The effective date for a series of rule changes that the state proposed to determine who is eligible for services from the Health Safety Net (HSN) has been delayed from April 1 to June 1. MHA, its member hospitals, and many other groups had strongly objected to the changes. The Health Safety Net helps to finance care provided to Massachusetts low-income residents who are uninsured or underinsured.
One proposed change to the eligibility rules includes altering the retroactive date of coverage. Currently, many patients who get coverage under the Health Safety Net are covered for six months retroactive from their application. The Executive Office of Health and Human Services (EOHHS) plans to change that to only 10 days retroactive coverage. The concern among hospitals caring for the uninsured and underinsured is that patients don’t always apply for coverage at the time they receive care and only realize they need financial assistance after they receive a bill. Other changes to the eligibility rules include a new deductible for those earning between 100% and 150% of the federal poverty level (FPL) and the elimination of partial HSN coverage for those earning between 300% and 400% FPL.
MHA testified in strong opposition to the proposed changes, all of which will become effective June 1 unless further action is taken. In a letter to EOHHS, MHA wrote, “Unfortunately, the proposed regulatory changes weaken that safety net and, as a result, shift costs to low-income patients and hospitals. These cost-shifts are also likely to affect commercial payers and the business community in some degree in the form of higher premiums.” In March, many legislators led by Sens. Jason Lewis (D-Winchester) and John Keenan (D-Quincy) also weighed in and sent a letter to EOHHS, decrying the HSN changes and stating, “The erosion of HSN eligibility will be an impediment to necessary medical care for residents and lead to consumer medical debt and bad debt at hospitals and health centers.”
In addition to the two-month delay in the implementation of the controversial changes, EOHHS also announced that it would introduce a new eligibility policy that had not been proposed previously. The policy called “presumptive eligibility” would permit hospitals and community health centers to use a simplified application for determining patients eligible for the Health Safety Net temporarily instead of the full application that is used for all state programs, including MassHealth and ConnectorCare. MHA has concerns with the proposal and urged EOHHS to not adopt it at this time.
“We appreciate that EOHHS is attempting to address some of our concerns; unfortunately this proposal does not materially address the issues related to retroactive coverage and also raises significant program integrity questions,” said MHA’s Dan McHale. “Hospitals seek to first determine if uninsured applicants are eligible for MassHealth and other state healthcare programs. Caution in changing this practice is needed.”
In a related note, there has been no resolution yet to the funding reduction of the Health Safety Net. Governor Baker’s FY2017 budget proposal eliminates the state’s customary $30 million contribution to the HSN, which affects the program in FY2016. This reduction results in a cost shift to hospitals, as any funding shortfall is paid for solely by hospitals in addition to the $165 million tax on hospitals. The current shortfall is estimated at $90 million.