At the April meeting of the Joint Medicaid Oversight Committee (JMOC), the Director of the Ohio Department of Medicaid (ODM), Barbara Sears, notified committee members that her department intends to submit Ohio’s request for federal waiver authority to implement work requirements for the Medicaid expansion population by the end of this month. The Center for Community Solutions was one of more than 900 organizations and individuals that submitted written public comments on the draft 1115 demonstration waiver posted by ODM in February. In her testimony to JMOC, Director Sears highlighted that around 650 of these comments were submitted to the department on the final day of the comment period. Federal law requires ODM to consider and respond to these questions in the final waiver request it submits to the Centers for Medicare and Medicaid Services (CMS). Of all the comments submitted, approximately 95 percent expressed opposition to the proposed waiver.
The Center for Community Solutions was one of more than 900 organizations and individuals that submitted written public comments on the draft 1115 demonstration waiver posted by ODM in February.
State Representative Emilia Strong Sykes asked Sears what the timeline would be for implementation if the waiver is approved by CMS, expressing concern that an implementation date of July 1, 2018 (the start of the new fiscal year) would leave counties with less than three months to prepare for the changes in eligibility determination. Sears explained that ODM is working with its software vendor to build the new eligibility requirements for Medicaid into the existing Ohio Benefits system in order to streamline eligibility determinations. Sears also noted that it is difficult to predict CMS’ timeframe for responding to waiver requests, meaning a July 1 implementation goal may not be realistic. Sears and her staff stated that although submission of the work requirement waiver was required by the most recent state budget, there is no statutory deadline for when the waiver must be implemented.
Of all the comments submitted, approximately 95 percent expressed opposition to the proposed waiver.
Sykes also had questions about who would ultimately be responsible for deciding whether enrollees and applicants satisfy the work requirements or exemption criteria, and whether ODM will issue guidance in establishing a uniform process for making these determinations. Another issue Representative Sykes raised was how people with a behavioral health condition would receive the care coordination they need if they lose their Medicaid eligibility due to the work requirement. ODM has made clear that individuals who are participating in a drug or alcohol treatment program will be exempt from the work requirement, along with those diagnosed with a serious and persistent mental illness who participate in ODM’s Specialized Recovery Services Program. But, as Community Solutions emphasized in our public comment, it is unclear whether individuals who are on waiting lists for these programs will qualify for an exemption. Further, this exemption does not take into account those who are living with an undiagnosed substance use disorder or mental illness. For these individuals, the loss of Medicaid coverage would make it more difficult to take the first steps of receiving a diagnosis and beginning treatment.#Ohio Department of #Medicaid plans to submit eligibility requirements to feds by the end of April, implementation date undetermined Click To Tweet
Upon submission of the final waiver request to CMS, Community Solutions will provide further analysis of how ODM addressed the questions and concerns expressed in JMOC, our public comments and the hundreds of other public comments on this waiver.