Starting December 1, the Agency for Health Care Administration (AHCA) is launching a statewide roll-out of new Medicaid health insurance plans. This affects over 3 million Florida Medicaid recipients, primarily children. AHCA has negotiated detailed contracts with each of these plans — a process hidden from providers, beneficiaries, legislators and the public-at-large.
As part of that under-the-radar negotiation, AHCA decided that the plans, for the first time, would be responsible for covering early intervention services (EIS) and medical foster care (MFC). Now, instead of providers with years of experience and expertise in serving these children, it will be mainly private for-profit insurance companies in the “driver’s seat” determining whether these services are “medically necessary.”
EIS is for Florida infants and toddlers from birth to 36 months who have disabilities or delays. Services include screenings, evaluations, and training and support for families on how to increase the child’s participation in daily activities and routines. These are not traditional medical services. They are delivered by providers certified by the Department of Health (DOH) to have special expertise.
The importance of timely, seamless delivery of these services cannot be overstated. As highlighted on Florida’s Department of Health website: “Positive early learning experiences are crucial for later success in school, the workplace and the community…Research shows that children’s earliest experiences play a critical role in brain development.”
Medical foster care is similarly targeted to a very vulnerable group of children and youth —those who are in the care and custody of the Department of Children & Families and who have complex medical needs. These services are delivered by specially trained foster parents.
More than 21,000 children are affected by the EIS transition and more than 300 by the MFC changes.
Families, providers and the managed care plans face numerous challenges to successfully execute this transition. For example, providers, including foster parents, must now negotiate with multiple insurance companies to become part of their networks and navigate multiple plan administrative procedures to get paid. Moreover, none of the affected families have received notice that these insurance plans will now be determining whether their child continues to get these services or whether the child can keep the same provider. Frequently, these providers have cultivated relationships with these children over the span of multiple months and years, which is critical for the services to be effective.
AHCA held rule development workshops last week on EIS and MFC. This was the first opportunity for the public to have a say about these changes. Workshops are the initial step in the rule-making process. There is no way this process will be completed prior to Dec. 1.
These changes also require amendments to the state’s Medicaid waiver. The waiver provides the federal authorization for Florida’s Statewide Medicaid Managed Care program. The current waiver terms exclude early intervention services and medical foster care from Florida’s managed care program. It is unclear whether the state has even initiated the waiver amendment process.
Multiple unresolved issues need to be worked out through the full rule and 1115 Waiver amendment processes before AHCA moves forward to implement these changes. The agency’s current timeframe for making this transition is unrealistic. This train needs to slow down for the good of Florida’s most vulnerable children.