IN PERSPECTIVE:

FREE-CARE CHANGES

Joe Ianelli, Manager of Patient Financial Services/Financial Access Unit (who happens to be a professional social worker) , addressed social service staff at our October 28, 2004 staff meeting. As Joe noted, the final Uncompensated Care Pool (or “Free Care”) regulations were released on September 29 with significant changes from previous indications, for an October 1 effective date. So, the MGH and Partners have had to play “catch-up” to understand the regulations and their impact, and to design relevant policies and procedures. This space has been covering the Free Care change proposals for the last several months, but now that we have the final regulations, Joe’s presentation helped simplify and clarify the changes and to allow staff to understand how they’re likely to impact their practice, put the changes in perspective and explain them them to patients.

Note:Remember those 65 and older do not yet fall under the new rules outlined below! We expect it will apply to them by the end of 2005.

Critical Access

OLD:no such regulation.

NEW: starts January 1, 2005

The most anxiety-provoking policy change for our staff and patients, this provision limits Free Care coverage of hospital-based primary care to only services that provide “critical access”. Currently Partners’ practices are designing their implementation plans, but there are no plans to move patients en masse to health centers, or to deny care to existing primary care patients. The state has told providers that they will be issuing guidance on how physicians can certify that certain patients are receiving “critical access” services and should remain under their care. For now, it seems as if providers would only need to document patient exceptions for audit purposes by documenting the need briefly in the billing record, and more extensively in the medical record.

This provisionshould NOT directly impact MGH patient’s ability to continue to get pharmacy or mental health services from MGH. Though certainly if patients eventually need to move their primary care elsewhere, this may effect their ability or willingness to continue other treatment here.

Also of note, while the regulations are designed to encourage moving patients’ primary care to Community Health Centers, there is no increased funding to health centers for capacity building to accommodate an influx of new patients. Capacity obviously varies greatly depending on the health center.

Application

OLD:

• Separate MassaHealth and Free Care applications
• MassHealth application optional to get Free Care
• Separate Free Care applications for each facility
• Free Care applications approved on the spot by facility staff

NEW:

• Combined MassHealth and FreeCare application
• MassHealth application required before getting Free Care
• One application covers patient regardless of facility
• Free Care application approved by MassHealth after assessed for MassHealth eligibility

Part of the implementation of the changes includes a new computer system. Once in this system (upon the next eligibility determination for those who already receive Free Care), patients can access Free Care from any medical system/facility.

ELIGIBILITY and COVERAGE

OLD:

• Non-Massachusetts residents could receive urgent and emergent care under Free-Care
• Eligibility for one year
• Retroactive for one year

NEW:

• Non-Massachusetts residents are not eligible for even urgent or emergent care
• Eligibility remains for one year
• Retroactivity reduced to six months
• If have MassHealth, automatically have Free Care back-up

Patients who currently have Free-Care will not be re-evaluated until their “anniversary”, as they would have under the old regulations. One application issue that has been eased is proving Massachusetts residency. It now will be self-report, however, i f a letter is returned to MassHealth for an inaccurate address, they will assume the applicant is a non-resident and she/he will automatically be disenrolled from Uncompensated Care.

Immigration Issues

No changes, except for aforementioned residency requirements. Advocates, however, are concerned that the MassHealth application requirement will discourage immigrants from seeking needed health services.

There is no exception to the rule requiring a MassHealth application to access Free Care. An official MassHealth Q and A states, however, that: “ MassHealth has worked diligently with various advocate groups to publicize the fact that the Program is not required to, and does not, automatically inform INS and other federal authorities of information relating to the applicant. It does maintain the confidentiality of the applicant's information.” Similarly, receiving health care assistance (in fact any non-cash assistance) would not put immigrants in danger of being deemed a “public charge” when seeking citizenship. Any immigrants who are concerned should speak to an immigration attorney or an immigration advocacy organization such as MIRA (617-350-5480) and/or discuss the case with CRC staff before applying.

Patient Education

There is no official plan from the state to communicate these changes in any way to patients. The state mails redetermination packets to the patient before the patient’s expiration date. Encourage patients to communicate any changes in contact information to MassHealth, and to watch their mail and respond in a timely manner to MassHealth communications.

-Adapted from materials from Joe Ianelli and Kim Simonian, MPH, Health Access and Community Partnerships, Community Benefit Programs, Partners HealthCare