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Notice of Meeting to Solicit Public Comments and Intent to Act Upon Amendments to the Medicaid Services Manual (MSM) Public Hearing July 28, 2020 Date and Time of Meeting: July 28, 2020 at 9:04 AM Name of Organization: State of Nevada, Department of Health and Human Services (DHHS), Division of Health Care Financing and Policy (DHCFP) Place of Meeting: Please use the teleconference/WebEx options provided below. If accommodations are requested, please advise using the information at the end of this agenda. Out of deference to Declaration of Emergency Directive 006 (https://nvhealthresponse.nv.gov/wp- content/uploads/2020/03/Declaration-of-Emergency-Directive- 006-re-OML.3-21-20.pdf) from the State of Nevada Executive Department signed by Governor Sisolak on March 22, 2020 as well as Emergency Directive 003 (https://nvhealthresponse.nv.gov/wp- content/uploads/2020/03/2020-03-20.Declaration-of-Emergency- Directive-003.pdf) signed March 20, 2020, a physical location will not be open to the public for attendance at this time. Note: If at any time during the meeting an individual who has been named on the agenda or has an item specifically regarding them included on the agenda is unable to participate because of technical or other difficulties, please email or call Jenifer Graham at [email protected] or (775)684-3685 and note at what time the difficulty started so that matters pertaining specifically to their participation may be continued to a future agenda if needed or otherwise addressed. Webinar: https://dhcfp.webex.com/dhcfp/onstage/g.php?MTID=e0de248a4e4f3917d669 7ea8eb0e9f9ef Or www.webex.com, select “Join,” enter Meeting Number 288 495 867, your name and email and then select “Join.” Audio Only: (415) 655-0002 Event Number: 285 519 609 PLEASE DO NOT PUT THIS NUMBER ON HOLD ( hang up and rejoin if you must take another call) 1100 East William Street, Suite 101 Carson City, Nevada 89701 (775) 684-3676 ● Fax (775) 687-3893 ● dhcfp.nv.gov
Transcript
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Notice of Meeting to Solicit Public Comments and Intent to Act

Upon Amendments to the Medicaid Services Manual (MSM)

Public Hearing July 28, 2020

Date and Time of Meeting: July 28, 2020 at 9:04 AM Name of Organization: State of Nevada, Department of Health and Human Services

(DHHS), Division of Health Care Financing and Policy (DHCFP) Place of Meeting: Please use the teleconference/WebEx options provided below. If

accommodations are requested, please advise using the information at the end of this agenda. Out of deference to Declaration of Emergency Directive 006 (https://nvhealthresponse.nv.gov/wp-content/uploads/2020/03/Declaration-of-Emergency-Directive-006-re-OML.3-21-20.pdf) from the State of Nevada Executive Department signed by Governor Sisolak on March 22, 2020 as well as Emergency Directive 003 (https://nvhealthresponse.nv.gov/wp-content/uploads/2020/03/2020-03-20.Declaration-of-Emergency-Directive-003.pdf) signed March 20, 2020, a physical location will not be open to the public for attendance at this time.

Note: If at any time during the meeting an individual who has been named on the agenda or has an item specifically regarding

them included on the agenda is unable to participate because of technical or other difficulties, please email or call Jenifer Graham

at [email protected] or (775)684-3685 and note at what time the difficulty started so that matters pertaining

specifically to their participation may be continued to a future agenda if needed or otherwise addressed.

Webinar:

https://dhcfp.webex.com/dhcfp/onstage/g.php?MTID=e0de248a4e4f3917d669

7ea8eb0e9f9ef

Or

www.webex.com, select “Join,” enter Meeting Number 288 495 867, your name and

email and then select “Join.”

