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The Alliance of Community Service Providers Testimony to The Pennsylvania Department of Public Welfare on Healthy Pennsylvania January 3rd,

2014 National Constitution Center Philadelphia, PA The Alliance of Community Service Providers, previously known as The Philadelphia Alliance, is pleased to submit testimony on the proposed Healthy Pennsylvania plan today. The Alliance is a non-profit trade association of 54 private provider organizations who provide mental health, addiction treatment and intellectual disAbility services to children and adults. The Alliance brings a wealth of experience providing services to the behavioral health population. As such, we know that to maintain a cost effective health system which also produces positive health outcomes, we must ensure ease of access to appropriate behavioral health services for those who need them. The most impactful step we can take in achieving this goal is the expansion of Medicaid. The National Association of State Mental Health Program Directors estimates that 40% of the expansion population will have some type of behavioral health need. As such, we applaud the administration for taking this first step towards insuring more than a half million Pennsylvanians in need of health care. Though we at The Alliance support the expansion of Medicaid, we have concerns about several provisions in this plan and how they will impact individuals with behavioral health conditions. In particular, we are concerned with the increased administrative burden this poses for County Assistance Offices, the screening process for individuals with disAbilities, and the proposed reductions to our current benefit package. In particular, we are concerned with the following five components of the plan: 1. Healthy Pennsylvania creates significant administrative red tape and barriers with its work search requirements, premium requirements, and screening for various levels of eligibility. We are concerned about the cost of this, the burden on our already understaffed CAOs, and the impact on current Medicaid enrollees, many of whom are already wrongly denied health benefits due to our understaffed and underfunded CAO system. 2. Healthy Pennsylvania reduces current Medicaid benefits to be more commercial like. This is deeply problematic for individuals with behavioral health conditions as commercial plans do not offer robust enough benefits to meet the needs of even someone with a moderate behavioral health condition. In fact, Medicaid has often acted as a safety net insurance for individuals with behavioral health conditions when their private insurance fails to meet their needs. Unfortunately, in the Healthy Pennsylvania plan, even the High Risk Alternative Benefit Package contains more stringent mental health and addiction treatment visit limits than what is currently offered through Medicaids

behavioral health benefit. Reducing benefits will hurt people with disAbilities who need these services to lead healthy lives in the community. 3. Healthy Pennsylvania proposes changes to the current capitation rate based on premiums many individuals will be unable to pay. This will hurt providers and our health infrastructure in Pennsylvania with reduced rates. 4. Premiums and work search requirements are unnecessary and punitive. 75% of expansion eligible households in Pennsylvania have at least 1 working household member. Additionally, Healthy Pennsylvania proposes requiring premiums of individuals earning less than $6,000 annually. Additionally, as the plan is currently phrased, it would seem that these requirements apply to some medically fragile individuals. These expectations are unrealistic and will result in the loss of health coverage for some of our most vulnerable citizens. 5. The Medically Frail and High Risk vs Low Risk Benefit screenings will create barriers to care for those who need it most. Healthy Pennsylvania does not provide a copy of the health assessment which must be completed to determine medically frail, high risk, and low risk eligibility. However, this screening must create easy access to higher levels of care for Pennsylvanians with disAbilities. Additionally, the plan states that if the screening is not completed, current enrollees will default into the low risk plan. Many of our most disabled citizens will be less likely to fill out the screening, and this default setting will result in inaccurate placement of many disabled Pennsylvanians in the low risk group. While we applaud efforts to increase health access in Pennsylvania, these efforts must not hurt current beneficiaries, particularly those living with a disAbility. We thank you for allowing us to share our knowledge base with you and look forward to working together to create a system which ensures a Healthy Pennsylvania for all of our citizens.