Public
comments from the CT Health Policy Project raise deep concerns about SIM’s
proposal for Medicaid reform requirements could undermine hard-won successes in
the program and may not achieve the goals. The Community and Clinical
Integration Plan (CCIP) is SIM’s plan for community-based resources to support
Medicaid advanced networks that will be sharing in savings under the evolving
reform plan. While CCIP’s goals, to promote health equity among others, are important,
independent advocates and other stakeholders have expressed concerns about the
plan. The CCIP proposal imposes substantial costs on Medicaid provider networks
without any source of funding. CCIP’s 66 pages of standards are too
prescriptive in some places and too vague in others, creating a very large burden
for already busy providers and undermining innovation and flexibility to serve
local conditions. Consumers could get conflicting advice on how to manage their
conditions from different sources. No evidence is given to support the
effectiveness of CCIP’s standards. Unlike successful states, SIM is proposing
that CCIP standards be required of Medicaid networks. However networks that don’t
serve Medicaid members will not be affected. The proposal to have SIM and their
vendor oversee the standards is also a concern. Because of a loophole in the
law, SIM is not subject to the State Code of Ethics;
concerns
have been raised about SIM grants being awarded to SIM committee insiders
in the past. Advocates and other stakeholders are urging delay allowing
Medicaid stakeholders to consider the evidence, ensure CCIP is feasible, and ease
the burden on providers.
