Today the Connector Board approved the last round of materials necessary to prepare for Commonwealth Care. With only three days left until October 1st, we’ve entered the final countdown. After reviewing a last set of contracts and regulations, the Board gave the all clear and Executive Director Jon Kingsdale said Commonwealth Care is ready to be launched.
Readiness Update
Connector COO Rosemarie Day told the Board that all systems are “Go” from the administrative end. She said all the software has been checked and they will be able to accept enrollees through the Virtual Gateway starting October 1. Eligible individuals should get letters this week alerting them to the launch of Commonwealth Care, and next week they will receive enrollment materials.
Board members wanted to check that certain systems were operating properly. Dolores Mitchell wanted the staff to track where people had heard about Commonwealth Care, so that information could be used later for outreach. Celia Wcislo asked to have staff call enrollees to facilitate the process. Rosemarie said that they would be sure to do so for Phase II (enrollment of people with incomes from 100%-300% fpl), and would try to do so for Phase I (enrollment of people with incomes below 100% fpl). The Board will get biweekly reports about the progress of enrollment, and about what types of concerns enrollees have when they call customer service.
Rosemarie then briefed the board about the Phase II contract with Maximus, which will operate customer service and handle premium billing. The contract is worth $9.6 million, assuming that 100,000 people enroll in Commonwealth Care. If more people enroll the cost will be larger, if fewer enroll, it will be lower. Celia asked about Maximus’ language capabilities and about whether they provide health insurance to their employees. Rosemarie verified that the customer service representatives speak Spanish and have access to a language line, and they do have health insurance. Jon Gruber raised a concern about giving Maximus a competitive advantage in bidding for future contracts if the have exclusive access to customized software. The Board discussed the possibility of making the software public, but did not reach a clear resolution of the issue. The Board then agreed to the contract.
Regulations
The Board knew that it needed to approve some portions of the regulations for the launch to work properly, but was concerned with other parts that were not essential to the launch. The provisions that were cut included two criteria for hardship waivers, a section about excluding some people from eligibility, and references to plan type V.
Chip Joffe-Halpern suggested that the Board reinstate the option of payment plans for people who fall behind on their premium payments. The Board strongly supported this addition.
The biggest concerns centered around the hardship waivers. The draft mirrored MassHealth regulations which allow the agency to waive premiums if an enrollee has extreme financial hardship due to a number of specific factors. Board members raised concerns about the criteria regarding percent of income spent on medical expenses and significant, unexpected increases in essential expenses. The Board decided to strike two these criteria for the time being and refer them to a committee. Celia raised, and Julie Bowler echoed, a concern about whether enrollees with hardship waivers would still be responsible for co-pays. Executive Director Jon Kingsdale said that as the regulations stand, the hardship waiver removes the enrollee’s responsibility for premiums, but not for co-pays. Celia made sure to confirm that the Board will address the hardship issue again and in more detail.
The Board also discussed and resolved a variety of other concerns about the regulations. Celia made sure that the definition of families was modified to include two adults with no children. The Board decided to strike section 3.09, which excluded people who get coverage through certain other sources, for example fishermen and students. The Board wasn’t sure if they had the statutory authority to make this exclusion, and weren’t sure they wanted to make it if they did. The Board decided to discuss this issue further and return to it later. Celia also raised the related concern that employer-offered plans that leave people underinsured should not make people ineligible for Commonwealth Care.
Insurance Commissioner Julie Bowler was concerned about the about 60-day “free look” provision, which allows enrollees to switch plans soon after enrollment. EOHHS Secretary Tim Murphy (sitting in for Beth Waldman) said this is an important provision for protecting people who are auto-assigned, and the Board decided to keep it. Chip asked that the 10-day notice of termination for non-payment to be extended to 14 days, and since the staff did not object, the rest of the Board agreed. The Board corrected a few other minor problems, then passed the regulations.
MMCO Contracts
Patrick Holland gave the board a presentation about the MMCO contracts. He began by discussing the negotiation process used to develop the contracts and mentioned that the prospect of auto-assignment based on lowest price was very helpful for keeping the bids low. He also noted that coverage will be provided to the entire state; of the 38 service areas, 28 have three or more plans and only 7 have only one plan. Patrick then presented the capitation rates, which range from about $275 to $390 depending on plan type and geographic area (see page 13 of presentation). Next, Patrick explained the auto-assignment process: any MMCO whose rates are within 3% of the lowest bidder will receive a portion of the auto-assigned enrollees (see page 17 of presentation). Finally, Patrick discussed the risk sharing provisions in the contracts. He noted that the risk sharing allowed the MMCOs to offer lower capitation rates and helped offset uncertainty. One form of risk sharing is aggregate risk sharing, under which the Connector will share half of the MMCO’s costs if it is more than 5% above the expected level (also, the state would share in the savings if costs fall more than 5% below the target). Another form of risk sharing is specific stop loss, under which, if the costs for a specific enrollee exceed $150,000, the rest of the cost will be covered by a pool of funds contributed by all the MMCOs. Each MMCO will pay 1.25% of the monthly capitation payment into the pool. The final risk mitigation strategy was to allow plans to cap enrollment. This can only be done after March 31, 2007, and only if the MMCO shows that further enrollment would cause undue financial hardship and the MMCO agrees to cap all plan types.
As Patrick presented, some board members raised concerns about the contracts. Most significant was Celia’s concern about ensuring that all enrollees have adequate access to care. Patrick assured her that all plans must have a hospital within 15 miles or 30 minutes of all enrollees or have two open primary care sites. After Patrick’s presentation, the Board voted to approve the negotiated agreements with the MMCOs.
Closing comments
At the close of the meeting, Chip, who works with uninsured people in his regular job, told the story of a couple he had met recently. The husband worked, but his employer had stopped providing insurance. The wife got insurance through her employer, but when she was incapacitated, she lost both her job and her insurance. They were covered by MassHealth for a time, but when they began receiving social security payments, they lost their MassHealth eligibility, and they won’t be eligible for Medicare for two more years. But they will be eligible for Commonwealth Care, and Chip was able to tell them they could enroll in January. The husband was so happy he was in tears. Chip reminded the board that helping people like this is what Commonwealth Care is all about.
Eric Benson
