Community Health Network of Washington (CHNW) is the community health center (CHC) based provider network for Community Health Plan of Washington (CHPW), the only not-for-profit Medicaid managed care plan that operates solely in Washington State. Together, we are committed to ensuring access to care for our members and CHC patients statewide and implementing innovative integrated programs in the delivery system.
We are committed to federal health care reform. The recent efforts to repeal and replace the Affordable Care Act (e.g., the American Health Care Act and the Better Care Reconciliation Act) would have taken us backwards in the gains we have made, including expanding Medicaid coverage to more than 600,000 Washingtonians and affordable insurance coverage to more than 200,000 Washingtonians who have qualified health plans (QHPs) purchased on the Health Benefit Exchange. There is more work to be done to ensure that every resident has affordable and stable coverage, but this cannot be done by taking away health care to hundreds of thousands of people in this state.
CHNW also supports the following legislative priorities:
- Provide Long-Term Funding for the Children’s Health Insurance Program, the Community Health Center Fund, the National Health Service Corp, and the Teaching Health Center Graduate Medical Education program
- Permanently Authorize Medicare Advantage Dual-Eligible Special Needs Plans and Assure Their Sustainability
- Eliminate Regulatory Hurdles to the Delivery of coordinated Car Services to People with Substance Use Disorders
- Ensure Marketplace Stability
Provide Long-Term Funding for the Children’s Health Insurance Program, the Community Health Center Fund, the National Health Service Corp, and the Teaching Health Center Graduate Medical Education program
At the end of September, Congress let funding lapse for the Children’s Health Insurance Program (CHIP), Community Health Center Fund (CHC Fund), the National Health Service Corp (NHSC), and the Teaching Health Center Graduate Medical Education (THCGME) program. These are critical programs that help fund services to our members and directly support our CHCs and their ability to provide services to the uninsured or underinsured in our communities.
- In our state, 58,000 kids get health coverage through CHIP. Over the last 10 years, Washington has made great strides in making sure kids have access to care and CHIP coverage is an essential part of this. The uncertain fate of CHIP funding jeopardizes the successes we have achieved
- Funding from the CHC Fund helps our CHCs care for more than 165,000 uninsured Washingtonians. While our state has made great strides in enrolling eligible Washingtonians in Medicaid and qualified health plans, about 6% of Washingtonians remains uninsured. Often, they have nowhere else to go other than a CHC. Our CHCs need these vital federal funds to serve all that need care.
- Our CHCs and other safety net providers use programs like NHSC and THCGME programs to recruit, train, and retain the essential health care workforce (e.g., doctors, nurses, pharmacists, dentists, mental health professionals, etc.) needed to serve our low-income residents. These providers are the backbone of our safety net care delivery system.
We ask Congress to pass the CHAMPIONING HEALTHY KIDS Act, HR 3922.
The Medicare Advantage Dual-Eligible Special Needs Plans (D-SNPs) serve Americans who are enrolled in Medicare and Medicaid — “dual eligible.” They represent some of the poorest, sickest, and costliest beneficiaries in both programs and often fall through the cracks between Medicare and Medicaid. In 2003, Congress created the D-SNP program to improve coordination of care for dual eligible through health plans.
We urge Congress to:
- Permanently authorize the Dual-Eligible Special Needs Plans (D-SNP) program. They are currently authorized through the end of 2018. Congress should make the program permanent by passing the D-SNP provisions in the CHRONIC Care Act of 2017, S 870;
- Improve the Medicare Advantage Star Rating program by adjusting for dual eligible status and comparing D-SNPs to D-SNPs; use appropriate health plan quality measures that consider the needs for full-benefit dual eligible with complex health, behavioral, and cognitive conditions and whose care is affected by socioeconomic challenges;
- Unifying the Medicare and Medicaid grievances and appeals processes applicable to D-SNPs; and
- Designate the Medicare-Medicaid Coordination Office as CMS contact to assist stats with D-SNP Medicare-Medicaid misalignments.
Those who suffer from substance use disorder (SUD) and go untreated are among the highest utilizers of health care services, requiring twice as much health care as those being treated for the same disorders. Unfortunately, outdated federal regulations that predate current models of car create significant barriers to holistic care for people with SUD. Those barriers – found in 42 CFR Part 2 and requiring individualized and specific patient consent before providers and plans can disclose a SUD to coordinate care – undermine efforts to integrate behavioral and physical health services for people with SUD, ultimately leading to worse health outcomes.
We request that Congress support legislation creating a narrow statutory exception to the 42 CFR Part 2 requirement for individualized consent for health plans that operate in Medicaid, CHIP, D-SNPs and those that operate as QHPs in the health insurance marketplace. The sole purpose of this narrow exception would be to allow the flow information that is necessary to foster care coordination, provide proper treatment, promote patient safety, make payment, and ultimately, improve the individual’s health status. Under this exception, existing privacy and security requirements would apply to protect sensitive health information form any other use, including the initiation or substantiation of criminal charges. All other requirements of 42 CFR Part 2 that serve to protect a member’s SUD treatment records that have been shared for the narrow purposes of care coordination, treatment, patient safety, and payment would continue to apply. Congress should support the Overdose Prevention and Patient Safety Act, HR 3545.
Cost sharing reduction payments, enforcement of the individual mandate, and comprehensive and affordable coverage for consumers all contribute to a stable marketplace. We ask Congress to:
- Appropriate funds consistent with section 1402 of the ACA (cost sharing reduction payments);
- Enforce the current mandate or institute another equally-effective combination of policies (“Evaluation of Alternatives to the Individual Mandate” finds that repealing or changing the individual mandate must consider ramifications to the risk pool and premiums. It is likely only a combination of policies and greater government expense could produce similar risk pool effects to the current mandate.)
- Support proposals that advance coverage in the individual market that is both comprehensive and affordable. Examples of this include changing the age rating bands from 3:1 to 5:1 (it allows issuers to offer lower-priced options to young enrollees, thus improving the risk pool). However, this change must be coupled with a tax credit structure by both age and income so not to adversely impact older, poorer adults. Likewise, coverage should truly be meaningful (i.e., not repealing the essential health benefits). Similarly, short-term, limited-duration plans do not offer adequate coverage.