In comments to the U.S. Department of of Health and Human Services (HHS), NHeLP urges it to reject proposed amendments to Utah’s Primary Care Network (PCN) project. While NHeLP supports the use of Section 1115 waivers to implement experiments to improve health outcomes, we strongly object to any efforts to use Sec. 1115 to skirt essential provisions that Congress has placed in the Medicaid Act to protect Medicaid beneficiaries and ensure that the program operates in the best interests of the population groups described in the Act.
Utah?s proposals to impose work requirements, place time limits on Medicaid coverage, cap enrollment in certain population groups, charge higher co-payments for non-emergency use of the emergency rooms, eliminate hospital presumptive eligibility, and eliminate EPSDT for individuals ages 19 and 20 should be rejected, separately and together, as they are inconsistent with the provisions of Sec. 1115.