JMOC Update and Healthy Ohio’s First Public Comment Hearing

On April 21st, the Ohio Department of Medicaid was busy with Director John McCarthy offering testimony before the Joint Medicaid Oversight Committee (JMOC) in the morning as well as serving as host to the first of two required hearings for Ohio’s 1115 Demonstration proposal known as “Healthy Ohio” in the afternoon. During JMOC, the director provided a brief overview of the Department’s activities regarding Ohio’s Disability Determination Redesign, Ohio Benefits, and the Behavioral Health Redesign.

Director McCarthy affirmed the ongoing work with the Center for Medicare and Medicaid Services (CMS) around establishing a timeline for the new coverage via DDR. He outlined a request to CMS to delay the new coverage for existing participants until their redetermination in 2017. While the new coverage rules would still apply to any new applications starting July, 2016, this would allow county caseworkers, he explained, to learn the new rules between July of this year and January, 2017.

Moving on, Director McCarthy highlighted the successes of the Ohio Benefits system in decreasing enrollment times and increasing access for application renewals. Director McCarthy explained that Medicaid would soon be fully integrated into Ohio Benefits, moving Ohio one step closer to retiring CRIS-E, Ohio’s outdated benefits management system.

Behavioral Health Redesign was the final area of conversation for JMOC, leading to the only questions from the committee’s chair, Senator David Burke, regarding provider feedback. As McCarthy explained in both his testimony and response to the chair, the redesign work is an ongoing policy formulation process that has involved numerous, often positive conversations with providers around how to successfully make the transition to the new system of billing and Managed Care contracting. He explained to the committee that, after several months of dialogue with providers, the redesign will likely be $37 million above budget neutrality to accommodate some of those concerns for both adult and children’s behavioral health providers. Moreover, to assist with transition, the new billing codes would not be mandatory until July, 2017, but would go live in January, 2017, allowing providers the opportunity to use the new codes in January and April before the mandatory transition in July.

During the afternoon public comment process on Healthy Ohio, a number of organizations and individuals—including me—offered perspectives on Ohio’s impending proposal to CMS. To start the meeting, representatives from ODM’s contracted actuary provided an overview of Healthy Ohio to Ohio’s Medical Care Advisory Committee (MCAC), a body of advocates, providers, and others to advise the Medicaid program on policy issues. Of the numerous individuals who provided comment before MCAC (and the dozens of attendees), none stood in support of the proposal.

The comments offered were brief, with no questions taken. The comments from organizations included the potential impacts Healthy Ohio could have on foster children, behavioral health providers, and consumers. In addition to organizations, however, several individuals stood to offer comments, often citing concerns about affordability, access to coverage, and the stigmatization of the poor in regards to personal economic choices.

CCS has formally submitted its comments to ODM, a copy of which can be found here. Generally speaking, after a comprehensive review of the proposal, we ultimately feel the proposal is too complex and too harmful for many low-income Ohioans. Not only does the waiver bring into question issues of coverage disruption, outcomes, and fraud and abuse, but it also has the potential to seriously impact a major industry in Ohio and the region. In fact, recent research from Families USA has shown that in the five states where premiums have been imposed, not only were there disruptions in coverage, but administrative costs were significant and revenue generated was minimal. This is especially of concern for Ohio’s proposal as ODM’s current application does not include details regarding how much Healthy Ohio’s administrative expenses might be.

The second hearing is slated for Tuesday, April 26, in Cincinnati. Anyone who wishes to submit comments can do so via email at, but we encourage everyone to check out ODM’s landing page for Healthy Ohio before the comment submission deadline of 5/16/16.

For more information on the public comment process, please check out