New Report Looks at Medicaid and Social Determinants of Health

A new report outlines how state Medicaid programs can improve the health of Medicaid beneficiaries through a more concerted approach to addressing social determinants of health.

The report, from the Institute for Medicaid Innovation, focuses on how state Medicaid programs, through alternative payment models and especially through managed care organizations, have implemented new programs designed to address social determinants of health such as inadequate social supports and housing, food insecurity, lack of transportation, and others.  It also highlights federal regulations that facilitate the implementation of new ways to address social determinants of health and presents brief case studies in which states, state Medicaid programs, and Medicaid managed care organizations tackle social determinants of health.

Such approaches are especially relevant to private safety-net hospitals because they care for so many more Medicaid patients than the typical community hospital.

Learn more from the Institute for Medicaid Innovation report “Innovation and Opportunities to Address Social Determinants of Health in Medicaid Managed Care.”

NASH Comments on Proposed Medicaid DSH Revamp

In mid-December, Senator Marco Rubio (R-FL) introduced the State Accountability, Flexibility, and Equity (SAFE) for Hospitals Act, which seeks to restructure the federal Medicaid disproportionate share hospital payment program (Medicaid DSH).  Hospitals that care for especially large numbers of Medicaid, low-income, and uninsured patients often receive supplemental payments, called Medicaid DSH payments, from their state government to help underwrite costs associated with such patients for which they are not reimbursed.  Medicaid DSH payments are funded in part by the federal government and in part by the individual states.

As part of his introduction of his bill, Senator Rubio contacted many stakeholder groups and invited them to review and comment upon his proposal.

Among the groups contacted was the National Alliance of Safety-Net Hospitals, and last week, NASH wrote to Senator Rubio to convey its views.

Instead of addressing specific aspects of the proposal, NASH offered three principles it believes should guide any effort to modify the Medicaid DSH program.  Those principles are:

  • Delay the scheduled Medicaid DSH cuts. (Significant reductions of Medicaid DSH allotments to states, mandated by the Affordable Care Act but delayed three times by Congress, are scheduled to take effect in FY 2020.)
  • Any changes in Medicaid DSH must reflect the role Medicaid DSH plays in state Medicaid programs.
  • Any changes in Medicaid DSH must preserve states’ flexibility to use Medicaid DSH resources in the manner they believe best serves their individual Medicaid programs.

Learn more about the SAFE Hospitals Act from Senator Rubio’s news release outlining the proposal and learn about NASH’s response to his request for stakeholder input from the letter NASH sent to Senator Rubio last week.

 

Chatter About Medicaid Block Grants Grows

A week after a published report suggested that the Trump administration might be working on a plan to introduce Medicaid block grants, the Washington Post reports that those efforts are under way in earnest.

According to the Post,

A small group of people within the Centers for Medicare and Medicaid Services is working on a plan to allow states to ask permission for their federal Medicaid dollars to be provided in a single lump sum instead of the way they are currently awarded as a percentage of states’ total costs.

While many, including members of Congress, insist that the administration cannot move forward with such a proposal without legislation, others suggest that the administration may offer states the opportunity to participate in Medicaid block grants voluntarily, by seeking a federal waiver.  What remains to be seen is whether the prospect of greater flexibility to shape their own Medicaid programs is sufficient to entice states to participate in an approach that almost certainly would result in less federal money for those programs.

NASH is concerned about the prospect of Medicaid block grants and their potential impact on private safety-net hospitals and addressed this issue in its 2019 advocacy agenda, writing that

If the policy focus shifts from participants to spending, an effort could be undertaken to attempt to introduce a major Medicaid change that has been much-discussed in the past: Medicaid block grants. Block grants, whether based on individual states’ Medicaid enrollment or on their past Medicaid spending, could impose unreasonable limits on Medicaid spending that could potentially leave private safety-net hospitals unreimbursed for care they provide to legitimately eligible individuals. NASH will work to ensure that any new approach that involves Medicaid block grant continues to give states the ability to pay safety-net hospitals adequately for the essential services they provide to the low-income residents of the communities in which those hospitals are located.

Learn more about what the administration is considering and how policy-makers, industry leaders, and others are reacting to the prospect of a push toward Medicaid block grants from the Washington Post story “The Health 202: The Trump administration is working on Medicaid block grants?

Proposed Public Charge Regulation Causes Confusion in Clinics, Elsewhere

A Trump administration proposal to redefine what constitutes a “public charge” is making life challenging for low-income immigrants and the clinics and other providers to which they turn for Medicaid-covered health care.

The proposed regulation from the Department of Homeland Security would establish new criteria for determining whether a person is a “public charge,” based on their participation in certain public programs, and therefore in jeopardy of losing their legal immigration status.

