Your Comments Needed by June 13th: HCA Draft Waiver

Dear WCAAP Members,

The Washington State Health Care Authority has drafted a waiver application to the Centers for Medicare and Medicaid Services to expand coverage and access, advance whole-person care, and accelerate care delivery and payment innovation focused on health-related social needs. Information about this application can be found here: MTP renewal | Washington State Health Care Authority.

Today, we are writing to share some high points about this draft waiver application and urge you to comment on it.  To comment, please complete this online survey or email medicaidtransformation@hca.wa.gov before June 13 at 5pm.

The draft waiver application shares the WCAAP’s top goals of behavioral health integration in primary care (or providing “whole person” care) and addressing families’ social determinants of health (SDoH).

The draft waiver includes three proposals that are outright wins for children, teens and families:

1. Continuous Medicaid enrollment for children 0-6 years of age.
2. 12-months post-partum Medicaid coverage — one of WCAAP’s highest priorities and big wins of the 2021 state legislative session. The waiver proposal would draw down federal funds for this coverage.
3. Ensuring that youth aged 16+ are eligible for supportive housing.

Our concerns about the draft waiver include:

• It fails to call out, draw upon, specify or bolster primary care’s instrumental role in prevention, screening, early intervention and supports for SDoH.

• It speaks to the importance of Community Health Workers, and seeks additional federal investment for the currently state-funded Community Health Worker pilot the WCAAP was able to help pass this year, but does not describe how roles like these will be incorporated into primary care payment transformation or value-based payment in the future.

• It proposes electronic infrastructure to support SDoH and “closed loop referrals” to care and services – which we applaud; although  the idea of 10 different regions to implement such infrastructure concerns us.

• While “whole person” care is one of the top goals of the draft waiver, the application does not describe approaches to serve the unique needs of children and teens, investment adequate to build behavioral health integration in primary care for kids, or intent to improve a spectrum of behavioral health care services for kids.

We urge you to comment on the draft waiver application. When many of you act your voices can be powerful.

Sample comments (please tailor to your own voice and priorities):

Thank you for including Continuous Medicaid enrollment for children 0-6 years of age and 12-months post-partum Medicaid coverage. Access to high quality preventive care in the first years of life and postnatally can impact health through a child’s entire life course.

Thank you for including youth aged 16 and older for supportive housing given the massive challenges some Washington youth face.

Please increase the waiver application’s focus on prevention and primary care to improve health outcomes across the lifespan, and accordingly direct investments toward prevention.

For some patients and families, especially those with limited education or limited English, navigating needed resources and accessing and mental health care can be insurmountable tasks. Thank you for including Community Health Workers in this draft waiver application; please do all you can to make this an ongoing part of Medicaid for kids in Washington.

Please increase investments in this application to help build behavioral health integration for kids – such as IT support to monitor kids’ engagement in care and outcomes, training in evidence-based interventions for kids, and IT support to seamlessly communicate between primary care and specialty care.

Pediatric health care providers need adequate infrastructure to help patients get the resources they need and to follow up on patients who needed help. The draft waiver application seems to seek investments to make this a reality. Please seek timely, seamless approaches– that allow electronic exchange of information between pediatric health care providers and community social service agencies for health care providers to have a uniform way to support our patients’ SDoH across the state.

Thank you for your membership in the WCAAP. We hope this information is helpful and that you are able to take the time to comment to the HCA.

The WCAAP will continue to work closely with the HCA to do all we can to advance care for Washington kids. Thank you for being part of our work. 

Sincerely yours,

Sarah Rafton, MSW
Executive Director