Audio Only: (415) 655-0002 Event Number: 285 519 609

PLEASE DO NOT PUT THIS NUMBER ON HOLD (hang up and rejoin if you must take another call)

1100 East William Street, Suite 101 ● Carson City, Nevada 89701

(775) 684-3676 ● Fax (775) 687-3893 ● dhcfp.nv.gov

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Teleconference Attendees

Gabriel Lither, Deputy Attorney General (DAG) Tammy Moffit, DHCFP Bill Heaivilin, Nevada Disability Advocacy & Law Center, (NDALC) Janet S. Belcove-Shalin, NDALC Jovanna Leid, DXC Technologies Ellen Flowers, DHCFP Kirsten Coulombe, DHCFP DuAne Young, DHCFP Cody Phinney, DHCFP Antonio Gudino, DHCFP Holly Long, DHCFP Kelly Woods, DHCFP Jackie Obregon, DHCFP Marla Williams Shawna Derousse Valerie Padovani Lea Cartwright Cheri Glockner

Introduction:

Ms. Tammy Moffitt, Chief of Pharmacy, DHCFP, opened the Public Hearing introducing herself, Mr. DuAne Young, Deputy Administrator, DHCFP and Mr. Gabriel Lither, DAG.

Ms. Moffitt – The notice for this public hearing was published on June 26, 2020 in accordance with the Nevada Revised Statute (NRS) 422.2369.

1. Public Comment No Comments.

2. Discussion of proposed adoption changes to MSM Chapter 1200 – Prescribed Drugs

Mr. Antonio Gudino summarized the proposed revisions to Medicaid Services Manual (MSM) Chapter 1200 –

Prescribed Drugs, Appendix A are being proposed to reflect recommendations approved on January 23, 2020 by

the Drug Use Review (DUR) Board. The proposed changes include addition of new prior authorization criteria for

Nucala® (mepolizuman) and Dupixent® (dupilumab) within the Monoclonal Antibody Agents section, addition of

new prior authorization criteria for Lemtrada® (alemtuzumab), Mavenclad® (cladribine), Ocrevus® (ocrelizumab)

agents for Multiple Sclerosis (MS) section, addition of new prior authorization criteria for Zelnorm® (tegaserod) to

the existing Functional Gastrointestinal Agents section, addition of new prior authorization criteria for Sunosi®

(solriamfetol) to the Narcolepsy Agents section and addition of new prior authorization criteria for Nayzilam®

(midazolam) to the existing Anticonvulsants policy section.

The following providers who prescribe, dispense or administer this drug may be affected by this change, including but not limited to the list of provider types on the Agenda.

Mr. Gudino advised the location and details of the first proposed change can be found in Appendix A, Page 35,

Section P, titled Monoclonal Antibody Agents. The age indication for Nucala® (mepolizumab) was revised from 12

years of age to six years of age based on FDA indications. Additionally, new prior authorization criteria were added

for its additional FDA-approved indications of Severe Asthma; and Eosinophilic Granulomatosis with Polyangiitis

or (EGPA).

Mr. Gudino stated within the same Monoclonal Antibody Agents therapeutic class, new prior authorization criteria

were added for Dupixent® (dupilumab) and its different FDA-approved indications of Atopic Dermatitis,

Eosinophilic Asthma, Oral Corticosteroid Dependent Asthma, and Chronic Rhinosinusitis with Nasal Polyposis or

(CRSwNP).

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Mr. Gudino continued with the next proposed change found on Page 60, Section CC. The section title has been

revised to “Multiple Sclerosis (MS) Agents”. Within the section, new prior authorization criteria were added for

Lemtrada® (alemtuzumab) / Mavenclad® (cladribine) and Ocrevus® (ocrelizumab).

Mr. Gudino stated the next proposed change can be found on Page 108, Section WW, titled Functional

Gastrointestinal Disorder Agents. The section includes new prior authorization criteria for Zelnorm® (tegaserod)

for the treatment of Irritable-Bowel Syndrome with Constipation (IBS-C).

Per Mr. Gudino the next update is found on Page 116, Section AAA. This section title has been revised to

“Narcolepsy Agents”. Additionally, new prior authorization criteria were added for Sunosi® (solriamfetol).

The last update that Mr. Gudino addressed is found on Page 160, Section BBBB, titled Anticonvulsants. New prior

authorization criteria were added for Nayzilam® (midazolam).

Ms. Holly Long addressed proposed changes to Appendix A. Diabetic Supply Program policy. Language was added

specific to preferred and non-preferred diabetic products and supplies, adding clarification language for when a

prior authorization is required versus not required and providing language specific to Continuous Glucose Monitors

(CGMs) with special features for recipients with an impairment.

The last proposed change Ms. Long talked of was proposed revisions to Antihepatitis Agents policy are being

proposed by updating the age indication for Epclusa® based on updated FDA indications.

