We are currently enrolled in the HIPP program. But as on 12/31/2009 we will no longer be eligible because we have a family plan insurance policy. In our home there is my husband, me, and our two sons, 6 and 4. My husband is the only one working because I stay at home with our younger son, as he was born with special needs. Because of his disability he receives Medicaid which allowed us to participate in the HIPP program. We are reimbursed $471 per month because our BCBS pays most of the charges at 100%. With the new regulations, we are not eligible based on the number of persons in our household that are not Medicaid eligible. What I do not understand is how our policy is no longer cost effective. We can remove our sons from our private insurance, our younger son would have primary Medicaid and our older son would go on FAMIS, making VA responsible for 100% of care for them. Instead of being secondary insurance for only one son for less then five hundred dollars per month. How is this cost effective for VA? Perhaps I just simply do not understand. I do understand that you are trying to save money, however cost effectiveness has to be looked at on a per application basis. Otherwise, it is not a truly cost effective policy. To be fully responsible for the cost of health care for two children vs. partially responsible for the cost of one child makes absolutely no sense when you are looking to be cost effective and save money. Thank you for helping VA be a great place to live, but we are as only as good as the folks that live here. Please don't make life harder for VA families with special children than it already is. Thank you for your time. Kelly Brubaker

 This is the most ridiculous thing i have ever heard of,2009 we are eligible,2010 we are not.We have the same policy.Just because we only have one child that is medicaid elegible,this one child has CYSTIC FIBROSIS and if you would take the time to look at some of his medications you would see the cost,some of his meds can run between 3000 to 6000 dollars a month!All of which go through my insurance first,and the Dr. visits and hospitals stays which all goes through my insurance first.

What happens if i cant pay my insurance premiums,medicaid would have to pay all of this!The smart thing to do would be to make sure i paid my premiums every month.It sounds to me your just counting on people not to drop there insurance,and that is a sorry way to save Va. money!

I have a wife that cannot work anymore because of the care that this child needs and 2 other children living in this household,I ask you to please reconsider this decision,when you have a special child every little bit counts.

I am very concerned about this action.  The assumptions here are not correct and your plan will seriously harm families who are dealing with sick children.  I read your logic that:

"Medicaid enrollees whose eligibility is not determined based on family household income are likely to be covered under a family health insurance policy which includes the entire family. In these instances it is unlikely that the health insurance would be dropped for one household member who has Medicaid coverage as the cost of the family coverage would be the same regardless of the number of family members in a family plan. Therefore, there is no benefit for the State to enroll the participants in HIPP who would otherwise remain enrolled in the family health insurance if HIPP were not available."

This assumption is grossly inaccurate.  In our case, the family would be forced to drop the insurance.  I can hardly fathom how much MORE expensive that will be for the State of VA.

Young families bear an extreme financial burden with a disabled child (and in our case one who is terminally ill).  The parents cannot suddenly be expected to pay the tab for health insurance so the Commonwealth can enjoy the benefit of being the secondary insurer.  

In such tough economic times, shifting 100% of this cost to a young family with a seriously ill child is NOT the answer.  I recognize the state's goal, but surely there would be some savings if the family paid 1/3 and the state paid 2/3.  Shifting 100% is simply unreasonable.  Pleas re-think your decision.

All while this issue was being considered, no one notified those who would be hurt the most.  Now, we learn that the Gov. has signed off on this and families are receiving notification letters telling them that the HIPP program no longer applies.  Could that be more unfair?  Please - please consider what unintended consequences this may have.  This is a HUGE change and one that will result in serious consequences for our family.

