Recently, a federal judge halted implementation of the Bevin Administration’s 1115 Medicaid Waiver, also known as Kentucky HEALTH. The Bevin Administration is seeking re-approval of Kentucky HEALTH by the federal Centers for Medicare and Medicaid Services (CMS) before it can be implemented. CMS has opened an additional 30-day public comment period to ensure stakeholders have an opportunity to comment on the entire waiver proposal, issues raised in the litigation, and the court’s decision, and they need to hear from you.
As child advocates, we want to make sure the Bevin Administration’s 1115 Medicaid Waiver proposal does not create unnecessary barriers to coverage for many parents covered through Medicaid expansion. Research shows a linkage between parental coverage and that of their children. Minimizing barriers to coverage and promoting access to services for parents is a vital component to ensuring children do not lose their coverage, even if children’s eligibility and benefits do not directly change.
If you are concerned about the impact the 1115 Medicaid Waiver could have on your family’s coverage, advocate for families who receive Medicaid benefits, or want Kentucky to continue making progress in health coverage and outcomes, submit your comments to CMS by August 18th by following the instructions below.
Read the Bevin Administration’s full waiver proposal with recent proposed modifications here. Read Kentucky Youth Advocates position statement regarding the Bevin Administration’s 1115 Medicaid Waiver proposal here.
Steps to Make a Public Comment to CMS
STEP 1. Go to the public comment page at https://public.medicaid.gov/connect.ti/public.comments/answerQuestionnaire?qid=1897699. You can choose to enter your comments in the text box or attach a file with your comments.
STEP 2. Begin your comments with a couple of sentences describing who you are and why you are concerned about the proposed Medicaid waiver, known as Kentucky HEALTH. Example: “I am a father of two kids, and I need Medicaid to go to the doctor,” or, “I am a counselor at a school, and I know many of the kids who attend the school have parents on Medicaid.” If you are submitting comments as an organization, include relevant information about your organization.
STEP 3. Copy or modify some or all of the following talking points:
A number of provisions in the 1115 Medicaid Waiver proposal create barriers to parents maintaining health insurance. Parents’ health is vitally important to children’s health, and if parents are going to improve health outcomes for themselves and their children, the Medicaid program must be simple for families to understand, participate in, and utilize. Also, if parents lose health insurance due to added requirements and cost-sharing mechanisms, children across Kentucky are likely to also lose coverage even if those children’s eligibility and benefits do not change.
Because I want Medicaid to work for all families in Kentucky who need it, I would like to see the following provisions be added or amended in the final 1115 Medicaid Waiver:
–Include dental and vision benefits in the standard benefits package instead of being classified as an earned benefit.
–Exempt individuals under 100% of the federal poverty level from premiums and copayments.
–Cap the monthly premium at $15 per month for the length of the 1115 Medicaid Waiver (5 years) to ensure working adults without employer-sponsored insurance who cannot secure jobs with higher pay can maintain affordable health insurance through Medicaid.
–Remove barriers to Medicaid re-enrollment, such as lockout provisions and the requirement to back pay premiums, if dis-enrolled for nonpayment.
–Exempt all caregivers in non-traditional situations, like kinship care, from all cost-sharing and lockout periods.
–Exempt individuals diagnosed with a substance use disorder (SUD) from all cost-sharing requirements until they are on a successful path to recovery.
–Increase the dollar amount of My Rewards Account incentives for parents and pregnant women for activities such as prenatal visits or taking children for preventative dental visits. While the Bevin Administration added more activities for parents to the final waiver proposal submitted to CMS, increasing the incentive dollar amount to be earned per activity would allow individuals to earn more dollars to spend on things like over-the-counter medications.
–Define pregnancy to include a time period of six months after birth to ensure eligibility for appropriate follow-up care.
–Ensure Medicaid members have access to help if they have questions about their plan in person, by phone, and online. This includes having help available after regular business hours so parents who work during the day can get help in the evening in understanding their plan and the requirements they must meet to continue receiving Medicaid.
–Ensure there are a variety of ways for recipients to report changes that may affect their eligibility, and ensure they understand how to meet their obligations by offering help in person, by phone, and online. Offer that help after regular business hours so that parents who work during the day can get help in the evening.
The 1115 waiver proposal includes several provisions that protect vulnerable populations, and I would like for the final re-approval of the waiver to include those provisions. This includes exempting children and pregnant women from cost-sharing requirements; exempting primary caregivers of dependents from work and community engagement requirements; exempting former foster youth from the waiver; and maintaining the current Medicaid benefit package for children, pregnant women, and parents covered through SSA 1931.
STEP 4: You can also add a description of how premiums, a lock-out period, or reduced benefits could impact you, someone you work with, or your community.
STEP 5: If you are submitting your comments as a document, upload your file to the comment page. Whether you typed in the text box or uploaded a file, click “Finish” to submit your comments.