Press Remarks by Don Hazaert on the Essential Health Benefits
First, let me thank the members of the press for joining us on this afternoon’s call to discuss the state of Michigan’s recommended benchmark for an Essential Health Benefit plan for the private insurance market in Michigan. My name is Don Hazaert and I am the director of Michigan Consumers for Healthcare. Joining me on the call is Karlene Ketola the director of the Oral Health Coalition. Also on the call to assist in answering your questions is Ryan Sullivan who is policy staff for Michigan Consumers for Healthcare.
The Essential Health Benefit- or EHB package- of the Affordable Care Act serves as every American’s guaranteed right to meaningful coverage. It serves essentially as a floor of benefits that all private health insurance policies sold in the state must include, regardless of whether they are sold inside or outside of the healthcare exchange. This makes selection of an EHB plan vitally important, and, in a perfect world, something that would have involved very significant consumer stakeholder participation and input. Regrettably, that was not the case this time around. But, the good news is, two years from now we get a second chance at doing it the right way.
The plan the State is recommending will only be in place for two years after which time the EHB package of benefits must be reevaluated. The state of Michigan’s position is they did not have sufficient time or information to establish a stakeholder process or give consumers more than just a two week public comment period on their EHB plan selection recommendation. But, with a two year lead up, that certainly will not be the case next time. Consumer expectations will be much greater in 2014 for the State to develop a thoughtful, transparent stakeholder process that allows for a meaningful debate on what our citizens’ essential health benefit needs actually are.
We are concerned that state officials, in explaining their selection criteria, cited plan cost as their primary consideration. As we all experience in our everyday lives, the least expensive choice is not always the best choice. This is particularly true in something so life-and-death important as the quality of your health insurance.
The consumer comment period on the State’s EHB recommendations ends in just 2 days. For consumers who would like to weigh in on the conversation, they may visit our website at consumersforhealthcare.org where we provide information, analysis and a pre-drafted template letter to help get them started.
The comment letter that will be submitted by Michigan Consumers for Healthcare will express, amongst other things, concern that the selected plan appears not to meet statutory mental health parity requirements under the Affordable Care Act. The ACA does not allow plans to discriminate on the basis of mental vs. physical health. The State recommended plan clearly does discriminate by putting limits on mental health services. Therefore, it is unclear to us how the State intends to resolve that problem. Likewise, it is unclear how the state will supplement for habilitation services, which is mandated coverage under the ACA but is not covered in the selected benchmark.
In our opinion, the focus of any final recommendation should be on improving benefits and developing comprehensive coverage that fills the gaps that have historically existed. The State recommended plan, for example, limits end-of-life hospice care to just 45 days. The obvious question one must ask is, what happens if the patient does not pass away within the 45 day limit? Will the patient then be forced back into a hospital setting where care costs will be substantially higher? Benefit limits, in many instances, are counter-productive to efforts to meet the essential needs of consumers and to restrain costs.
The next time around consumers will demand a more meaningful stakeholder process that allows public debate on not just how to meet the minimum mandated requirements of the ACA but also what optional services should also be considered for inclusion. A robust, vibrant public debate is going to inevitably result in a more representative EHB benefit package than a plan developed in relative isolation and treated as essentially an administrative function.
To illustrate our point that coverage determinations should be publicly and robustly debated, we are being joined on the call by Karlene Ketola the director of the Oral Health Coalition to discuss why the State should consider a bigger picture approach to designing an Essential Health Benefit package and consider adding non-mandated coverage such as adult dental coverage.