The location and details of these changes can be found in Appendix A, Page 84, Section HH, titled Anti-Hepatitis

Agents. Revisions to the existing criteria for Epclusa were made based on updated FDA age indications. Rather

than having to update the age requirement every time there is an FDA change, the language has been revised to

read, “The request is FDA approved for the recipient’s weight and age.”

The location of the next proposed changes can be found on Page 186, Section 4, titled Diabetic Supply Program.

Revisions to existing prior authorization criteria for Diabetic Supply Program policy include adding clarifying

language regarding preferred and non-preferred diabetic products and supplies and language specific to CGMs

with special features for recipients with an impairment. A link has been included to the Medicaid Diabetic Supply

site for reference.

There is no anticipated fiscal impact known at this time.

The effective date is August 3, 2020.

At the conclusion of Ms. Long’s presentation, Ms. Moffit asked Mr. Young and Mr. Lither if they had any questions or comments. Mr. Young advised there were none. Mr. Lither advised he did not have any questions or comments on these changes, but he did have concerns as he received an email from a member of the public who was trying to make public comment earlier but was not able to. Mr. Lither asked if there had been anything done to mute the mikes on the public’s end and if there was any way to confirm members of the public being able to express their thoughts if they have any.

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Ms. Jenifer Graham replied the public is notified at the beginning of each meeting if there are questions or comments to type the questions or comments under the Question and Answer. Individuals with questions or comments will be unmuted.

Mr. Lither reiterated that if there are any members of the public that wished to make comments on the current revisions to type questions or comments so they could be unmuted, and for the same process will be followed for the upcoming Transportation Services section.

There were no public comments.

Ms. Moffitt – Recommended the Administrator approve as submitted.

Mr. Young– Approved as submitted.

Ms. Moffitt – Closed the Public Hearing for the MSM Chapter 1200 – Prescribed Drugs.

3. For possible action: Discussion and adoption of changes to MSM Chapter 1900 – Transportation Services.

Ms. Kelly Woods summarized the proposed revisions to MSM Chapter 1900 are being proposed to align with amendments made to the contract held with the current Non-Emergency Transportation (NET) vendor, Medical Transportation Management, Inc. (MTM) due to the fiscal impact of COVID-19. The proposed changes include revisions to policy language to remove references to meal reimbursement and lodging, as this will no longer be a covered transportation benefit. Changes to policy language are also being made to update the reimbursement language for NET services provided by Indian Health Programs, tribal community health representatives (CHRs) and volunteer drivers from double the IRS medical mileage rate to a reimbursement that is equivalent to double the IRS per mile rate for business use. Policy is also being updated to require recipients to request transportation to any out-of-area medical appointments at least 21 days in advance. In addition, transportation of an escort traveling with a recipient to and from a Residential Treatment Center (RTC) will no longer be covered.

The location of the proposed changes can be found in Section 1904, Non-Emergency Transportation (NET)

Services, Page 1, language regarding out-of-state/long distant travel was updated for improved readability and

the reimbursement language for NET services provided by Indian Health Programs was updated.

Ms. Woods advised the remaining updates are all under the section titled “Coverage and Limitations”:

Section 1904.2(A)(3)(c), Page 7, updated language for NET services provided by Volunteer Drivers and removed

language to clarify that Volunteer Drivers do contract with the NET broker.

Section 1904.2(E), Page 9, language was updated to specify that escort travel is a covered expense only during the

transport of the recipient to a medical facility and during the return transport to the escort’s/recipient’s residence.

Added language to state that meal reimbursement and lodging expenses are not a covered benefit for the escort

or the recipient.

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Section 1904.2(F), Page 10, removed language regarding meal and lodging reimbursement for foster/adoptive

parents obtaining medical services for foster/adoptive children.

Section 1904.2(I)(2)(a-b), Page 10, updated language to require recipients to request out-of-area NET 21 days prior

to the travel date, instead of the previous 14 day requirement.

Section 1904.2(I)(3-6), Page 11, removed and updated language to state that meal and lodging reimbursement is

not a covered benefit for out-of-area trips and that gas mileage reimbursement trip logs must be submitted within

60 days after the trip.

Section 1904.2(J), Page 11, removed language regarding “per diem” pay for parents caring for a newborn receiving

treatment.

