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Questionnaire NameNorth Carolina Amended 1115 Demonstration Application
DescriptionNorth Carolina is amending their 5-year section 1115 demonstration application previously submitted on June 1, 2016. The amended application requests to implement managed care transformation for Medicaid beneficiaries including incorporating tailored plans for some populations. Additional proposed programs under the amended application include the development of a substance use disorder program, expansion of the provider loan repayment program, building a behavioral health home care program, and piloting new programs such as telemedicine and regional resource management for unmet needs. The federal comment period will be open from December 5, 2017 through January 5, 2018.
Response FromID: #312245 on Dec 27th 2017 11:51 am
North Carolina Amended 1115 Demonstration Application

North Carolina Amended 1115 Demonstration Application

We encourage the public to submit their comments on Medicaid.gov as they relate to demonstrations open for public comments. In support of transparency and open government, all public comments received are immediately posted and are in the public domain. Center for Medicaid and CHIP Services staff will review all public comments posted and we reserve the discretion to delete comments that are generally understood as any of the following: obscene, profane, threatening, or otherwise inappropriate.

Refer to the Application

Open for Public Comment – 12/05/17 – 01/05/18

Please provide your comments here and/or attach below:

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
concern.

Concerns

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
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