Cordially,

One family who relies on HIPP

Normally, comments are allowed as part of the vetting process before legislation is signed into law.  However, I am the parent of an autistic child who think it drastic to suddenly drop financial assistance to families with special needs children from 100 to zero percent.  This legislation may have appeared more sensitive to families like us if the State proposed reducing its share, say 75 or even 50 percent.  It would have even made more sense to pro-rate based on the ratio of Medicaid eligible children in the household; but to suddenly take away all financial assistance for special needs children under the HIPP is shortsighted and does not make long term economic sense.  Families like us now have to figure how to make up for this sudden loss in  financial support.  What would happen if these children were to become wards of the State because of the increased financial hardship resulting from insensitive actions like this?   Shifting costs within the State Budget does not create savings overall.  Anyway, my hope is that someone will revisit this bill and balance the need to address the budget with that of increasing financial hardships on the families with special needs children.  Parents want to provide for our special needs children but legislation like this make it more and more difficult to do so.

Thanks for the opportunity to comment.

Hello,

Thank you for the opportunity to comment.  

My husband and I have a terminally ill child who has a rare metabolic disorder.   During her first year of life, we endured countless medical test trying to find a diagnosis and cure for her.   We incurred $9,000 of medical bills her first year of life due to insurance not covering these tests and procedures given that she didn't have a diagnosis.  We finally got the diagnosis when she was 11 mths old - and was able to finally get her on Medicaid to help with the out of pocket expenses.   Even with a primary and secondary insurnance (Medicaid), we still are responsible for a significant portion of her medical care costs. Currently, I am using her HIPP reimbursement to pay for care that alllows me to work full time to maintain her health insurance.    Her EDCD waiver funds do not cover this expense in its entirety. 

Also, please understand that not every employer has a multi-tiered insurance plan.  For example, if enroll anyone other than myself, I must go into the family plan.   The state argument that most families would not drop their special needs child from their insurance is not a fair statement.   Actually, I could do that and make Medicaid her primary insurer.  This would in turn also lower my employers experience ratings (and then in turn lower MY health insurance premiums) which would be beneficial to me. 

The amount of reimbursment that we recieve each month doesn't equal 10% of her "normal" medical expenses, much less if she has an hospitalization at CHKD.   Please reconsider this decision on a case by case basis and look at the insurance options available to the parents before you make these blanket choices.   Thank you.

My daughter has been a participant in the HIPP Program.  We have just received notice that we are no longer eligible for this program.  In reading the eligible-vs-noneligible family plans chart that was included in the cancellation notice, it appears that if my husband were to drop our two non-Medicaid eligible children from his policy and only retain our medicaid enrolled child that we would still be eligible for the program.  Am I reading this correctly?  My husband's monthly premium (through BC/BS) doesn't change based on the number of children in our family-1 child or 12 children-the monthly family premium is the same.  I'm confused as to why dropping the other kids from the policy would make us more cost-effective.  If we have to drop the kids, my daughter's primary insurance would be solely medicaid.  I do not have medical insurance as an option through my job because it is basically parttime (so I can be available to care for my totally dependent special needs child).  I hope that further thought is given to this legislation before it is passed as its impact will hurt many families that are already struggling with the outrageous cost of caring for a severely disabled child at home.

           Neither Town Hall Form TH-13 Substance nor the recent 12VAC30-20-211 are consistent with the purpose of 12VA30-20 which states, “The purpose of this regulatory change is to amend current Medicaid regulations to remove the requirement for enrollment in an employer-based group health plan, if such plan is available to the individual and is cost effective, as a condition of Medicaid eligibility…” Under the Substance section of 12VAC30-20 it is clear the primary objective is to: 1) Eliminate the requirement that Medicaid families "must" apply for HIPP and make it "voluntary" and 2) the regulation change attempts to capture/cover the 20% of disabled adults that live independently, but can still fall under the health insurance of the parent/family.  

          The following information is lifted from the appeal letter we sent to DMAS in response to their recent notification about terminating HIPP. It is hoped the following information will convey the concerns and issues we have with TH-13.

