To the editor,
The R.I. Department of Human Services and Gov. Donald L. Carcieri propose to save $46.6 million in fiscal year 2009 by re-balancing the state’s long-term-care delivery system, as outlined in a paper, “The Rhode Island Global Consumer Choice Compact Proposed Waiver” that DHS sent to the U.S. Centers for Medicare & Medicaid Services (CMS) on March 26.
Rhode Island’s proposed global waiver is designed similarly to Vermont’s Long-Term Care Plan Waiver, which was granted by CMS in 2005.
A study of Vermont’s waiver was conducted by the Kaiser Commission on Medicaid and the Uninsured in April 2006. According to the Kaiser study, “If federal Medicaid spending were to grow nationwide at the same rate allowed in Vermont … it would cost the federal government an additional $105 billion over five years and a third of a trillion dollars over 10 years.”
In essence, the global waiver would make Rhode Island a managed-care organization. The state would create an “Assessment and Coordination Unit,” which would be comprised of state employees who would conduct assessments that would restrict the choice of care settings for the consumer.
The state proposes to create three levels of care: highest, high and preventive. The detail of eligibility for each level is not clearly defined in the document, although it is clear that in some cases patients may be denied benefits they require. For example, individuals with a high nursing home level of care do not have the option of receiving care in a nursing home. According to the waiver proposal, “Rhode Island’s program redesign is based on the assumption that community-based services will result in improved health, quality of life and cost-effective care.”
In addition, those choices would not save the state anything, because current law requires that any money saved via reductions in nursing home utilization must be spent in equal amounts on home and community-based services.
The global waiver also poses a risk to Medicaid beneficiaries. If Rhode Island reaches its funding cap, it no longer will be able to share the burden of additional costs with the federal government, making it more likely that the state will use its authority to cut back on coverage for beneficiaries.
The document submitted by the state requests waivers from certain provisions of Title XIX (Medicaid) that would allow it to “restrict the amount, duration and scope of services included in a plan … [and give it] the authorization to expand cost-sharing requirements above the 5-percent-of-income threshold for beneficiaries of certain population,” among many other provisions.
The governor proposed that the savings of $46.6 million would be gained by transferring current nursing home residents into alternative-care settings, but existing law requires that any dollar saved via less occupancy in nursing homes would need to be spent in equal amount on home and community-based services. As a result, this plan yields no savings for Rhode Island.
Despite the governor holding up the Green Mountain State as an example of what to do regarding Medicare and Medicaid expenses, we cannot afford to be like Vermont.
Kathleen M. Lavallee, administrator, The Episcopal Housing Foundation of Rhode Island
