Response to Public Comments
SCDHHS received approximately 90 comments related to Medicaid reimbursement changes since June 7. Staff members either sent a personal email response or contacted by phone every individual who submitted a comment. Below is a summary of responses to the most frequently received comments.
General comments about reductions:
SCDHHS must make significant cost reductions in order to stay within appropriated funding levels during State Fiscal Year 2012. The agency has worked closely with provider groups and other stakeholders in developing a comprehensive cost reduction plan that will reduce Medicaid spending by approximately $125 million (state dollars). In addition to reimbursement changes, cost savings initiatives include increased beneficiary contributions through co-payments, quality improvement strategies, increased fraud and abuse enforcement and the elimination of duplicative efforts. We will be monitoring beneficiary access to care to ensure these changes do not have a detrimental impact on those who rely on Medicaid.
Dental rate reduction:
Dental health is an important goal of DHHS and is proud of its work with the South Carolina Dental Association, which has resulted in an “A” rating in oral health from the Pew Center on the States. Dental rates will be reduced an aggregate of 3%, with lower reductions assigned to preventive dental services.
Emergency room physician rate reduction:
A 5% reduction for emergency services will take effect in July. While comments indicated reductions for ER physicians should be equal to those for primary care physicians because of the large number of non-emergent visits seen in the ER, SCDHHS believes emergency room usage for routine, non-emergent care must be discouraged. SCDHHS is convinced that inappropriate use of the emergency room is a multifactorial problem that must be solved working closely with hospitals, ER physicians, primary care physicians, Medicaid Managed Care and Medical Homes Networks, health centers and patients.
Increased Beneficiary Co-payments:
Co-payments for some beneficiaries for routine services such as doctor appointments will increase from $2.30 to $3.30 in July. The decision to increase co-payments was partly based on public comments urging greater shared responsibility for sustaining the Medicaid program. The department has also received feedback from physicians that patients who contribute to the cost of care-even small amounts-view themselves as consumers rather than beneficiaries and more actively engage in their care and demand better service. SCDHHS will monitor this change to ensure beneficiaries are not deterred from seeking needed care.
Reductions for oncologists:
Pediatric oncologists will receive a rate reduction of 2% while adult oncologists will receive a 5% reduction. While chemotherapy related drugs were reduced by 3% on April 8, 2011, these and other physician administered drugs will not receive an additional cut as part of the July reduction.
Hospital reductions:
In order to ensure access to care for rural Medicaid recipients, SCDHHS has exempted the following hospital categories from reductions listed in the public notice: qualifying burn intensive care unit hospitals, critical access hospitals, and hospitals located in areas with Rural/Urban Commuting Area designations of isolated rural and small rural. In addition, as a result of further analysis and public comment, hospitals operating in areas with a Rural/Urban Commuting Area designation of large rural AND designated as a “Primary Care Health Professional Shortage Area (HPSA) for the Total Population” will also be exempt from these reductions. See the FAQ section for a complete list of exempt hospitals.
ICF-MR reductions:
Working with the SC Department of Disabilities and Special Needs (DDSN) and stakeholders, SCDHHS will reduce overall Medicaid expenditures in DDSN by means other than the 3% ICF-MR rate reduction indicated in the original notice.
Differences between school-based and private therapies:
Unlike other Medicaid therapies, the state portion of school-based therapy costs is matched with education funds. Treatments in school settings are regulated and federally mandated under the Individualized Education Program (IEP). SCDHHS is continuing to investigate the best means of ensuring the high quality delivery of therapies in school and non-school settings in a cost effective manner.
Labor and Delivery reduction:
Physician fees for C-Sections will be reduced from $1,164 to $1,000 per delivery; vaginal deliveries will be reduced from $1,164 to $1,100. Based on local and national data and discussions with hospitals and physicians in South Carolina, the SCDHHS believes that payment policy and convenience have led to a rapid growth of medically unnecessary C-Sections in South Carolina and the United States. SCDHHS is partnering with hospitals, OB/GYNs, MFMs and neonatologists on a new comprehensive initiative to improve birth outcomes for Medicaid enrollees and reduce overall costs, and is also working closely with physicians to develop a global delivery rate. OB/GYNs, MFMs and neonatologists did not receive additional reductions.
Comments received through the comments@scdhhs.gov email address.
In response to the following:
Comments have been formated as close to original as possible.
Some comments received were not published due to HIPAA privacy concerns. » Read more: Comments on July 11th changes