Our son was enrolled in medicaid in the past year.  I applied for HIPP and was accepted into the HIPP program.  That made sense since it encourages me to keep my son in my employer's medical plan.  My other choice would be to drop him from employer-provided medical and let Medicaid pay 100% of my son's medical expenses, letting the state bear the entire burden rather than the employer's plan bear the majority of the expense.  Please note that higher medical expenses incurred in the employer plan increase employer plan rates that my employer and I have to pay, so there is motivation to drop my son from my employer plan coverage absent receiving HIPP.  By incentivizing me to retain my son in my employer's plan via HIPP, this has resulted in cost avoidance to the state and its taxpayers.  That's the essential purpose of HIPP, isn't it, to provide medicaid cost avoidance?

The emergency regulations caught me by surprise when I learned of them when receiving notice of cancellation in the mail last month, effective January 1, 2010.  In a more close reading of the emergency regulations, I found the subsequent regulations established to implement 12VA30-20 to be head scratchers.  Comments by commentator John Carvil of November 17, 2009 in this regulatory town hall speak in detail to this point.  I refer to that post (10109) in lieu of repeating it.

In phone calls I placed with DMAS, I learned that the emergency regulations were established, basically, due to budget constraint issues.  From my perspective, the implementing regulations, rushed and absent public comment and appropriate vetting, are flawed.  In addition to inconsistencies noted in the previous paragraph, I think it good to look at the unintended consequences of the regulations' implementation.  We'll use my family's situation as an example (although I know other HIPP participant families that are in the same boat).  We have family coverage for 4; myself, my wife and 2 sons.  If I had only one son, and he was the one on medicaid, under the new regulations we would continue to be HIPP eligible, and continue to receive 100%.  'Unfortunately,' we have another son participating in the medical plan who is not in Medicaid. So we're cancelled from HIPP and receive zero.  It's all or nothing.  In our medical plan, there is no difference in medical plan participant rates if I cover one or two sons...its the same rate.  This illustrates how the emergency regulations are flawed.  They are punishing families who 'unfortunately' have more than one child who is not on Medicaid.  Needless to say, its also more expensive to raise 2 children than one child.  I do not believe that our Commonwealth is for having regulations that have such animus toward families, even if they were originally established out of good intent.  Other solutions must be found and the current emergency regulations cancelled.

Here some options to consider in order to address HIPP budget reductions:

-Determine how much the premiums are for the Employee and Medicaid enrolled family member(s) only would be under the employer plan, regardless of other family member participation in the medical plan.  Employer benefits plan administrators are able to furnish that information and that information can become part of the forms the employee has to submit. Reimburse at that amount. 

-If the above does not provide sufficient reductions to meet the HIPP budget, then simply determine the percentage of additional overall reduction needed, and apply it to HIPP participants.  For example, if after the first calculation above, the anticipated expenses are still 20% above budget, reduce the reimbursements to the HIPP participants by 20% across the board.

The above options, if implemented, would:

-Provide a fair approach to address the need to reduce expenses.  Rather than keeping in essence 100% reimbursement or 0% reimbursement, with a forced reasoning found in the new eligibility chart that is hostile to larger famililes, it provides a way to calculate reimbursement that is more family size neutral.

-Maintain more participants in HIPP.  Even if reimbursements have to be reduced some in order to meet budget, participants are still incentivized to maintain medicaid enrollees in the employer plan.  This gets at the core of what HIPP is about.  As it stands now, every one of us who has been cancelled are motivated to reconsider whether to drop their medicaid-covered family members from the employer plan.  My cancellation notice has certainly caused me to seriously consider that option.  This will drive up overall costs of medicaid, which is ironic since the state is addressing serious budget deficits.

Allow me to say, so that it doesn't get lost in the discussion, that I support full funding of HIPP.  It is smart regulation to lower medicaid costs.  The above discussion is within the context of the reality that there is a HIPP budget to be managed here and now.

At this time I am maintaining my son who is enrolled in medicaid in the employer plan.  I have hope that the emergency regulations will be changed for the better with a more favorable outcome for families.

Thank you for considering my comments.  Geoff Klein