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