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- April 29, 2014
Re: California’s Bridge to Reform Demonstration (No. 11-W-00193/9)
Read moreThere are three major components of the CCI. As drafted, the amendment repeatedly fails to effectively delineate what changes are occurring under each of these separate components. The amendment frequently conflates the three components of the CCI, muddling an already complicated set of changes. The amendment should set forth,…
- April 29, 2014
Comments on All Plan Letter: Continuity of Care: Definition and Practice
Read moreWith the transition of seniors and persons with disabilities (SPDs) into managed care in 2011, we learned that COC is arguably the most critical factor in successfully transitioning high need beneficiaries into a new health care setting. The poor performance of COC protections led to significant, and at times…
- April 29, 2014
Comments on the Proposed Enrollment Strategy into Cal MediConnect for LA
Read moreApproximately 216,000 dual eligible beneficiaries will receive multiple notices regarding enrollment into Cal MediConnect. Many thousands more will receive notices about enrollment in Medi-Cal managed care only under the Coordinated Care Initiative (CCI). In addition to the sheer number of impacted beneficiaries in LA County, the enrollment strategy also…
- April 29, 2014
Lessons from CA: Exchange Eligibility Appeals under the Affordable Care
Read moreSection 1411(f) of the Affordable Care Act requires the HHS Secretary to establish an appeals process related to eligibility determinations made by Exchanges, including among other things, eligibility for enrollment in a QHP and eligibility for premium tax credits and cost-sharing reductions. The federal Department of Health & Human…
- April 29, 2014
Comments on Cal MediConnect Enrollment Materials
Read moreThe Coordinated Care Initiative encompasses several very complex changes. This makes it very difficult to create notices that can simply and concisely explain the changes in a manner that is understandable for the large number of beneficiaries impacted. At a minimum, the notices should: alert the reader to the…
- April 28, 2014
Comments on All Plan Letter: Continuity of Care
Read moreWe are happy to see that the APL addresses that COC applies to both continuity of services and continuity of provider relationships. However, we believe that the APL should be clearer and more definitive with regard to these protections. We have highlighted in the APL where language should be…