Section 1904.2(K)(4), Page 12, added language to specify that transportation of an escort traveling with a recipient

residing in an RTC is not covered.

Section 1904.2(L-M), Page 12, removed all language in both subsections as it pertains to meal and lodging

reimbursement for escorts and lodging reservations.

Section 1904.2(N), Page 13, updated reimbursement language for NET services provided by Indian Health

Programs.

Entities Financially Affected: The proposed changes only affect the Medicaid NET vendor, MTM, Inc. and how MTM delivers NET services to Medicaid recipients PT 35.

Financial impact on local government: There is no anticipated financial impact on local government that is known at

this time.

Effective date: July 29, 2020.

At the conclusion of Ms. Wood’s presentation, Ms. Moffit asked Mr. Young and Mr. Lither if they had any questions or comments. Mr. Young did not have any comments. Mr. Lither advised he did not have any comments but advised he received emails, especially from Ms. Janet S. Belcove-Shalin, who is attending the meeting but unable to talk on the microphone. Mr. Lither asked if there was a way to make sure she is able to express comments specifically.

Ms. Graham replied that all phone-in callers have been unmuted and advised Ms. Belcove-Shalin to proceed.

Ms. Belcove-Shalin referenced the written comments previously submitted (attached). Ms. Belcove-Shalin advised that Transportation Services ceased to be a viable benefit when the means of how individuals are able to transport themselves to appointments such as surgeries, procedures, doctor appointments, the RTC and etc. has been undercut. If the individuals do not have lodging and food reimbursement, they will be unable to afford to take advantage of the benefit of Chapter 1900.

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Ms. Belcove-Shalin advised children are entitled to an adult escort under Early and Periodic Screening, Diagnosis

& Treatment (EPSDT). Under Chapter 1900, Escorts are disallowed to RTC Centers. However, children cannot go by themselves. Under EPSDT children and adults with disabilities who may need an escort if the treatment is medically necessary are entitled to an escort.

Ms. Belcove-Shalin advised Nevada Medicaid recipients cannot afford to bear the burden of the additional travel and costs, for instance how the mileage rate has gone down dramatically. The recent mileage rate is 57.5 cents per mile and MTM is now reimbursing at 17 cents per mile which is more than a 300% prohibitive reduction for Medicaid beneficiaries.

Ms. Belcove-Shalin advised another key point is if Nevadans cannot afford to travel to appointments, they may be forced to forego medically necessary treatment.

Ms. Belcove-Shalin stated the number of physicians in Nevada is on the rise but with the ever-growing population, the state is still struggling to catch up to the national average, according to a new report from the University of Nevada’s Reno School of Medicine. Nevada’s state doctor/patient ratio is bleak. Nevada ranks 47th in the nation in terms of physician per person. Beside the doctor and nurse shortage, Nevada lacks the necessary equipment needed for up-to-date diagnoses and treatment. Routinely Nevadans rely on quick trips, most often to California or Arizona, for medical care to compensate for state scarcity. However, if the Department of Health and Human Services (DHHS) succeeds in affecting the proposed cuts to Chapter 1900, the Medicaid population’s health and treatment will be disadvantaged since beneficiaries cannot afford the increased burden of those expenses.

Ms. Belcove-Shalin asked if there were any questions for her.

Mr. Young answered there were no questions for the commenter.

Ms. Belcove-Shalin returned that she has specific questions in addition to her comments that are on Page 4 of her written comments.

Ms. Belcove-Shalin asked what would be Medicaid’s solution to provide healthcare to recipients who must travel for medical care that is unavailable in their community but are unable to afford to do so upon the service cutbacks.

Mr. Young replied that items that were not agenized could not be discussed. However, he gave a general statement that the division intends to continue working through the district offices and with the managed care partners to come up with solutions via charitable organizations and other entities that can assist to help with the gap.

Ms. Belcove-Shalin said it would be beneficial to help with the gap before changes are made in Chapter 1900, because if the changes are effective July 29, 2020 and there is no support system to help the individuals, the individuals will be unable to access Chapter 1900. There cannot be a gap as the beneficiaries’ medical treatment will suffer.

