HCRCC Public Health Safety Net Workgroup Comment Ltr x

Maryl

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October 5, 2010 The Honorable James Hubbard, Co-Chair Deputy Secretary Renata Henry, Co-Chair Deputy Secretary Fran Phillips, Co-Chair Public Health, Safety Net and Special Populations Workgroup Health Care Reform Coordinating Council Dear Co-Chairs Hubbard, Henry, and Phillips: On behalf of the 67 members of the Maryland Hospital Association (MHA), I am writing to share our comments on the key issues being considered by the Health Care Public Health, Safety Net and Special Populations Workgroup of the Maryland Health Care Reform Coordinating Council (HCRCC). Passage of the Patient Protection and Affordable Care Act (ACA) is historic and creates great opportunities to expand coverage, enhance access, and reduce costs. There will remain, however, pockets of uninsured and underinsured Marylanders who will need access to a wide array of hospital and community-based services. Additionally, there are concerns about “churning,” as the newly insured potentially fall in and out of coverage due to their inability to pay deductibles and co-pays. To ensure that services will be available in all communities for the uninsured and insured, MHA believes that the following must occur: • Medicaid reimbursement must reflect the true cost of providing care; • Annual payment updates to providers must recognize the full inflation-driven cost of providing care and reflect the actual costs of goods and services that rise from one year to the next; and ...

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• Publié par: Indo
• Nombre de lectures: 15
• Langue: English

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October 5, 2010

The Honorable James Hubbard, Co-Chair

Deputy Secretary Renata Henry, Co-Chair

Deputy Secretary Fran Phillips, Co-Chair

Public Health, Safety Net and Special Populations Workgroup

Health Care Reform Coordinating Council

Dear Co-Chairs Hubbard, Henry, and Phillips:

On behalf of the 67 members of the Maryland Hospital Association (MHA), I am writing to

share our comments on the key issues being considered by the Health Care Public Health, Safety

Net and Special Populations Workgroup of the Maryland Health Care Reform Coordinating

Council (HCRCC).

Passage of the Patient Protection and Affordable Care Act (ACA) is historic and creates great

opportunities to expand coverage, enhance access, and reduce costs.

There will remain,

however, pockets of uninsured and underinsured Marylanders who will need access to a wide

array of hospital and community-based services.

Additionally, there are concerns about

“churning,” as the newly insured potentially fall in and out of coverage due to their inability to

pay deductibles and co-pays.

To ensure that services will be available in all communities for the uninsured and insured, MHA

believes that the following must occur:

•

Medicaid reimbursement must reflect the true cost of providing care;

•

Annual payment updates to providers must recognize the full inflation-driven cost of

providing care and reflect the actual costs of goods and services that rise from one year to the

next; and

•

The state must recognize the need to invest in community-based mental health resources so

that these patients get the care that is best for them, thus freeing up expensive hospital

resources for truly emergent care.

Medicaid

According to Maryland Department of Legislative Services (DLS) analyses, the major driver of

growth in the Medicaid budget continues to be enrollment growth (15.6 percent in 2009,

16.5 percent in 2010, and a projected 4 percent in 2011).

Similarly, the Kaiser Commission on

The Honorable James Hubbard

Deputy Secretary Renata Henry

Deputy Secretary Fran Phillips

October 5, 2010

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Medicaid and the Uninsured recently released a survey finding that a number of states

experienced rapid growth in their Medicaid enrollment and spending last year, and expect

additional growth in fiscal year 2011; states attributed the unexpected jump to higher-than-

expected increases in eligible families due to the recession.

While Medicaid enrollment growth

in Maryland is a good thing, for the past several years it has been financed in large part by

reducing reimbursement to all kinds of providers who take care of Medicaid patients--hospitals

being just one example ($200 million in reduced Medicaid payments since 2009).

This is a “cost

curve” that is unsustainable, and it makes all providers nervous to think of expanding a Medicaid

program that is already enormously underfunded.

Annual Payment Updates

Additionally, hospitals remain concerned about the hospital averted uncompensated care

assessment that has been imposed since the beginning of 2010.

The idea was that, as the number

of uninsured patients dropped, so could uncompensated care payments to hospitals.

In reality,

however, hospitals have not seen a decrease in the number of uninsured that they treat.

Yet

hospital reimbursement was reduced an additional $89 million beginning in January 2010 due to

this program--money that was prospectively removed from hospital rates without an accurate,

real-time “settle-up.”

The DLS Medicaid budget recommendation from the most recent

legislative Session requires the Department of Health and Mental Hygiene to reconcile the

averted uncompensated care assessment with actual Medicaid enrollment data.

We believe the

current prospective reductions in hospital payments due to poorly estimated averted

uncompensated care should end until all prior averted uncompensated care reconciliations have

been completed to the satisfaction of policymakers and reconciled with actual hospital

experience.

Mental Health

Special populations, including those with behavioral health issues, will benefit greatly from the

continuum of care goal set by health reform.

Hospitals, however, remain concerned about the

ever-shrinking infrastructure in place to provide ongoing care for this population, many of whom

have other needs as well.

In fact, DLS estimates that the community mental health fee-for-

service budget had a state fund deficit of almost $11 million in fiscal 2010 and $18.5 million in

fiscal 2011.

As a result of the lack of a safety net, the hospital emergency department often

becomes the primary place for treatment, because of the lack of practitioners and infrastructure

able to care for these patients.

Again, the state must recognize the need to invest in community-based mental health resources

so that these patients get the care that is best for them, freeing up expensive hospital resources

for truly emergent care.

The ACA provides Maryland the opportunity to restructure the delivery system in such a way

that truly expands coverage, enhances access, and reduces costs.

But in doing so, we must not

The Honorable James Hubbard

Deputy Secretary Renata Henry

Deputy Secretary Fran Phillips

October 5, 2010

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abandon the lessons learned from and fix the shortcomings of the current system, so that moving

forward, we restructure more efficiently and effectively.

MHA appreciates the opportunity to comment on the key issues before the Public Health, Safety

Net and Special Populations Workgroup, and we look forward to working together to move our

state’s health care reform efforts forward.

Sincerely,

Valerie Shearer Overton

Senior Vice President, Legislative Policy