June 12, 2017 Kaela Konefal EOHHS Office of Medicaid One Ashburton Place, 11th Floor Boston, MA 02108 us Re: Comments for Demonstration Amendment I am writing to you today to urge you to not include the waiver of the requirement for NEMT transportation as part of the Medicaid plan for the Commonwealth. NEMT is a necessary transportation service available to individuals who have no other option to get to follow up appointments, dialysis, and therapies. It is an option that is a pati of a family of service options a community can provide holistically. If one option, especially one that is vital to health survival, is isolated and removed, the whole cannot work effectively ·for the individual, the family, or the community. This solution is a self-centered financial solution that does not consider detrimental personal or program outcomes. Medicaid NEMT is the largest of the non-FTA programs, surpassing many of the Federal Transit Administration programs. If this NEMT waiver is granted, CMS will have the ability to operate independently from all other federal agencies and departments providing transportation options and will not work cooperatively within the holistic system. This will create a financial burden for the rest of the 80 programs that currently share the responsibility. This shift will cause confusion, hardship, and is not a part of the good faith process already being realized through the Coordinating Council on Access and Mobility (CCAM). If programs like yours begin to take matters into their own hands without considering impact, we will end up with a patchwork of broken options that will never fully serve the community or the individual. People who need health care transportation will end up with no resources. I would hope that you could as least hold off a decision until the CCAM completes the federally mandated strategic planning process. I would also hope you would press the CCAM to study the potential impact of such a decision. Separately we can serve a few, together we can move communities to better health. Best regards, Kristen Joyner Executive Director South West Transit Association
June 12, 2017 Kaela Konefal EOHHS Office of Medicaid One Ashburton Place, 11th Floor Boston, MA 02108 us Re: Comments for Demonstration Amendment I am writing to you today to urge you to not include the waiver of the requirement for NEMT transportation as part of the Medicaid plan for the Commonwealth. NEMT is a necessary transportation service available to individuals who have no other option to get to follow up appointments, dialysis, and therapies. It is an option that is a pati of a family of service options a community can provide holistically. If one option, especially one that is vital to health survival, is isolated and removed, the whole cannot work effectively ·for the individual, the family, or the community. This solution is a self-centered financial solution that does not consider detrimental personal or program outcomes. Medicaid NEMT is the largest of the non-FTA programs, surpassing many of the Federal Transit Administration programs. If this NEMT waiver is granted, CMS will have the ability to operate independently from all other federal agencies and departments providing transportation options and will not work cooperatively within the holistic system. This will create a financial burden for the rest of the 80 programs that currently share the responsibility. This shift will cause confusion, hardship, and is not a part of the good faith process already being realized through the Coordinating Council on Access and Mobility (CCAM). If programs like yours begin to take matters into their own hands without considering impact, we will end up with a patchwork of broken options that will never fully serve the community or the individual. People who need health care transportation will end up with no resources. I would hope that you could as least hold off a decision until the CCAM completes the federally mandated strategic planning process. I would also hope you would press the CCAM to study the potential impact of such a decision. Separately we can serve a few, together we can move communities to better health. Best regards, Kristen Joyner Executive Director South West Transit Association
comments-received-for-section-1115-demonstration-amendment-request.docx