, it promotes unnecessary utilization, regardless of the preferred circle. Our PCPs are not in favor of referral circles. Preferred specialists should also be concerned that removing a referral requirement will allow unnecessary care to get to them. You should keep referrals in place for all non- ACO provided services. However, we are very supportive of adding more meaningful administrative requirements for non-preferred providers (eg; authorization or ACO generated referrals with unique numerical sequencing), and we encourage you to seek approval to do so in this Waiver Request. 4.1.4.3 27 Model B ACOs must have a repayment mechanism – a line of credit, restricted capital reserve, or performance bond – to ensure they can bear the financial responsibilities of the ACO risk model. MassHealth must be able to implement withholds upon go- live as this can be an internal strategy to create a reserve fund for funding a portion of repayment obligations (ie: an ACO PCP claims withhold). We would like to be able to select the amount from 1% up to 15%. 4.1.6 28 Accelerate the readiness work that ACOs are performing during this period We are in full and complete agreement with this statement. 10 Gove St, East Boston, MA 02128 617-852-4709
Signed, Dan O'Leary Mass Home Care & Mystic Valley Elder Services Dennis G. Heaphy, Bill Henning Disability Advocates Advancing Our Healthcare Rights (DAAHR} Barbara Mann Mass Senior Action Council Chet Jakubiak Mass. Association of Older Americans Larry Spencer Cerebral Palsy of Massachusetts, Inc. Linda Andrade Massachusetts Council for Adult Foster Care Julius Britto Attentive Home Care, Inc. Joanne Collins Woburn Councilon Aging Paul Spooner Metrowest Center for Independent Living Paul Crowley Greater Lynn Senior Services Lou Swan Elder Services of Worcester Area John O'Neill Michael E. AARP Massachusetts David P. Stevens Mass Councils on Aging Lisa Gurgone Home Care Aide Council Mike Trigilio Associated Home Care Diana DiGiorgi Old Colony Elder Services Shea Boston Commission on Affairs of the Elderly Amy Waters Worcester Commission On Elder Affairs Carolyn Lightburn Director of Everett Human Services Paul Lanzikos North Shore Elder Services Gregory Giuliano Montachusett Home Care Corporation M.O'Brien
Somerville Cambridge Elder Services Paula Shiner Coastline Elder Services John Lutz Services of Berkshire County Priscilla Chalmers WestMass ElderCare Vin Marinaro Pittsfield Council on Aging Leslie Scheer Elder Services of Cape Cod and the Islands Scott M.Trenti SeniorCare Inc Jennifer Goewey, Sheffield Senior Center & Council on Aging Nancy Munson Bristol Elder Services Rosanne Distefano Elder Services of Merrimack Valley Foluso Olubanjo Seraphic Springs Health Care Lorna Gayle Lanesborough Councilon Aging Mary Jean McDermott HESSCO David Hedison Chelmsford Housing Authority Susan Schwager North Andover Senior Center Jennifer Claro Westfield Council On Aging Roseann Robillard Newburyport Council On Aging Roseann Martoccia Franklin County Home Care Lynne Stanton Groveland Council On Aging Robert Schaeffer Multicultural Home Care Dale Mitchell Ethos Rosaleen Doherty Right at Home Boston and North Annmary Connor Amesbury Council on Donna M. Bys Professional Medical Services, Inc. Jonathan Morin Intercity Home Care Joan Butler Minuteman Senior Services Ruth Beckerman-Rodau Springwell Sharon Rochester Council on Aging Anne Sylvia
Marion Council on Aging Janice Long Hudson Council on Aging Elaine Massery Greater Springfield Senior Services, Inc. Joanne Walsh Home Staff Nancy Fillers Montachusett Opportunity Council/Nutrition Raphael Bibiu Ace Medical Services Catherine Hardaway Central Boston Services Dianna Morrison Baldwinville Council on Harriet Klayman The Highlands Adult Day Health Marge McDonald Burlington Council on Rev Robert Stetson Littleton Councilon Judy Luciano Wakefield Council on Jodi Gibeley Topsfield Council on Aging Mary Prenney North Reading Elder Services Heather Sylvia Fairhaven Council on Aging Marilyn L. Travinski Tri Valley, Inc. Sandra Lindsey South Shore Elder Services Trish Pope Marlborough Council on Aging Sandra Lamb North Adams Council on Aging Christine Alessandro Baypath Elder Services Doherty Lunenburg Council on Aging Tim Riley Action, Inc. Margaret M. Hogan Boston Senior Home Care Deborah Thompson Harvard Council on Carolyn Brennan East Longmeadow Council on Aging Nancy Levine Friends of the Littleton Council on Aging Tracy Nowicki Chelsea Council on Aging Rev. Debra Lee New Bedford Council on Aging Judith A. O'Connor
