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Comments to OMAP for PH 95 MA Co-payment
August 17, 2012

On August 11 the Department of Public Welfare (DPW) announced its intent to amend the Medicaid State Plan and apply co-payments to services provided to certain Medical Assistance (MA) eligible children with disabilities. Co-payments will be applied for MA behavioral health and pediatric services provided to children with disabilities whose household income is above 200 percent of the federal poverty level. The notice is at www.pabulletin.com/secure/data/vol42/42-32/1551.html.

Community behavioral health and primary health care providers and families are being strongly encouraged to submit comments to DPW identify questions, concerns, and recommendations for implementation of these co-payments.  In addition to self-identified concerns and recommendations, topics to consider for inclusion follow.

  • The August 11 notice published by the state provides no information about how the co-payments will be applied in HealthChoices so timely provision of comments in cannot be reasonably expected.
  • The notice provides no information about how co-payments and coordination of benefits will be applied in HealthChoices to families that also have private coverage under the Autism Insurance Act.
  • The implementation of a point-of-service co-payment collection system in a behavioral health system where many child and adolescent services are delivered in schools, communities, and homes is extraordinarily problematic.
  • The implementation of a point-of-service co-payment collection system where payment would need to be collected by treatment staff is detrimental to the therapeutic relationship.
  • The implementation of a point-of-service co-payment collection system or a post-service billing and collection process will be prohibitively expensive for providers.
  • The implementation of a co-payment charge and collection system using the time delayed and inaccurate Electronic Verification System will result in numerous and expensive billing errors and disputes.
  • The notice does not describe a mechanism for families and health care providers to address and resolve disputes regarding Medicaid charges or co-payments.
  • PCPA and several counties have recommended that the process of service aggregation (all physical health and behavioral health procedures) related changes and billing should be centralized and administered by the Office of Medical Assistance Programs (OMAP) or its contracted agent to maximize efficiency, minimize errors, and ensure uniformity of administration and conflict resolution in this complex process.

Submit written comments to:
Pennsylvania Department of Public Welfare
Office of Medical Assistance Programs
c/o Deputy Secretary's Office
ATTN: Regulations Coordinator
Room 515, Health and Welfare Building
Harrisburg, PA 17120

Comments must be submitted by September 10. Please send a copy of comments to Connell O’Brien (connell@paproviders.org). Organizations should consider communicating comments to local legislators and county leadership.

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