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North Carolina Amended 1115 Demonstration Application

Dec 6th 2017 4:17 pm Response: #312209 1115 does not include the consumer advocacy family committee in the amendment and as a of a consumer of NC Medicaid who is developmentally disabled, the consumer advocacy family committees are very important for the silent voice of the intellectually disabled can be a positive input on changes in the medicaid program.
Lisa Carroll
Catawba County
North Carolina
7703 River Bend Road
Claremont, NC 28610
Dec 6th 2017 8:21 pm Response: #312213 You need to exclude all children in the CAPC program from managed care, not just the kids with NCHIPP. There are many other states that have proof of the damaged caused by this. These changes could hinder care and for medically fragile kids mean death!
Dec 6th 2017 8:54 pm Response: #312217 In Michigan, when managed care was required, not every plan had to provide nursing, so disabled children who needed private duty nursing were given "straight" (non-managed-care) medicaid, and then had to argue about it every time they came up for renewal. For families like this who have a primary private insurance and medicaid as secondary, having 2 managed care plans arguing over what doctors you can see and how procedures will be paid for is a mess.
Dec 6th 2017 10:49 pm Response: #312221 For families with employer provided primary insurance and Medicaid as secondary, managed care organizations create problems for finding in-network physicians and getting specialty pharmacy prescriptions filled. Medically complex children need to see a variety of specialists, and managed care provider lists never fully overlap with primary insurance lists. The transition to MCO makes life more difficult for medically complex kids.
Dec 9th 2017 11:36 am Response: #312225 In North Carolina's 1115 waiver demendsration there is no mention of Consumers and Families of Services having a seat at the table to assist in the implementation and the direction of the 1115 waiver like it is now under the 1915b/c waiver. Consumers & Families are customers of Medicaid. We should not loose our voice at the decision making tables.
Dec 11th 2017 1:20 pm Response: #312233 I am in total support of the new amendments on this bill to provide behavioral and mental health support for certain populations. It will benefit everyone.
Dec 22nd 2017 9:14 am Response: #312241 Please see attached comments from the NC Pediatric Society, the state chapter of the American Academy of Pediatrics. Thank you.
Dec 27th 2017 11:51 am Response: #312245 We have a number of concerns with this waiver proposal. Many of these concerns relate
back to a few simple facts. Children represent 70% of the population covered by the waiver
proposal. In North Carolina generally, 40% of children are insured through Medicaid or CHIP. In
rural areas, 54% of children have public health insurance. Therefore, any changes to benefits and
service delivery will have a disproportionate impact on children. Also, since it is not unusual for
independent pediatric practices, especially in rural areas, to have 40% or more of their patients
insured through Medicaid or CHIP, even small changes in payment, administrative burden, or other
factors could make the difference between a practice closing its doors or continuing to offer health
care services to any children in the community. Finally, given the relative rarity of certain pediatric
subspecialists, paying specific attention to pediatric specialty access should be of particular


Benefits: Benefits need to remain strong with particular attention to assuring the full array of Early
Periodic Screening Diagnosis and Treatment (EPSDT) benefits and adherence to Bright Future
guidelines. Benefits should be strengthened and at a bare minimum maintained.

Inadequate payment rates: Payments for primary care should be at parity with Medicare rates or 115%
of current Medicaid, whichever is higher. Research shows that enhanced Medicaid payment rates lead
to greater participation by providers and improved access to care. For example, a new study in
Pediatrics (January 2018) finds that payment increases resulted in more physicians participating in
Medicaid, including 6% more accepting all new Medicaid patients. Payments that are inadequate to
cover the costs of providing care do not represent a sustainable business model. (For example, the cost
settling provisions for safety-net providers on page 30 foresees a need “to cover difference between
PHP reimbursement and providers’ costs…”) Furthermore, reliance on the CDPS + Rx (Chronic Illness
Disability Payment System + Pharmacy) model is adult-centric. A child-focused complement, such as the
Pediatric Medical Complexity Algorithm, should be strongly considered as well to better capture the
needs of pediatric patients. Finally, we are concerned that resources currently devoted to health
services may be redirected towards PHP administration. Existing fundi
Dec 28th 2017 0:18 am Response: #312253 Dear Medicaid Advocate,
Please see the collection of information submitted to our NC State Legislators over a period of time, attached below.
Thanx for your time and thoughtfulness,
Harald Kowa, MD
Pediatrician, Blue Sky Pediatrics Asheville, NC
Dec 29th 2017 6:59 am Response: #312261 Greetings.

It is a concern of mine that the current waiver for Medicaid will make access to care more difficult for the 2 out of 5 children in NC who rely on this coverage for their healthcare. Making participation harder with complicated rules, procedures and measures -- or rules, procedures and measures that don’t make sense for children -- will substantially reduce access in our state. Currently my suburban practice has about 25% of our patients taking Medicaid. If payment is reduced, or capped, or if payment is delayed or difficult, my practice will have to make a decision financially to cap our medicaid enrollment or we could face financial peril. We are fortunate that we could limit our medicaid population and still stay solvent. Colleagues of mine across the state could not.
Inadequate or delayed payments will hurt access. When children don’t have access to the right care and at the right time, both their immediate health and their longer-term health trajectories can be compromised.

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