Friday, October 26, 2012

NMICoA Health Committee comments for NCAI

October 23, 2012

NMICoA Health Committee commentary for Nation Congress of American Indians
The New Mexico Indian Council on Aging (NMICoA) Health Committee was develop by its late President, Archie Chavez of Sandia Pueblo, in 2008 to address Healthcare concerns of Pueblo Seniors. The Impetus of the Health committee formation was the institution of the Coordination of Long Term Services (CoLTS) program by the State of NM. The CoLTS program which served seniors eligible and enrolled in Medicaid had a mandate for seniors to be enrolled in a managed care program contracted by the NM Human Services Department, in order to receive medically associated services and benefits in a more coordinated fashion. The implementation of CoLTS for NM Native American (NA) seniors brought many problematic issues with outreach and education of the program, as well as, with service coordination, delivery, utilization, and reimbursement. The CoLTS implementation experience was the second that Native Americans had with Managed Care and now NM is planning to implement Centennial Care to replace the many Medicaid programs. The NMICoA Health Committee has been following the implementation of Patient Protection and Affordable Care Act (PPACA) and Medicaid Reform in NM, and has the following comments for consideration.

There is a Government to Government Relationship that exists between the Tribes, States and the Federal Government. There has been a serious lack of true Consultation and Collaboration between Tribes and the State of NM Human Services Department (HSD). The State of NM by law has mandated that all State Agencies must consult with Tribes on any issue will affect Tribal Communities. The Federal Government also has many rules and regulations governing consultation with Tribes. It is the opinion of the NMICoA Health Committee that the State of NM has not achieved true consultation with Tribes.

NM HSD 1115 Waiver “Centennial Care” while has many merits and improvements to the Medicaid program, is opposed by all Tribes in NM due to:
Centennial Care will mandate that all NA will be enrolled into a Managed Care Organization (MCO) this will take the coordination of care out of the hands of Tribal programs and place it with an undetermined urban based MCO.
The Elimination of the “opt out” category for NA enrolled in Medicaid. Since the 1990s NA have had the option of on obtaining Medicaid Services through a “Fee For Services” category, and today approximately 80% of NA still are opt out of managed care.
Lack of meaningful consultation and collaboration with NM HSD and Medical Assistance Division (MAD), in documents submitted with the Centennial Care Waiver to CMS tribal statement comments and participation were misrepresented. Consultation with all Tribes was not achieved and not all information discussed and presented to HSD was included.
Due to these issues the Tribes and Pueblos of NM are unified in their opposition to the State of NMs imposition of Centennial Care on Tribal peoples.

Medicaid Expansion for the State of NM would be a great economic boost to NM and Tribal Communities. The decision whether or not to accept the Expansion of Medicaid from CMS solely belongs to Governor Martinez office. Given the Government to Government relationship between the States Tribes and Federal Governments:
By law before any decision is made regarding the use of Federal funding that will have a significant impact on Tribal Governments or Programs all State and Federal Agencies must consult with Tribes. Does the decision to Expand Medicaid require consultation due to the Federal Funding attached to the Medicaid program?
If the State of NM decides not to expand Medicaid for the Non Native population can the Governor make this decision on behalf of Tribes. This is a question of Tribal Sovereignty.
If the States and Tribes do not agree on Expansion of Medicaid will CMS grant a Waiver to Tribes to expand their programs independent of the States?

NM Health Insurance Exchange (NMHIX) while is an important component of the PPACA, is not ideal as a means health care delivery for Native Americans. The Snyder Act of 1921 obligated the Federal Government to provide the Tribes with Housing, Education, and Healthcare. Forcing the Tribes to “buy in” or purchase health insurance, while has some advantages, takes the burden of obligation to provide healthcare off the Federal Government. This will also continue to erode tribal sovereignty in that Managed Care Plans and Private Health Insurance Plans do not share the same Government to Government relationship. Here in the state of NM there has still been no formal consultation between Tribes and the State on NM regarding the development and implementation of a Health Insurance Exchange.

Respectfully Submitted by

Dr. Ron Lujan       
Committee Member                   
NMICoA Health Committee             

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