Friday, March 21, 2014

Family Voices public comment on 1634 changes to Medicaid Disability

Family Voices Indiana is an advocacy organization as well as the family to family health information center. In our advocacy role, we provided testimony today related to the 1634 transition for Medicaid. 



Comments on Medicaid 1634 transition affecting Indiana Medicaid in the aged, blind and disabled (ABD) categories.
Rylin Rodgers

Family Voices Indiana, a statewide not for profit organization, serves Indiana families who are raising children with disabilities and special health care needs.  As our state’s federally funded Family to Family Health Information Center, we help families navigate the complex world of Health Care Financing.  Today I am here to speak about how the 1634 Transition impacts the families we serve.  In many ways this effort at streamlining and coordinating systems has the potential to positively impact the families we serve.  We hope the move to automatically enroll individuals that the Social Security Administration determines eligible for Supplemental Security Income into Indiana Medicaid will help families who have children with disabilities by ensuring that eligible children access both SSI and Medicaid. 
We are concerned about how the lack of a “spend down” option will impact some families.  It is true that a relatively small number of families utilize spend down currently; but for those that do, this transition creates significant challenges.  While the Affordable Care Act makes it possible for these families to buy coverage via the Marketplace, this coverage may not meet the complex needs that can drive a family’s medical costs to be so high that spend down is a critical option.  In addition, given our state’s overwhelming rural landscape and lack of comprehensive access to public transportation, it should be noted that Marketplace Plans do not allow for access to transportation to medical appointments, a critical service that Medicaid does cover.  Finally, Marketplace options may create barriers of access to critical pediatric subspecialty care via their limited networks. For these reasons, we urge you to consider accessing the opportunity under the Family Opportunity Act Medicaid to allow families with incomes up to 300% of the federal poverty level to buy into Medicaid Disability to provide health coverage to uninsured or underinsured children who have disabilities.
The families we serve include children who access Medicaid Disability under Indiana’s Medicaid Waiver Programs.  Because family income and assets are disregarded when children are under 18 in these programs, we urge you not to include SSI determination as part of the initial and annual eligibly process.   Doing so would create an undue burden on families and the system as the child would be found ineligible for SSI due to family income.

Finally, on behalf of the families we serve and the professionals who support them we urge you to provide comprehensive training to intake, eligibility and related staff about these changes.  Similarly, we urge you to provide consistently clear and easily accessible information to the public about processes, requirements and changes.

Specifically we encourage:
·         That all local DFR, BDDS, AAA, Social Security  and related offices be able to answer questions and the information provided is consistent among all staff and offices.
·         That information about how this change impacts children under 18 is clearly available
·         That information sent to families is individualized, reflecting their eligibility process and written in clear language at no higher than a 3rd grade reading level
·         That terms including “Miller Trust” are defined and explained in understandable language and posted where they are easily accessible by the public.
·         That letters send regarding these changes are written to specific individuals and communities rather than one letter attempting to cover everything
In short, Family Voices Indiana urges that the transition occurs with careful planning and communication and that unique needs of children under 18 who have significant disabilities be carefully considered.  That, Hoosier families have access to Medicaid buy in for children who have complex disabilities for whom access to adequate insurance is critical. And Family Voices Indiana stands ready to assist the state in disseminating information about these changes so that families can make the best choices possible as they strive to maintain their employment and participation in their communities.

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