The public comment period on the Ohio Department of Medicaid’s 1115 Healthy Ohio waiver request is now open. While the Ohio Academy of Family Physicians has already submitted comments expressing concern that approval of the waiver would increase the number of uninsured and decrease the number of individuals with Medicaid coverage, individual OAFP members can submit comments as well.
The federal comment period ends on Sunday, August 7. Submit your comments directly to the Center for Medicare and Medicaid Services (CMS). There is no formal deadline for CMS to respond to the state for 1115 waiver decisions.
The Ohio General Assembly included a provision in the last state budget that required the Ohio Department of Medicaid (ODM) to seek federal permission to mandate enrollment in a Health Savings Account for every non-disabled adult enrolled in Medicaid. So in keeping with the dictates of the statute, state officials, on July 1, submitted a Section 1115 waiver request to CMS asking federal regulators to allow Ohio to charge premiums to nondisabled, working-age adults on Medicaid who have incomes of less than 138% of the federal poverty level, or about $16,200 a year. If approved, the waiver would affect one million Ohioans by requiring that they establish Health Savings Accounts and pay annually to maintain their Medicaid coverage.
“On behalf of the 4,800 family physician, family medicine resident, and medical student members of the OAFP, I write to express extreme concern with the ODM’s Healthy Ohio Program 1115 Demonstration Waiver application.
As primary care physicians serving on the front lines of patient care in Ohio, we know firsthand that approval of Ohio’s waiver application would be a devastating blow to progress made in providing health care coverage to Ohio’s Medicaid and other low-income populations. In fact, the Healthy Ohio Waiver, as written, threatens coverage of over one million adult Ohioans who now have coverage – a huge step backward rather than continuation of earlier progress made possible by the Affordable Care Act (ACA) and Medicaid expansion.
Premiums have been a feature of Medicaid’s waiver programs in other states and have consistently resulted in program disenrollment and participation decline. That means people are not getting the health care they need. Research also shows that the cost of administering nominal co-pays or premium payment programs far exceeds the value of the premiums or co-pays collected. Furthermore, Medicaid expansion has improved care by transitioning services from expensive hospital emergency departments to less expensive outpatient settings.
Supporters of the waiver application would have you believe that Ohio’s waiver proposal is very similar to the Indiana waiver that CMS approved. The truth is Ohio’s proposal is far more drastic and harmful as Ohio’s plan locks out all participants (except pregnant women) from basic Medicaid coverage if they are unable to pay premiums. Indiana provides participants with basic Medicaid coverage if they fail to pay premiums as long as they are at or below 100% federal poverty level or if they were unable to pay the premium due to domestic violence, living in a county with a disaster declaration, being medically frail, and other exceptions deemed necessary. Ohio offers none of these exceptions.
The bottom line – the Indiana waiver decreased the number of uninsured individuals and increased the number of individuals with Medicaid coverage. Ohio’s waiver would do the exact opposite – increase the number of uninsured and decrease the number of individuals with Medicaid coverage. This is not the direction we want to head as a state or nation.
Please reject Ohio’s 1115 waiver application for what it is – another way to dismantle the ACA by eliminating Medicaid coverage for those who need it most. This waiver application is a foolhardy attempt to take Ohio back to a point that is even worse than its pre-Medicaid expansion days when large numbers of our most vulnerable populations lacked health care coverage.”