Dartmouth COA Jackie Coucci Mattapoisett Council on Aging Anne Shattuck Specialty Home Care Services June Cowen Sauvageau Northeast Independent Living Program, Inc. Mary Margaret Moore Independent Living Center of North Shore And Cape Ann Trevor R. Ruggles Independence Healthcare Corporation Karen A. Hulette MOC Energy Services Linda Ravenscroft Capital International &Home Health Services Millbury Council on Aging Ann Ruder Center for Living Y Work Amy Tobin Southeastern Mass Home Health Aides Teresa Gove Arnold Aging & Disability Resource Consortium Of the Greater North Shore Donna Sbardella Anodyne Homemaker Services Jim Kruidenier Stavros Alecia Lombard Active Home Care Pamela Woodbury Spencer Council on Aging Stephen Pitcher Julius & Sandra Britto Family Services of Central Massachusetts Attentive Home Care William Anjos Interim HealthCare Susan Pacheco Cambridge Council on Aging. Linda S. Cornell Lisa Krinksy LGBT Aging Project John Keegan Door Transportation by SCM Carol Nagle VNA of Eastern Massachusetts Fall River Family Services Visiting Nurse Assisted & Senior Living Communities Lisa Yauch-Cadden Buzzards Bay Speech Therapy Gail Fortes Helena Hughes Immigrants Assistance Center Deborah Harrington
We look forward to working with you to improve health care delivery to MassHealth recipients. ,,/ / Mental ealth Le aVAdvisors Committee 24 School Street, uite 804 / Boston, MA 617-338-2345 x129 4
we appreciate the general thrust of MassHealth’s efforts and especially endorse the role of housing stabilization and supports in your plan for better community health. Andre Green Senior Project Manager On Ground Coalition COALITION MEMBERS: Action for Boston Community Development Advocacy Network to End Family Homelessness (ANEFH) Bessie Wilson Initiative for Children B'nai B'rith Housing Casa Myrna Children’s HealthWatch Citizens for Affordable Housing in Newton Development Organization (CAN-DO) Citizens’ Housing and Planning Association Crittenton Women’s Union Family Independence Initiative Family-to-Family Project Father Bill’s & Mainspring Friends of Families in Transition HAPHousing Home Funders Homes for Families Horizons for Homeless Children Jane Doe Inc., the Massachusetts Coalition Against Sexual Assault and Domestic Violence Jewish Community Relations Council Massachusetts Association for Community Action Massachusetts Coalition for the Homeless Massachusetts Law Reform Institute Massachusetts Public Health Association Metropolitan Boston Housing Partnership One Family, Inc. Project Bread Project Hope Project Place Regional Housing Network of Massachusetts Somerville Homeless Coalition Square One Thrive In Five Initiative Tzedek Reflection Western Massachusetts Network to End Homelessness Worcester Area Mission Society RESEARCH PARTNERS: Center for Social Policy, UMass Boston Collins Center, UMass Boston Massachusetts Budget & Policy Center Green On Ground Coalition 617.201.9512
Page 5 Health Official and State Medicaid Director RRC residents not previously enrolled in their state Medicaid program would be able to apply to their intended release state of residency for eligibility determination while incarcerated, but would not be eligible to receive Medicaid benefits until their status changed to home confinement, parole, probation, or full-term release. QS. Free Choice of Provider: Must individuals in transitional or supervisory arrangements have the ability tofi"eely choose their Medicaid providers, as required in Federal law at Section 1902 (a)(23) of the Act? AS. Yes. Eligible individuals who are not inmates but rather who are in transitional or supervisory arrangements, as beneficiaries of the Medicaid program, have the same ability to choose their providers of health care services as afforded to other Medicaid beneficiaries in their states. Q6. Individuals on Home Confinement: Is FFP available if an individual is on home confinement? A6. Yes. An individual's private place of residence generally would not meet the definition of a "public institution", which is a component of the coverage exclusion, despite the involuntary nature of the home confinement scenario. FFP is available for expenditures under the approved state plan for covered Medicaid benefits furnished to eligible individuals living at home under home confinement. Q7. Voluntary and Temporary Residence in a Public Institution: Is an individual considered an inmate of a public institution if residing there voluntarily for a temporary period? A7. No. An individual is not considered an inmate when residing in a public institution voluntarily and the coverage exclusion does not apply. For example, FFP is available for services when an individual (if eligible and enrolled in Medicaid) is living voluntarily in a detention center for a temporary period of time after his case has been adjudicated and arrangements are being made for his transfer to a community residence. The voluntary nature of the residence is critical; an individual would be considered an inmate during temporary involuntary residence in a public institution imposed by the justice system (for example when confined pending trial) but not when the individual is free to leave, but is "residing in a public institution for a temporary period pending other arrangements appropriate to his needs" consistent with 42 CPR 435.1010. Q8. Residence in Facilities for Treating Mental Health and Substance Use Disorders: Is FFP available for mental health or substance use disorder services, furnished exclusively to inmates, in a residential treatment facility?