July 15, 2016 Dear Assistant Secretary Tsai: Thank you for offering a comment period on the draft 1115 Waiver Proposal to CMS. The work that you, your colleagues and the entire Governor Baker administration has taken with regards to this work is creative, smart, innovative and incredibly focused on the needs of the state's most vulnerable populations. We applaud you for these efforts and we very much look forward to partnering with you to bring this progressive vision to a successful reality. The table below contains our feedback. Please do not hesitate to reach out for any clarity you need on any of the below. Best Regards, Christina Severin President & CEO Section Number Waiver Content CCC's feedback Page number (of 92 pages) Executive Summary An MCO must demonstrate This option should also become 5 competencies and readiness in available for high-performing these areas before it takes on B ACOs. accountability for LTSS Section 3 Additionally, MassHealth will Can the consumer 21 establish an advocate and representative on our board member advisory group to participate in this group for ensure that members will have board education and an appropriate forum to development purposes? provide input to support design, implementation planning and roll-out. 4.1.2 All eligible members will enroll We believe this should read, 25 in a managed care option and eligible members will have “All select a primary care provider, the right and opportunity to as they do today. All eligible select their health plan and/or members will have the right and PCP”, since picking a Model B opportunity to select their ACO is picking his/her PCP, but health plan and PCP. not a plan”. “heath 4.1.4.1 These tools may include options We strongly desire for 26 to take on more advanced withholds to be available to 10 Gove St, East Boston, MA 02128 617-852-4709
July 15, 2016 Dear Assistant Secretary Tsai: Thank you for offering a comment period on the draft 1115 Waiver Proposal to CMS. The work that you, your colleagues and the entire Governor Baker administration has taken with regards to this work is creative, smart, innovative and incredibly focused on the needs of the state's most vulnerable populations. We applaud you for these efforts and we very much look forward to partnering with you to bring this progressive vision to a successful reality. The table below contains our feedback. Please do not hesitate to reach out for any clarity you need on any of the below. Best Regards, Christina Severin President & CEO Section Number Page number (of 92 pages) Waiver Content CCC's feedback Executive Summary 5 An MCO must demonstrate competencies and readiness in these areas before it takes on accountability for LTSS This option should also become available for high-performing B ACOs. Section 3 21 Additionally, MassHealth will establish an advocate and member advisory group to ensure that members will have an appropriate forum to provide input to support design, implementation planning and roll-out. Can the consumer representative on our board participate in this group for board education and development purposes? 4.1.2 25 All eligible members will enroll in a managed care option and select a primary care provider, as they do today. All eligible members will have the right and opportunity to select their health plan and PCP. We believe this should read, “All eligible members will have the right and opportunity to select their health plan and/or PCP”, since picking a Model B ACO is picking his/her PCP, but not a “heath plan”. 4.1.4.1 26 These tools may include options to take on more advanced We strongly desire for withholds to be available to 10 Gove St, East Boston, MA 02128 617-852-4709
appendix-c-public-comments.docx