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Society weighs in on two policy issues

The Wisconsin Medical Society recently submitted comments on two new regulatory policies: the Wisconsin Department of Health Services’ (DHS) “Medicaid Managed Care Quality Strategy” and a proposed rule regarding short-term limited-duration insurance plans (STLDI).

The Medicaid Managed Care Quality Strategy focuses on four categories of quality improvement for its managed care and long-term care populations: (1) access to care and member choice, (2) cost-effectiveness, (3) person-centered care and member experience and (4) health outcomes and reducing disparities. To achieve improvements in these areas, DHS plans to employ payment levers, delivery system and person-centered care approaches and member engagement and choice initiatives.

In its comments, the Society offered both support and caution in how DHS could utilize value-based payments to achieve quality improvements. The Society suggested ways DHS could improve efficiencies for long-term care members while maintaining and improving patient outcomes. The Society also pointed out how any strategy changes should consider physician satisfaction and burnout, and ensure that any new policies do not unnecessarily burden physicians.

In the second comment letter, the Society opposed STLDI plans based on the Society’s Health System Reform Objectives.

Under the Affordable Care Act (ACA), individuals can acquire STLDI plans for up to three months to alleviate gaps in coverage and avoid paying a penalty under the individual mandate. STLDI plans are not required to follow all of the ACA’s guidelines in that they don’t have to cover essential health benefits, can underwrite, can deny coverage based on preexisting conditions and can place caps on coverage. The proposed rule would allow individuals to acquire STLDI plans for up to 12 months, and could be interpreted to allow individuals to renew STLDI coverage, which is currently prohibited.

Aside from not adhering to patient protections, the expansion of STLDI plans could undermine the broader ACA market. The Society expressed concern that younger, healthier individuals may leave the ACA exchange plans in favor of cheaper STLDI plans, which would increase costs and premiums for sicker and older individuals in the ACA exchanges. The Society also suggested that the proposed rule should shorten the expanded 12-month window or make the plans non-renewable.

If you have questions about either of these issues, contact the Society’s Policy Specialist H.J. Waukau.

Back to April 26, 2018 Medigram