Mr. Lither commented that it is his understanding that, at least for the children, under EPSDT the request for transportation can still be made, and in situations where it is medically necessary, they may be able to obtain that benefit under the EPSDT Program.

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Mr. Young elaborated that all travel access services will still be granted for medically necessary services. Nevada will now be in alignment with what other states are doing by covering transportation for the child but not necessarily for the parent or escort to accompany the child.

Ms. Belcove-Shalin replied that children need to be accompanied. They cannot go to an RTC on their own.

Mr. Young responded that is correct. The Division does understand the hardships and if there was another choice through means of financial renumeration with the contract, Medicaid would have gone that route. Mr. Young continued to advise that this is a very difficult process in the chapter, but it is not permanent. The Division has

released feedback for the public on its Request for Proposal (RFP). This will be released in September to bring a new contract vendor and a new contract which all these elements are being removed from the Chapter and have been placed back into the RFP in hopes that the state is in a much better financial situation to have an all-inclusive bid.

Ms. Belcove-Shalin stated that is for the future—not starting tomorrow when the proposed changes will be implemented.

Mr. Young confirmed that is correct.

Ms. Belcove-Shalin continued that this is a problem for those who rely on these services. She said many have already found that MTM’s reimbursement rate has been implemented already. She questioned why Medicaid is changing its policy to conform to MTM’s reimbursement rate when there had not even been a hearing yet.

Mr. Young advised the changes will go into effect July 29, 2020. MTM had reimbursed incorrectly.

Ms. Belcove-Shalin stated at the moment she is dealing with an RTC in Texas and they refused to accept the notice they received from MTM as incorrect and she was waiting on a response from Medicaid. As of last week, the RTC in Texas still felt they could conform to the new MTM’s reimbursement rate. This was a real glitch as the Public Hearing had not occurred when the changes were accepted.

Mr. Young replied that staff is aware of the problem and Medicaid has reached out to the facility to correct the issue.

Ms. Belcove-Shalin stated again that the beneficiaries cannot afford the changes. Ms. Belcove-Shalin did some calculations and the current reimbursement rate for mileage of $307.80 as opposed to what it will be at $87.80. That is a huge difference and not having meals and lodging paid for basically makes Chapter 1900 moot for the beneficiaries.

Mr. Lither clarified that the numbers she put forth are based on the comments that were submitted in writing for the Transportation trip to Los Angeles, California specifically.

Ms. Belcove-Shalin verified that was correct and reiterated concerns as to how beneficiaries will be able to afford the costs prior to receiving charitable help as it does not help them immediately if medical trips are necessary now. She said she feels Medicaid has stripped recipients of their ability to travel to receive medical treatment.

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Mr. Young responded the Division takes all comments under advisement and staff will reach out with a written response for any follow up questions.

Mr. Lither reminded Ms. Belcove-Shalin that when changes are made, feedback is heard from the community and participants. Medicaid frequently tries to take steps to amend or change policies to make them the best that Medicaid can. Frequently, Medicaid hears from the people at the Public Hearings and the policy is adopted, but that does not mean it is the end of the procedure. Medicaid will continue to work with participants to try and make a policy the best that it can be.

Ms. Belcove-Shalin thanked Mr. Lither for his comments but asked in the meantime, when the policy is changed tomorrow, what can the beneficiaries do if they need to go out-of-state and the charitable organizations are not ready. She asked if Medicaid contacts beneficiaries with information about possible assistance, and what will beneficiaries do starting tomorrow.

Mr. Young replied recipients will, as they always have, remain in contact with the district offices, and the district office staff will help to continue to coordinate those issues.

Mr. Bill Heaivilin reiterated on Ms. Belcove-Sharlin’s comments of the overall burden and some of the issues

related to children under EPSDT. Mr. Heaivilin also mentioned adults with disabilities frequently do need

companion attendance for out-of-state medical treatment. This is needed as an accommodation for their

disabilities. Hopefully as Medicaid goes forward with adopting the changes, a process will be created for

individuals needing accommodations for disabilities under the Americans With Disabilities Act, as well as Section

504, to create a process so the request may be made and Medicaid would consider funding as reasonable

accommodation for disabilities.

