Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
chapter
Waivered Services [12 VAC 30 ‑ 120]
Action CCC Plus - Part 1
Stage Emergency/NOIRA
Comment Period Ended on 8/9/2017
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7/19/17  10:07 pm
Commenter: Anonymous

CCC Plus: not person-centered
 

One policy that goes into effect in August 2017 is the huge Medicaid/Medicare upheaval known as Commonwealth Coordinated Care Plus which affects every population that I currently work with. Most importantly, it affects the adults with ID and DD that I work with daily and has caused much chaos due to the uncertainty surrounding the differences in coverage that are vital to these individuals lives who already receive so little.  All remaining Medicaid populations and services such as community-based and home-based services along with LTC services will be mandated to utilize CCC Plus. During the CCC pilot program last year, potential enrollees (you had to have Medicaid and Medicare) had the option to choose from three different insurance companies. The information that wasn't widely distributed was the fact that there was an "opt out" option for individuals at this time. Individuals had a choice and that has since been taken away by this mandated inclusion. CCC Plus seeks to provide cost-effective, coordinated and managed care system of delivery within 280 days of its enactment. When describing why this change is needed, this regulatory action is described as needed for the welfare, safety and health of citizens that receive long-term services and supports from Medicaid so they can receive higher quality of care and care coordination. Jargon like person-centered, high-touch and improving quality with a managed care model and breaking free of a fee-for-service delivery system are but distractions. But let me ask, how is this person-centered when the person(s) it impacts have no choice? The argument for the emergency behind its implementation is that currently long term services and supports are not sustainable as the rates of those requiring Medicaid rises. There is no indication as to how the quality of services will be improved. This is a better managed way to save money by placing "Big Brother" on the forefront to ensure that one extra dime isn't taken from the greedy hand of state and federal public assistance if it isn't warranted by care coordination. Care coordination is a fancy way of describing the magnifying glass with which these MCOs will be holding down on those who are mandated to be a part of CCC Plus to ensure they don't receive one appointment or service past what is minimally needed. Public participation is encouraged in relation to cost and benefit alternatives, impacts and ideas on the development of CCC Plus yet not one person has left a comment? Is there even a point? This is happening whether or not this is commented upon. What is the most absurdly ironic happenstance regarding this regulatory action is that it seeks to provide a higher quality of care but also incorporates more control on budget predictability. We can all agree that individuals receiving Medicaid and/or Medicare (soon to be CCC Plus) don't have much in the way of disposable funds. The last sentence of the Town Hall Agency Background Document states "may decrease disposable family income depending upon which provider the recipient chooses for the item or services provided." What this really means is "stay in network or you're screwed." No matter how much fancy jargon, service quality promotion, or emergency propaganda the state spouts about this mandated change, one thing is for certain: it is NOT person-centered, it limits vulnerable populations even moreso than before, it provides more stringent guidelines on in-network healthcare and takes advantage of marginalized populations by forcing them to seek out of network care on their own dime. 

CommentID: 61482