To Whom It May Concern:
I am writing in reply to Governor Bevin's request for public comment on his plans for the restructuring of Kentucky's Medicaid program. Regarding the proposed changes, I would like to present my own personal and professional concerns.
I write to you as a professionally trained public policy analysts with more than forty years of experience working among poor and health challenged populations in both the United States and Latin America. The proposed changes present serious concerns as to how the Governor's recommendations will negatively impact these specific members of our community. These are some of my concerns.
1) There is a requirement of a thirty day period for public hearings to discuss the complications of proposed procedures. Unfortunately, the public has not received adequate notice about these sessions. Such gatherings are in locations that ignore the major populations centers of Kentucky. Furthermore, they are scheduled in the mornings at times when there is only minimal accessibility for the general public. Not only is this legally questionable in terms of the governmental obligations, it calls into question the government's motivation in providing full transparency for the hearings.
2) The program's work requirements, which in other programs in the past have had negligible results, does not take into consideration that many current recipients of Medicaid are already employed, although in low paying jobs - hence their enrollment for Medicaid assistance. There are also those residing in the poorer sectors of the inner cities, in rural areas, or in former coal communities, all of which are known to be high unemployment areas. Imposing additional employment obligations may not be possible when one considers their availability to work given their current undetermined work schedules. Such requirements also do not take into consideration the need for child care services during these periods of additional employment - nor does it consider the financial costs involved in paying for such child services.
3) Premiums supposedly are intended for recipients to "have some skin in the game", as if recipients are not aware of the social and financial price that they are already paying, most frequently on a disproportionate levels of taxes and living costs. Does the assigned $37.50 monthly payments include all or only one member of a family unit? The program's title, " My Rewards", is both demeaning and reflects how government officials envision their role in serving the community. It is evident that the goal of premiums, although not officially stated, is to reduce the number of recipients over an extended period of five years or more - a "savings for the Commonwealth of $ 2.2 billion dollars (with a reduction of some 86,000 recipients).
4) The proposed program also includes the retroactive disenrollment of recipients for failure to comply with the new Medicaid regulations. These might be a failure to pay specific premiums, or "noncompliance because transportation was discontinued (elderly persons will be eliminated from transportation to emergency rooms unless there is a verified medical emergency). "Lack of program compliance" will make recipients subject to extended periods of months with no health coverage, resulting in further deterioration of pre-existing medical conditions.
5) Future Medicaid recipients will also be subject to attending "financial and health literacy courses" whose administration, content, pass/fail requirements are not specified, nor are the individual's means of paying the costs of such services. What procedures will be established to monitor the progress of, or the attendance at, such government imposed courses?
6) Participants in the "My Rewards" program will be encouraged / ultimately required / to transfer their Medicaid coverage to employer covered health plans. This involves a few false assumptions, namely that in areas of high unemployment the employer: a) will have a company insurance plan, b) that Medicaid recipients will have enough hours of employment to be included, if such a program were available, c) what would be the expected deductible for such programs.
7) If economic limitations have been a major barrier to access in a health insurance program, how will current Medicaid recipients accumulate "savings" which could then be transferred into Health Savings Accounts? Such a proposal is mathematically impossible.
8) The elimination of eye and dental services are also envisioned in the new the Medicaid program. The lack of such services will directly impact low income and elderly populations in need of these programs. Their only choice is to go without them.
9) Kentucky has for decades been listed among the states with the highest incidence of chronic illnesses: cancer, diabetes, lung disease, high blood pressure, obesity, malnutrition, and cardio vascular disease. The recent extension of the Medicare program, KYnect, have for the first time made health insurance available to hundreds of thousands of Kentuckians who now fear a return to the past when their only recourse was the emergency room, or no care.
10) The Medicaid changes proposed by Governor Bevin will only result in the deterioration of the overall health condition of thousands of Kentuckians. The Governor reportedly has stated that if his proposal is not accepted by federal officials, he will then discontinue the Medicaid program in its entirety. This would be the ultimate disaster for the Commonwealth.
For all the reasons I fervently request that Governor Bevin's recommendations be rejected and more efficacious alternatives be adopted.
Dr. Joseph Brennan