Ms. Belcove-Shalin advised she does not think telemedicine is the answer to beneficiaries being able to receive medical care from out-of-state because, in many instances, it is not possible for Nevadans in large swaths of rural areas to have a reliable internet connection, nor is telemedicine possible if an individual does not own a computer or is not proficient with the computer. Also, telemedicine is not appropriate if it is more than a doctor’s appointment, such as a procedure or surgery.

Ms. Moffit asked if there were any further public comments.

Ms. Moffitt – Recommended the Administrator approve as submitted.

Mr. Young – Approved as submitted.

Ms. Moffitt – Closed the Public Hearing for the MSM Chapter 1900 – Transportation Services.

4. Adjournment

There were no further comments and Ms. Moffitt adjourned the public hearing at 9:39 AM.

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*An Audio (CD) version of this meeting is available through the DHCFP Compliance office. For more detailed information on any of the handouts, submittals, testimony and or comments, please contact Jenifer Graham at [email protected] or (775) 684-3685 with any questions.

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NEVADA DISABILITY ADVOCACY & LAW CENTER COMMENTS TO PROPOSED CHANGES TO

MEDICAID SERVICES MANUAL CHAPTER 1900

PUBLIC HEARING JULY 28, 2020

SUMMARY Revisions to Medicaid Services Manual (MSM) Chapter 1900 – Transportation Services to align with amendments made to the contract held with the current Non-Emergency Transportation (NET) vendor, Medical Transportation Management, Inc. (MTM):

1. Removing transportation benefits for meal and lodging reimbursements received by recipients and escorts.

2. Changing reimbursement language for NET services provided by Indian Health Programs, tribal community health representatives (CHRs), and volunteer drivers to include business use: From double the IRS medical mileage rate to a reimbursement that is equivalent to double the IRS per mile rate for business use.

3. Requiring recipients to request transportation to any out-of-area medical appointments at least 21 days in advance.

4. Removing coverage for escorts traveling with recipients to and from a Residential Treatment Center (RTC).

RELEVANT SECTIONS Nevada Disability Advocacy & Law Center’s comments concern the following proposed changes to Medicaid Services Manual Chapter 1900: 1904.2(E) Language updated to remove meal reimbursement and lodging as a covered benefit and to clarify covered transportation of an escort.

• This provision removes reimbursement for meals and lodging for both escorts and recipients.

1904.2(F) Removed language regarding meal and lodging reimbursement for foster/adoptive parents obtaining medical services for foster/adopted children.

• This provision removes meals and lodging for adoptive and foster parents escorting a recipient.

1

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1904.2(I)(3-6) Removed and updated language to clarify that meal and lodging reimbursement is not a covered benefit for out-of-area trips and that gas mileage reimbursement trip logs must be submitted within 60 days after the trip.

• This section removes all language requiring low-cost accommodations (since food and lodging are eliminated), current mileage reimbursements, and highlights changes regarding parents accompanying a child under 12 and live organ donors.

1904.2(J) Removed language regarding “per diem” pay for parents caring for a newborn receiving treatment.

• This section strikes a per diem reimbursement for transportation services when caring for a recipient-newborn.

1904.2(K)(4) Added language to clarify that transportation of an escort traveling with a recipient residing in a residential treatment center is not covered.

• This section reiterates that the transportation costs of the recipient receiving treatment at a residential treatment center is a covered benefit, but escort travel to it is not.

1904.2(L) Removed all language in this subsection as it pertains to meal and lodging reimbursement for escorts.

• There are no red-line deletions in this section. 1904.2(M) Removed all language in this subsection as it pertains to lodging reservations.

• There are no red-line deletions in this section. 1904.2(N) Updated mileage reimbursement language.

• In the context of Indian tribes and health programs, the mileage reimbursement has deleted the words “medical/moving” but added “business” to characterize the mileage rate.

COMMENTS

1. Children are entitled to an adult escort under EPSDT

2

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The proposed changes for escorts make it virtually impossible for a minor to seek treatment if unaccompanied. Minors need an escort since they cannot drive; necessarily fly alone; or negotiate treatment without support due to their youth. 1500 MSM Healthy Kids is Nevada’s Early and Periodic Screening, Diagnostic and Treatment (EPSDT) chapter, providing mandatory benefits for categorically needy individuals under age 21. One benefit is transportation which allows a recipient to receive medically necessary care and services. MSM 1503.7A. NDALC believes the Division should review Chapter 1900 to ensure it complies with the federal EPSDT requirements.

