DisAbility Rights Idaho (DRI) is the designated Protection and Advocacy agency for Idahoans with disabilities. We are concerned about the proposed §1332 waiver’s impact on people with disabilities who will be covered by Idaho’s Medicaid expansion.
Senate Bill 1204 directs the Idaho Department of Insurance to apply for a §1332 waiver to obtain Advanced Premium Tax Credit to purchase coverage on the Your Health Idaho insurance exchange instead of being automatically enrolled in Medicaid. Previous studies and estimates have concluded that Idaho’s expansion population will include many people with disabilities and chronic health conditions, including many people with serious mental illness. Your Health Idaho (YHI) exchange policies often fail to cover essential services for people with disabilities and chronic health conditions.
Mental Health coverage in YHI plans generally includes coverage of some psychiatric visits, short term hospitalization, prescription drugs, and a limited number of psychotherapy visits. These services will likely meet the mental health needs of most people. However, people with serious mental illness often need services covered by Medicaid but absent from private health plans. These services include:
- Adult Partial Care/Skills Training
- Skills Building/Community Based Rehabilitation Services
- Adult Peer Support
- Crisis Services
- Family Psychoeducation
- Behavioral Health Case Management
- Mental Health: Intensive Outpatient Services.
People with other chronic health conditions or disabilities may also need Medicaid services which are not included in YHI plans. These include long term services and supports like personal care services and Home and Community Based (HCBS) waiver services. There may also be differences in the pharmacy formularies of different providers which could impose a significant burden.
People in the expansion group would have the option of choosing Medicaid if they understand the differences in coverage. However, this waiver will create a significant risk of confusion. When the waiver is implemented, many people will be solicited by YHI plans to choose a policy on the YHI exchange. There is great risk of making a poor choice in these confusing circumstances.
If this waiver is implemented, it is essential that everyone receive an accurate description of the services and drugs covered in YHI versus Medicaid as well as the provider networks, and the premiums, deductibles and co-pays. The complexity of this information, and the individual differences in what individuals need, will make it very difficult to fully inform consumers of the consequences of their choice. If this waiver is granted, Idaho must commit to investing the resources necessary to educate and advise consumers, so that they can make an informed choice. Insurance carriers and agents must be required to provide complete and unbiased information that compares coverage, provider networks, premiums, deductibles, and co-pays to eligible people as it will affect each individual.
James R. Baugh, Executive Director