Some Medicaid patients who come to clinics ask if receiving Medicaid-covered services might jeopardize their legal immigration status; others fail to keep appointments or forego seeking care out of fear of the future implications.  Clinic operators walk a fine line between trying to provide the care their patients need and deciding how to answer patients’ questions honestly but without causing undue alarm.  Some choose not to address the issue at all; others seek to answer patient questions but only when asked; while still others provide information about the situation without being asked – doing so, they realize, at the risk of scaring off some of those patients.

Meanwhile, some legal experts believe that a new standard, if adopted, would not be retroactive and consider Medicaid enrollment prior to the regulation’s adoption.

The result is confusion and concern among providers, legal immigrants enrolled in Medicaid, and advocates.

Last month NASH wrote to the Department of Homeland Security to convey its objections to the proposed legislation, expressing concern about its potential impact on private safety-net hospitals and the patients and communities they serve.

Learn more about the proposed regulation and the challenges providers face as they await a decision on whether it will be implemented in the Kaiser Health News report “Providers Walk ‘Fine Line’ Between Informing And Scaring Immigrant Patients.”

Could Medicaid Buy-In Push Aside Medicare for All?

Officials in ten states are giving consideration, in one form or another, to permitting uninsured low-income residents to buy into their Medicaid programs.

So while Washington considers the possibility of Medicare for all, the ten states – Nevada, New Mexico, California, Delaware, Oregon, Washington, Connecticut, Illinois, Minnesota, and Wisconsin – are tackling the many issues they must address if they intend to pursue such a ground-breaking option.  Among them:

  • Who would be eligible to participate?
  • What benefits would be offered?
  • Would health plans be available on Affordable Care Act health exchanges, and if so, would ACA subsidies be available to potential purchasers?
  • How would cost-sharing, such as premiums, co-pays, and deductibles, be addressed?
  • In the absence of federal matching funds, how would the states pay for their share of Medicaid benefits purchased by those not eligible for Medicaid?
  • Would such as effort be approved by the federal government?

To the extent that Medicaid buy-in would turn uninsured patients into insured patients, Medicaid buy-in would be beneficial for private safety-net hospitals.

Learn more about what the states are considering and the potential obstacles they face in the Stateline article “Medicaid ‘Buy-In’ Could Be a New Health Care Option for the Uninsured.”

 

NASH Comments Proposed Medicaid Managed Care Reg

 

The National Alliance of Safety-Net Hospitals has submitted formal comments to the Centers for Medicare & Medicaid Services in response to CMS’s proposed changes in federal Medicaid managed care regulations.

NASH’s letter addressed three aspects of the proposed regulation:  payment rate ranges, directed Medicaid payments, and Medicaid pass-through payments.  The overall theme underlying NASH’s comments was that the proposed changes represent positive steps but could be taken further to provide additional flexibility for state Medicaid programs to take stronger steps to ensure the ability of private safety-net hospitals to serve their communities.

NASH expressed support for CMS’s restoration of the use of actuarial rate ranges in setting Medicaid managed care rates but urged CMS to make those rate ranges even broader or even eliminate them provided that negotiated rates still meet formal criteria for actuarial soundness.

NASH endorsed CMS’s expanded parameters for the use of Medicaid directed payments through managed care but encouraged CMS to expand those parameters even further than it has proposed.

And NASH called on CMS to restore the ability of states to use pass-through payments in Medicaid managed care programs, as they can do through Medicaid fee-for-service programs, so long as those payments remain actuarially sound.  In 2016 a new Medicaid managed care regulation called for the phase-out of such payments over a period of ten years but NASH asked CMS to suspend that phase-out.

Learn more about NASH’s perspective by reading NASH’s comment letter to CMS in response to the proposed Medicaid managed care regulation.

End Run Around Congress for Medicaid Block Grants?

The Trump administration reportedly is considering introducing Medicaid block grants through regulations rather than legislation, according to published reports.

Those reports explain that the administration may seek to offer states an opportunity to apply to the federal government to use Medicaid block grants by obtaining section 1115 Medicaid waivers, a commonly used tool for states seeking exemptions from federal legislative or regulatory requirements.

As reported by the online publication The Hill,

…the Trump administration is now considering issuing guidance to states encouraging them to apply for caps on federal Medicaid spending in exchange for additional flexibility on how they run the program, according to people familiar with the discussions.

Proposals to implement Medicaid block grants have arisen periodically over the past decade but have never gotten beyond the discussion stage because of how difficult it would probably be to gain congressional approval for such a program.  This latest proposal would seek to circumvent that problem by making Medicaid block grants optional for states and permitting those states interested in using them to apply for a Medicaid waiver from Centers for Medicaid & Medicaid Services to do so.

It is not clear whether such an approach would be legal.

