NMICoA Health Committee response HSD CMS press release

The following is a letter written on behalf of the New Mexico Indian Council on Aging, in response to the letter release by Cindy Mann Director of Medicaid and CHIP Services detailing several portions of the Centennial Care Waiver,  part of which is the fact that CMS will allow NA Adults and Children to continue to "Opt-in" to Managed care but will continue to allow HSD to mandatorily enroll Medicaid eligible Elders into a Managed Care program.  In my opinion this is unacceptable.

March 5, 2013

 

Cindy Mann

Director
Centers for Medicaid and CHIP services
7500 Security Boulevard, Mail stop S2-26-12
Baltimore, Maryland 21244 

Director Mann,

The New Mexico Indian Council on Aging (NMICoA) is a grassroots organization representing the Native American (NA) elders of the Sovereign Nations of the 19 Pueblos and the two Apache Tribes.  The purpose of the NMICoA is to promote education and advocacy of our elders regarding Health care services and promote NA Community involvement.

 The Health Committee of the New Mexico Indian Council on Aging was developed in 2008, by the late Archie Chavez of Sandia Pueblo, to begin to educate Pueblo Elders about available health care services and advocate on their behalf at the State Level.  We started with NM Coordination of Long Term Services (CoLTS), and now we are working to educate elders on the possible changes that will come with Centennial Care, NMs latest attempt to mandatorily place Medicaid Eligible NA’s into managed care.

New Mexico’s (NM) Human Services Department (HSD) development of an 1115 Research and Demonstration Waiver, from the Centers for Medicare and Medicaid Services (CMS), is an attempt to Waive Federal Protections for Sovereign NA Nations Tribes and Pueblos.  NMs Tribes Nations and Pueblos have never consented to waive these sovereign rights with regard to Centennial Care.

Provisions within the American Reinvestment and Recovery Act (ARRA) of 2009, and the Indian Health Care Improvement Act, were not initially addressed in consultation sessions prior to HSD submitting the 1115 Centennial Care Waiver to CMS.  NAs have a government to government relationship with both the State and the Federal Governments.  In 2008, when the CoLTS Program was introduced the Elders of NMs 19 Pueblos asked why the state was mandating enrollment into a Managed Care Organization.  Since the Implementation of the CoLTS program Native American Elders in NM, who are enrolled in Medicaid, have had poor experiences with the MCOs administering the CoLTS program.

·         Outreach and Education of Medicaid programs, by MCOs, have never been totally effective in Native American Communities.  Elders were often confused by the MCO policies and could not navigate the program without assistance.  The methods of communication between the MCOs and Elders were ineffective, due to the lack of access to phone and internet services.   

·         Coordination of Care or Case management is provided by Indian Health Service (IHS) and Tribal 638 Patient benefits coordinators, Doctors, Physician Assistants (PA), Nurse Practitioners (NP) and Community Health Representatives (CHRs).  Introducing another care coordinator form an outside MCO further complicates an elders’ access to health care services, and “benefits of managed care.

·         IHS and Tribal 638 Programs have had a history of problems collecting reimbursements from MCOs for Medicaid services provided to Medicaid enrolled Elders.  Through a the Fee for Service provision currently  within the Medicaid Program IHS and Tribal 638 Programs are usually reimbursed with in a 14 day time period, compared to 30 days to 60 days and sometimes 90 days with the MCO.  This third party funding is critical to the operation of IHS and Tribal 638 Health care providers.

·         NA Elders often have issues with language barriers when it comes to understanding policy and guidelines outlined by MCO employees.  This lack of cultural appropriateness is a definite barrier to our Pueblo elders.

NM’s NA elders have always taken the position of opposing the mandatory inclusion of Medicaid eligible enrolled individuals into managed care, since the development of Medicaid Reform in NM, which began in the 1990’s wit the Salud program. We recognize that the CoLTS program may be easier for those living in or near urban areas to access MCO providers and elders should have the choice to “Opt-in”

NA elders are mandated into managed care via Centennial Care, the proposed MCO’s will double and our elders will be selected into four MCOs.  We do not understand why our elders will have a different status from the rest of the NA Medicaid population.  Home and community based long term care can best be provided via local community programs on Pueblo lands.  We ask that you reconsider this option for our elders as we will discuss this with our Leaders.

Respectfully Submitted,

 

 

Dr. Ron Lujan MD (retired), Pueblo of Taos

Florence Chavez, Pueblo of Sandia

Leonard Armijo, Pueblo of Santa Ana

Manuel Cristobal, Pueblo of Santa Ana
Joseph Ray, Pueblo of Laguna
Eloise Smith, Pueblo of Laguna
Kay Ray, Pueblo of Laguna
Joe Cherino, Pueblo of Taos
Erik Lujan, Pueblo of Taos