2. Adults with disabilities may need an escort if treatment is medically necessary

Adults with significant physical or cognitive disabilities as well as those individuals needing assistance with communication seeking treatment may require reasonable accommodations such as an escort to accompany them to out-of-state treatment. The proposed change to expunge benefits for escorts will make travel assistance cost prohibitive and may violate Section 504 of the Rehabilitation Act and the Americans with Disabilities Act. NDALC would encourage the Division to revise the proposed policy to consider disability-related reasonable accommodations.

3. Nevada Medicaid recipients cannot afford to bear the burden of additional travel costs and expenses The proposed changes to MSM 1900 make travel for medical assistance unaffordable. NDALC clients tell us that expenses for food, lodging, and a mileage would have a chilling effect and dissuade them from traveling for medical care. With regard to mileage reimbursements, the recent rate is 57.5 cents per mile. If reduced to match the IRS medical mileage rate, the reimbursement will be 17 cents per mile. This is more than a 300% reduction.

4. If Nevadans cannot travel to appointments, they may be forced to forgo medically necessary treatment One alternative to an in-person appointment frequently used today is the virtual, telemedicine appointment. While increasing numbers of patients rely on telemedicine, this is often not possible for Nevadans in large swaths of rural areas without reliable internet connection. Nor is telemedicine possible if an individual does not own a computer or is proficient with it. As a result, Nevadans will go without medical care. NDALC would encourage the Division to consider assisting recipients with access to technology which may allow Medicaid recipients to benefit from out-of-state treatment providers without traveling.

5. Telemedicine is not the solution for every Medicaid recipient

3

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A Medicaid recipient connected to the web may have a successful telemedicine appointment IF it requires no hands-on diagnostic or treatment activity. That being said, telemedicine cannot accommodate surgeries, physicals, and procedures which Medicaid clients may require.

QUESTIONS NDALC requests that Nevada Medicaid answer the following questions regarding the proposed changes:

• If Nevada Medicaid recipients must travel for medical care unavailable in their community but cannot afford to do so upon service cutbacks to MSM 1900, what is Medicaid’s solution to provide healthcare to its clients?

• How can elderly individuals, unaccompanied minors, and individuals with significant physical or mental disabilities receive treatment out of state if they have no escort? It is our experience that these Medicaid beneficiaries require assistance from family members or personal care attendants to receive any type of health care treatment, even in their own communities.

• Why is Medicaid changing its reimbursement policy to conform to MTM’s reimbursement rate? Otherwise put, why isn’t MTM conforming to the current Medicaid reimbursement rate (which Medicaid recipients can way better afford)? If a Medicaid recipient drives round trip from Las Vegas to Los Angeles, some 540 miles, the current reimbursement is $307.80 as opposed to the proposed rate at $87.80. That’s a difference of $220.00, a huge increase to absorb.

• Our clients tell us that MTM has already lowered the mileage rate and refuses reimbursement for escorts to/from RTCs. How can MTM have implemented these changes prior to a Public Hearing? Why hasn’t DHHS informed RTCs that MTM’s notice is incorrect?

CONCLUSION “The number of physicians in Nevada is on the rise, but with an ever-growing population the state is still struggling to catch up to national averages, according to a new report from the University of Nevada, Reno’s School of Medicine.” Healthcare, “Physician numbers are on the rise, though Nevada still well below the national average.” Megan Messerly, August 5, 2018. Our state doctor-patient ratio is bleak: “Nevada ranks 47th in the nation in terms of physicians per person.” Id. Besides our doctor (and nurse) shortage, Nevada lacks the necessary equipment needed for up-to-date diagnosis and treatment.

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Page 14: Notice of Meeting to Solicit Public Comments and Intent to Act …dhcfp.nv.gov/uploadedFiles/dhcfpnvgov/content/Public... · 2020-08-06 · Mr. Young responded that is correct. The

Routinely, Nevadans rely on that quick trip (e.g., to California or Arizona) for medical care to compensate for state scarcity. Thus, if DHHS succeeds in effecting its proposed cuts to MSM 1900 Transportation, our Medicaid population’s health and treatment will be sorely disadvantaged since beneficiaries cannot afford the increased burden of these expenses.

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