On July 15, 2016, CHLPI submitted two comment letters to Massachusetts’ Executive Office of Health & Human Services (EOHHS) regarding its proposal to amend the state Medicaid program’s (MassHealth’s) Section 1115 Demonstration Waiver. Under the proposed waiver, MassHealth will transition away from siloed fee-for-service care by establishing provider-led Accountable Care Organizations (ACOs). These ACOs will be responsible for the quality, coordination, and total cost of patient care. In order to improve care, ACOs will receive flexible spending funds to address social determinants such as nutrition, housing, and transportation.
In its first comment, CHLPI and Community Servings urged EOHHS to design flexible spending program requirements to give ACOs the flexibility and responsibility to use these funds on services that best meet the unique needs of their patient populations. In its second comment, CHLPI addressed several waiver provisions that would restrict the ability of MassHealth members to freely choose and move between MassHealth’s managed care organization (MCO), ACO, and Primary Care Clinician (PCC) plans. CHLPI encouraged EOHHS to eliminate or adjust these provisions to avoid punishing patients whose evolving health needs require them to choose the PCC plan or move between plans over the course of a year.