NASH has long been skeptical about Medicaid block grants, concerned that the manner in which such block grants are implemented could impose artificial limits on state Medicaid spending that could be especially harmful during economic downturns when Medicaid enrollment typically rises and the demand for Medicaid-covered services falls especially heavily on private safety-net hospitals.  NASH’s advocacy agenda for 2019 addresses this very issue, explaining that

Block grants, whether based on individual states’ Medicaid enrollment or on their past Medicaid spending, could impose unreasonable limits on Medicaid spending that could potentially leave private safety-net hospitals unreimbursed for care they provide to legitimately eligible individuals. NASH will work to ensure that any new approach that involves Medicaid block grants continues to give states the ability to pay safety-net hospitals adequately for the essential services they provide to the low-income residents of the communities in which those hospitals are located.

Learn more about this latest proposal in The Hill article “Trump officials consider allowing Medicaid block grants for states.”

Medicaid MCOs Skimping on Care?

Medicaid MCOs may be skimping on care, according to a recent Kaiser Health News report.

According to Kaiser, for-profit companies that sub-contract with Medicaid managed care organizations to review requests for services often deny care to Medicaid patients to save money for the MCOs that employ them and to benefit themselves financially.

The Kaiser article presents examples of companies that have been identified engaging in such practices, explains how they go about their work, and outlines the dangers to Medicaid recipients posed by such practices.

Because they serve so many more Medicaid patients than the typical hospital, private safety-net hospitals, their patients, and the communities they serve can be greatly affected by such practices.

Learn more in the Kaiser Health News article “Coverage Denied: Medicaid Patients Suffer As Layers Of Private Companies Profit.”

Feds Urge States to Do More for Dually Eligible

In a formal guidance letter to state Medicaid directors, the Centers for Medicare & Medicaid Services has outlined ten ways that states can better serve individuals who are enrolled in both Medicare and Medicaid.

Noting that such dually eligible individuals represent 20 percent of Medicare enrollees but 34 percent of Medicare spending while also constituting 15 percent of Medicaid beneficiaries but 33 percent of Medicaid spending, the letter from CMS administrator Seema Verma to state Medicaid directors explains that

This letter describes ten opportunities – none of which require complex demonstrations or Medicare waivers – to better serve individuals dually eligible for Medicare and Medicaid, including through new developments in managed care, using Medicare data to inform care coordination and program integrity initiatives, and reducing administrative burden for dually  eligible individuals and the providers who serve them. A number of these opportunities are newly available to states through Medicare rulemaking or other CMS burden reduction efforts. We are happy to engage with you and your staff on one, many, or all of the items described in this letter. The CMS Medicare-Medicaid Coordination Office (MMCO) works across CMS and with states to better serve dually eligible individuals, including through efforts to better align the Medicare and Medicaid programs and demonstrations to test new approaches to integrated service delivery and financing.

Those ten ways are:

  • state contracting with dual eligible special needs plans (D-SNPs)
  • default enrollment into a D-SNP
  • passive enrollment to preserve continuity of integrated care
  • integrating care through the Program of All-inclusive Care (PACE)
  • reducing the administrative burden in accessing Medicare data for use in care coordination
  • program integrity opportunities
  • Medicare Modernization Act of 2003 file timing
  • state buy-in file data exchange
  • improving Medicare Part A buy-in
  • opportunities to simplify eligible and enrollment

Private safety-net hospitals serve especially large numbers of dually eligible, Medicare-Medicaid patients and will be interested to see whether CMS’s recommendations translate into action at the state level.

To see the entire letter, including additional information about these ten opportunities, go here.

CBO Targets Health Care in Options for Reducing Deficit

Every year the Congressional Budget Office publishes a menu of options for reducing federal spending and the federal budget deficit.  As in the past, this year’s compendium includes a number of options to reduce federal health care spending and raises federal revenue through health care initiatives.

The cost-cutting options include:

  • establish caps on federal spending for Medicaid
  • limit states’ taxes on health care providers
  • reduce federal Medicaid matching rates
  • change the cost-sharing rules for Medicare and restrict Medigap insurance
  • raise the age of eligibility for Medicare to 67
  • reduce Medicare’s coverage of bad debt
  • consolidate and reduce federal payments for graduate medical education at teaching hospitals
  • use an alternative measure of inflation to index social security and other mandatory programs

Options to raise additional revenue include:

  • increase premiums for Parts B and D of Medicare
  • reduce tax subsidies for employment-based health insurance
  • increase the payroll tax rate for Medicare hospital insurance

Many of these proposals, if implemented, would be damaging for private safety-net hospitals.

Learn more about the CBO’s recommendations, how they might be implemented, and their potential implications in the CBO report Options for Reducing the Deficit: 2019 to 2028.