April 9, 2007
His Excellency Deval L. Patrick
Governor of the Commonwealth
Executive Office
State House
Boston, MA02133
Dear Governor Patrick:
We write to you on behalf of Affordable Care Today (ACT!!), a coalition of community, religious, and provider organizations committed to the success of health care reform. We need to communicate to you our serious concerns about decisions on affordability and the individual mandate that will soon be made by the Commonwealth Health Insurance Connector Authority.
Since the enactment of Chapter 58 one year ago, the Connector has adopted a careful approach to addressing its many challenges. We urge you to ensure this approach is used in the determination of the affordability schedule and the individual mandate. In this, consensus among key stakeholders is critically important.
We could not support an affordability schedule that would punish economically vulnerable residents and would trigger a backlash against health reform. In the Blue Cross Blue Shield of Massachusetts Foundation’s November 2006 report, The Massachusetts Health Reform Law: Public Opinion and Perception, surveyors found fragile support for the individual mandate, particularly among lower income residents. The affordability decision is key to maintaining public support for the law.
Over 90 percent of Massachusetts residents already have health insurance. While many uninsured, lower-income residents have responded positively to coverage offered through the Connector, many others have found the premiums levels unaffordable. The Connector must recognize that individual financial situations are complex and unique, and that a cautious implementation approach is critical.We urge the Connector to include these components in the affordability schedule:
Include individuals up to 150% fpl in Commonwealth Care Plan Type 1.Research suggests that even a modest premium is a barrier to coverage for these low income individuals. We know the Connector is concerned about adverse risk selection in Commonwealth Care. By auto-enrolling known Free Care Pool users under 150 percent fpl into Commonwealth Care PT 1, we can lessen this concern, limit adverse selection, and reduce the number of Free Care Pool users. Even as we advocate reducing Pool use, we remain committed to maintaining adequate funding for uncompensated care.
Lower premium levels for Commonwealth Care Plan Types 2, 3 & 4.Enrollment in Commonwealth Care plans which require premiums from consumers has been much lower than projected. The higher the premium, the lower the enrollment.There also are noticeable geographic differences in sign-up patterns. We are concerned that the current premium schedule is prohibitively expensive for many eligible persons. Lowering premiums to 1%, 2%, and 3% of income for individuals at 150%, 200% and 250% of the federal poverty line, respectively, will enable more individuals to afford this coverage.
Define affordability between 4% and 8% of income, including premiums and deductibles, on a sliding scale for those between 300% and 600% of the federal poverty level. As Chapter 58 requires, we urge you consider the cost of deductibles by setting the definition of “least costly coverage” equal to premiums for the lowest cost “Silver” or “Value” plan.
Create a robust, simple individual waiver process.Individuals with exceptional circumstances need an appeals process that is fair, speedy, and accessible. All the steps outlined above will help to ensure an individual waiver process that meets these goals.
It is not the purpose of Chapter 58 to punish people who are unable to afford coverage. The intent is to require residents to buy insurance where creditable and affordable. The final judgment on affordability will rest with the residents of the Commonwealth—and will determine the success or failure of health reform. We should proceed responsibly and cautiously toward this common goal.
We urge that the affordability schedule address the needs of Massachusetts residents as real people, not as data points. We appreciate the opportunity to comment as the Connector sets an affordability schedule.
Sincerely,
Philip J. Edmundson
CEO, William Gallagher Associate
Chair, ACT!! Coalition
Members of the ACT!! Coalition Executive Committee:
Neil Cronin
Health Policy Analyst, Massachusetts Law Reform Institute
Patricia Edraos
Policy Director, Massachusetts League of Community Health Centers
Mike Fadel
Executive Vice President, 1199 SEIU
Deborah Fastino
Director, Coalition for Social Justice
Timothy Gens
Senior Vice President, Policy and Regulation, MassachusettsHospital Association
Maureen Goggin
Director of Government Relations, Partners Healthcare
Harris Gruman
Director, Neighbor to NeighborMassachusetts
Reverend Hurmon Hamilton
President, Greater Boston Interfaith Organization
Marc Hymovitz
Director of Government Relations and Advocacy, American Cancer Society, New England Division
John E. McDonough
Executive Director, Health Care For All
Judy Meredith
Executive Director, Public Policy Institute
Stephen Rosenfeld
Volunteer Legal Director, Health Law Advocates, Inc.
Gerry Thomas
Associate Director, Bureau of Community Initiatives, Boston Public Health Commission
Cc: Leslie Kirwan, Chair, Connector Authority Board
Nonnie Burnes
Bruce Butler
Thomas Dehner
Jonathan Gruber
Chip Joffe-Halpern
Louis Malzone
Dolores Mitchell
Richard Lord
Celia Wcislo
Jon Kingsdale
JudyAnn Bigby, Secretary, Health and Human Services
Therese Murray, Senate President
Salvatore DiMasi, Speaker of the House
Richard Moore, Senate Chair, Joint Committee on Health Care Financing
Patricia Walrath, House Chair, Joint Committee on Health Care Financing
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