The Devil’s in the Details: Connector Hears Testimony on CommCare Eligibility Regs

This morning, Jamie Katz, the Connector’s General Counsel and Melissa Boudreault, Director of Commonwealth Care, heard testimony on changes to the Commonwealth Care eligibility regulations (click here for regs). Some of the revisions, although deemed by the Connector as technical and stylistic, will make a real difference for folks who are enrolling in or trying to maintain CommCare coverage.

Jamie Katz and Melissa Boudreault heard testimony from two panels. Lindsey Tucker, Nancy Lorenz (GBLS) and Neil Cronin (MLRI) testified on behalf of the ACT!! Coalition.

The ACT!! panel urged the Connector to:

• Keep eligibility requirements for CommCare as broad as possible, especially for those who are eligible for the new COBRA subsidy under ARRA, to minimize gaps in coverage;
• Clarify and improve the payment plan and hardship waiver process;
• Provide aid pending appeal of a denial or termination decision and allow for corrective action to rectify the situation;
• Ensure that individuals who are auto-enrolled be assigned to the same health plan in which they were previously enrolled within a look-back period of no less than 90 days;
• Strengthen consumer protections; and
• Align coverage effective date with the date of enrollment.

In addition to the technical comments, Nancy shared a story about a client who had experienced gaps in coverage and difficulties with the payment plan and hardship waiver processes. Click here (pdf) to view ACT!!’s written comments, which were drafted by Mass Law Reform Institute.

Lorianne Sainsbury-Wong from Health Law Advocates introduced a panel including three past and present CommCare members affected by the eligibility regulations. Lorianne stated that many of her clients – included the individuals speaking on the panel – have difficulty paying their CommCare premiums. The common theme in each client’s story is that they had difficulty with the hardship waiver process, and they called for the need to broaden the criteria for being granted a hardship waiver. Melissa Boudreault and Jamie Katz were very receptive to each panelists’ comments. In fact, Melissa was very appreciative of the members’ testimony and said it was the most valuable to hear from real members.

The Connector Board is expected to vote on the final regulations at their June 11th meeting.
-Suzanne Curry