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CQC Urges Governors to Prioritize Consumer Care When Considering Waivers

WASHINGTON – As the nation’s governors descend on Washington, D.C. for the National Governors Association (NGA) Winter Meeting, Consumers for Quality Care (CQC) today issued an open letter urging them to keep consumers top-of-mind when considering state waivers.

In the letter, CQC points out that many states are considering harmful Section 1332 State Innovation and Section 1115 Medicaid waiver requests that, despite CMS claims they “give states additional flexibility to design and improve their programs,” actually pose a serious threat to quality health care by weakening access and decreasing coverage for many Americans.

In an effort to ensure states keep the focus on consumer care when navigating the waiver process, CQC, an organization led by health care advocates and former policy makers, created a checklist for state officials to consider as they craft waiver requests.

Some of the checklist’s consumer-focused considerations include:

  • Would this waiver preserve quality care by offering adequate provider networks, emergency care and essential health benefits?
  • Would this waiver put patients at the center by ensuring benefits for special populations, providing adequate exemptions for those with chronic conditions and engaging health care advocates in providing input on the waiver’s provisions?
  • Would this waiver cut costs for consumers by preventing cost shifts or cost increases and capping Medicaid out-of-pocket costs?
  • Would this waiver preserve access by ensuring no barriers to coverage, an accessible network of doctors and options for prescription drugs?
  • Would this waiver ensure transparency so that the public understands its potential implications – both to their health care and their state’s fiscal health?

“The answers to these questions are critical,” the CQC board wrote. “Higher costs, cuts in coverage and reduced access to quality care will harm consumers in every state, across the country.”

The checklist also highlights a number of ways already implemented waivers are harming consumers across the country, including through cuts to transportation benefits, increased out-of-pocket costs, restricted access to medications and unreasonable barriers to coverage.

“We know that every state’s top priority is preserving quality health care for their constituents. As such, we urge you review and consider our waiver checklist when submitting your waiver requests. The risks to consumer health care quality and access are high when waivers are not implemented with consumers at their core,” the letter reads.

CQC is led by a board of directors that includes the Honorable Donna Christensen, physician and former Member of Congress; Jim Manley, former senior advisor to Senators Harry Reid and Edward Kennedy; Scott Mulhauser, visiting fellow at Georgetown University and former Chief of Staff at the U.S. Embassy in Beijing to Ambassador Max Baucus; and Jason Resendez, Executive Director of the LatinosAgainstAlzheimer's Network and Coalition.

The full checklist can be accessed at www.consumers4qualitycare.org/statewaiverchecklist.

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Full text of CQC’s open letter to governors:

Dear Governor:

While the debate in Washington over the Affordable Care Act may have tempered in recent weeks, states like yours are considering dangerous waiver requests that, if implemented, pose a serious threat to Americans’ access to quality health care.

These Section 1332 State Innovation and Section 1115 Medicaid waiver requests to the Centers for Medicare and Medicaid Services (CMS) seek to radically reshape state health care markets and safety net programs. Despite what CMS claims, we are concerned that these waivers will not result in high- quality, affordable coverage but instead will dramatically weaken access and coverage for many Americans.

We are Consumers for Quality Care (CQC), a group of health care advocates who have come together to speak up for patients and health care consumers. Our mission is to ensure patients remain the most important stakeholder in any health care policy decision. That is why we are writing to you, our nation’s governors.

As you gather this week in Washington, D.C. for the National Governors Association (NGA) Winter Meeting, we urge you to carefully consider the impact these waivers will have on patients in your state. To aid in that deliberation and to help ensure consumer care remains the focus of the application process, we have put together a state waiver checklist to help.

Among the important questions to ask are the following:

  • Would this waiver preserve quality care by offering adequate provider networks, emergency care and essential health benefits?
  • Would this waiver put patients at the center by ensuring benefits for special populations, providing adequate exemptions for those with chronic conditions and engaging health care advocates in providing input on the waiver’s provisions?
  • Would this waiver cut costs for consumers by preventing cost shifts or cost increases and capping Medicaid out-of-pocket costs?
  • Would this waiver preserve access by ensuring no barriers to coverage, an accessible network of doctors and options for prescription drugs?
  • Would this waiver ensure transparency so that the public understands its potential implications – both to their health care and their state’s fiscal health?
  • The answers to these questions are critical. Higher costs, cuts in coverage and reduced access to quality care will harm consumers in every state across the country.
  • We know that every state’s top priority is preserving quality health care for their constituents. As such, we urge you review and consider our waiver checklist when submitting your waiver requests.

The risks to consumer health care quality and access are high when waivers are not implemented with consumers at their core.

Consumers for Quality Care Board of Directors
Donna Christensen, M.D.
Jim Manley
Scott Mulhauser
Jason Resendez


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