Action Alert – Submit Comments on the Bevin Administration’s 1115 Medicaid Waiver

As oral health advocates, we are counting on you to raise your voice by submitting public comments to CMS on the Bevin Administration’s 1115 Medicaid Waiver.

Recently, a federal judge halted implementation of the Bevin Administration’s 1115 Medicaid Waiver, also known as Kentucky HEALTH. The Bevin Administration is seeking re-approval of Kentucky HEALTH by the federal Centers for Medicare and Medicaid Services (CMS) before it can be implemented. CMS has opened an additional 30-day public comment period to ensure stakeholders have an opportunity to comment on the entire waiver, issues raised in the litigation, and the court’s decision, and they need to hear from you by August 18th.

As oral health advocates, we want to make sure the Bevin Administration’s 1115 Medicaid Waiver includes preventive and restorative dental coverage in the standards benefit package for the adult Medicaid population because it is a cost-effective measure to cover essential care.

If you are concerned about the impact the 1115 Medicaid Waiver could have on your family’s dental coverage, advocate for families who receive Medicaid benefits or want Kentucky to continue making progress in health and dental coverage and outcomes, submit your comments to CMS by following the instructions below.

Read the Bevin Administration’s full waiver proposal here. Read Kentucky Oral Health Coalition position statement regarding the inclusion of adult dental coverage here.

Steps to Make a Public Comment to CMS

STEP 1. Go to the public comment page. You can choose to enter your comments in the text box or attach a file with your comments.

STEP 2. Begin your comments with a couple of sentences describing who you are and why you are concerned about the proposed Medicaid waiver, known as Kentucky HEALTH. Example: “I am a father of two kids, and I need Medicaid to go to the dentist,” or, “I am a counselor at a school, and I know many of the kids who attend the school have parents on Medicaid.” If you are submitting comments as an organization, include relevant information about your organization.

STEP 3. Copy or modify some or all of the following talking points:

Re-approval of Kentucky HEALTH will eliminate dental coverage from the standard benefits package for many Kentucky adults’ Medicaid. Currently, Medicaid eligible adults have limited preventive and restorative dental coverage, which includes: exams, cleanings, x-rays, and fillings. Given our historic issues with poor oral health in Kentucky, we have made strides towards improvement in oral health by increasing access and preventive services. We as a Commonwealth cannot afford to move backward.

Receiving routine dental care allows for chronic disease management and early detection of chronic diseases that display symptoms in the mouth. The health of mouth impacts the health of the whole body — it doesn’t make sense to separate healthcare. After Medicaid expansion in 2014, over 100,000 more Kentuckians, mostly adults, received dental services than in 2013. Children also benefit when their parents have access to routine dental care. If parents have access to dental services, they will be likely to take their children, even if those services are covered under Medicaid or KCHIP. Dental care needs to be a partner in the management of chronic diseases for a healthier Kentucky.

Because I want Medicaid to work for all families in Kentucky who need it, I would like to see the following provisions be added or amended in the final 1115 Medicaid Waiver:

–Include dental and vision benefits in the standard benefits package instead of being classified as an earned benefit.

–Increase the dollar amount of My Rewards Account incentives for parents and pregnant women for activities such as prenatal visits or taking children for preventative dental visits. While the Bevin Administration added more activities for parents to the final waiver proposal submitted CMS, increasing the incentive dollar amount to be earned per activity would allow individuals to earn more dollars to spend on things like over-the-counter medications.

–Ensure Medicaid members have access to help if they have questions about their plan in person, by phone, and online. This includes having help available after regular business hours so parents who work during the day can get help in the evening in understanding their plan and the requirements they must meet to continue receiving Medicaid.

–Ensure there are a variety of ways for recipients to report changes that may affect their eligibility, and ensure they understand how to meet their obligations by offering help in person, by phone, and online. Offer that help after regular business hours so that parents who work during the day can get help in the evening.

The 1115 waiver proposal includes several provisions that protect vulnerable populations, and I would like for the final re-approval of the waiver to include those provisions. This includes exempting children and pregnant women from cost-sharing requirements; exempting primary caregivers of dependents up to age 18 from work and community engagement requirements; exempting former foster youth from the waiver; and maintaining the current Medicaid benefit package for children, pregnant women, and parents covered through SSA 1931.

STEP 4: You can also add a description of how premiums, a lock-out period, or reduced benefits could impact you, someone you work with, or your community.

STEP 5: If you are submitting your comments as a document, upload your file to the comment page. Whether you typed in the text box or uploaded a file, click “Finish” to submit your comments.