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AARP Kentucky Comments -- Public Hearing: Kentucky HEALTH 115 Waiver

Scott Wegenast, Associate State Director for Advocacy and Outreach with AARP Kentucky

AARP Kentucky Comments – Public Hearing: Hazard, Kentucky  Kentucky HEALTH 1115 Waiver Application

Good morning.  My name is Scott Wegenast, Associate State Director for Advocacy and Outreach with AARP Kentucky.  I appreciate the opportunity to comment on the proposed Kentucky HEALTH 1115 Waiver application, and to specifically express our concerns about the proposed changes for Medicaid and the possible negative impact the changes could have to the 1.2 million Medicaid beneficiaries in the state.

AARP is a nonprofit, nonpartisan organization, with a membership of nearly 38 million, that helps people turn their goals and dreams into real possibilities, strengthens communities and fights for the issues that matter most to families such as healthcare, employment and income security, retirement planning, affordable utilities and protection from financial abuse. We seek to help older Americans live long and healthy lives. AARP Kentucky, representing 460,000 members, is Kentucky’s largest organization representing the needs, views, desires, and hopes of Kentuckians 50 and older.


AARP members age 50 to 64 often struggle to qualify for or afford quality health insurance coverage. AARP believes everyone should have access to affordable health care.  Indeed, since Kentucky’s Medicaid Expansion occurred in 2014 an additional 428,000 low income adults have gained access to healthcare, with an overwhelming share of the cost assumed by the Federal Centers for Medicare and Medicaid Services.

And as you can imagine, the issue of healthcare coverage is particularly important to individuals who are over age 50 and not yet eligible for Medicare.  These middle-aged adults have been particularly hard hit by the economic downturn in recent years, often experiencing unemployment for longer periods than their younger counterparts, or struggling in jobs that don’t offer health coverage.  This lack of coverage comes at a critical time when people are beginning face the onset of health conditions that if left untreated could inevitably increase their need for and use of health and long-term care in the future.  Expanding Medicaid has given Kentuckians without insurance access to preventive care that can save lives, and has eased dangerous and expensive emergency room overcrowding that hurts all of us.

Helping Kentuckians maintain access to health coverage should be a top priority for Kentucky, but there are several elements in the Kentucky HEALTH waiver that should be altered to better achieve this goal.  We urge the state to modify the following key areas before a final waiver application is submitted to CMS:

Member Cost Sharing

As proposed, the new waiver premiums would be instituted for beneficiaries, based on income and ranging from $1 to $15 for the first two years, and rising higher thereafter. Although exempting some groups such as pregnant women and children is an important protection for some of the most vulnerable participants in Kentucky, we are concerned that the proposed monthly premiums could still result in reduced access to needed care or create undue service barriers. Premiums for those with extremely low incomes forces stressful financial decisions on individuals and families who are already having trouble making ends meet, pitting a desire to maintain health coverage against other essentials each month.

The required monthly premiums are made more problematic by the proposal that some participants who fail to pay the premium within 60 days be terminated from the program until overdue premiums are paid.  This proposal would be a significant departure from the traditional Medicaid program, in which failure to pay point-of-service co-pays does not result in complete termination of enrollment in the program.  The coverage gaps created by terminating enrollees will lead to added uncompensated care costs for providers, inability of health plans to manage care over time, and poorer health outcomes for enrollees that will be more expensive to treat later.  Taken together, the monthly premium requirement, coupled with the termination provision will create a sizable barrier to access, participation, and continuity of care.  This is especially the case for those who are newly eligible for coverage and therefore may have “pent up” needs for health care.   As such, we urge the Department to reconsider premiums as a requirement for participation in the plan and eliminate termination of coverage as a consequence for failure to pay monthly premiums.

Community and Engagement Requirements

Under the proposed Kentucky HEALTH plan, all able-bodied working age adult members without dependents will be required to participate in the Community Engagement and Employment Initiative to maintain enrollment.  Engagement activities include volunteer work, employment, job training, or job search activities. Failure to meet required engagement hours will result in a suspension of benefits until the member satisfies the requirement for a full month.

AARP is concerned that the Community Engagement and Employment Initiative requirement presents yet another barrier to health coverage for a sector of the Kentucky population that needs coverage the most.  While we are pleased that the plan does allow for individual exemptions from the Community Engagement requirement, such as for children, pregnant women, individuals determined medically frail, and adults who are the primary caregiver of a dependent, there is little information provided on how these exemptions would be administered.  This is problematic because those enrollees who will most likely need individual exemptions are also likely to be those who will have the most difficulty taking the necessary steps to obtain an exemption.

As with monthly premiums, participants who do not comply with the Community Engagement and Employment Initiative would be terminated from Kentucky HEALTH.  The member will have no coverage until the beneficiary satisfies the requirement for a full month, resulting in added uncompensated care costs for providers and poorer health outcomes for enrollees that will be more expensive to treat later.  For these reasons, we urge the Department to remove the Community Engagement and Employment requirement as a condition of eligibility in the Kentucky HEALTH plan.


AARP thanks you for the opportunity to share these brief comments, and AARP will express additional, more comprehensive concerns during the written comment period.   We encourage the Department to build upon the positive impact Medicaid Expansion has brought to Kentucky since 2014, and to resist additional barriers to care that will do little to address the needs of vulnerable, low-income Kentuckians.

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