Florida Policy Institute (FPI) recently filed public comments on AHCA's intent to request federal permission to extend Florida's 1115 Medicaid Waiver program (1115 waiver) through June 30, 2024. The request is being submitted nearly two years before the waiver’s expiration, which is slated for June 30, 2022. Typically, such requests are not filed this far in advance.
Under the 1115 waiver, over 3 million Medicaid beneficiaries are enrolled in and are required to access their health services through mainly "for profit" managed care plans. While 1115 waivers are supposed to test new and innovative strategies for improving beneficiaries' access to care, Florida's waiver periodically serves as a platform for making cuts to the program, such as the elimination of retroactive Medicaid benefits.
FPI's comments include recommendations for immediate actions the state should take to improve the managed care program, particularly in light of COVID-19. They include:
1. Collection and publication of COVID-19 data and other managed care plan (MCO) performance measure data disaggregated by race and ethnicity
AHCA collects and publishes data on how well MCOs are meeting certain "performance measures" such as access to preventive care and hospital readmissions. With COVID-19 laying bare stark disparities in health and health care among Floridians, MCO performance data broken down by race and ethnicity is a necessary first step to addressing these longstanding problems.
2. Reinstatement of the requirement for cultural competency plans
Until August 2018, AHCA required MCOs to develop cultural competency plans to ensure that services are provided in a culturally competent manner to all enrollees. AHCA eliminated this requirement in its current contract with the MCOs.
3. Reporting Child Core Set performance measures
Florida already reports to the federal government on multiple child focused MCO performance measures called "child core set (CCS)" measures. Yet performance measure data included in the waiver extension request exclude those CCS measures which do not overlap with Health Effectiveness Data Information Set (HEDIS) measures. Reporting only the HEDIS measures gives the appearance that overall performance on child health measures is better than it is.
4. Withdrawal of the request for a two-year extension of the elimination of retroactive Medicaid eligibility coverage
During the 2020 session the cut to Medicaid retroactive benefits was only temporarily extended through June 30, 2021. Yet AHCA is now asking the federal government to extend this cut through June 30, 2024, without legislative authority. George's story is a reminder of the hardships Floridians with catastrophic illnesses are facing after this cut.
5. Providing evidence of increased access to health care through expanded benefits
AHCA asserts that additional benefits MCOs are voluntarily offering, such as adult vaccinations, physical therapy, and substance abuse treatment, are enhancing recipients' access to care. But no evidence is provided that beneficiaries are in fact accessing these benefits and to what extent.
6. Making adult vaccinations mandatory benefits rather than optional expanded benefits
Adult vaccinations, such as flu and pneumonia vaccinations, are only offered through the expanded benefits package. As an “expanded benefit,” AHCA cannot hold plans accountable for providing this essential component of adult preventive care that is critically important during the pandemic.
When AHCA formally files the waiver extension request with the federal government, it will trigger another publicly noticed comment period. This will provide an additional opportunity for stakeholders to weigh in with their concerns.
In the meantime, AHCA should take steps now — during this unprecedented public health crisis — to ensure that the Florida Medicaid program is doing all it can to reduce racial and ethnic health disparities.