As reported in the January 24th issue of the MPCA eUpdate, the Michigan Department of Community Health (MDCH) has requested approval from the Centers for Medicare and Medicaid Services (CMS) to phase out Plan First!.
This program is a Family Planning Waiver that CMS approved in 2006 to allow women whose income is at or below 185% of poverty to receive reproductive health and pregnancy prevention services under Medicaid. The rationale behind the waiver was that women below 185% of poverty who become pregnant qualify for Medicaid, and Medicaid then pays for the prenatal, OB, and post-partum care which totals around $11,000 per normal delivery. To provide contraception care to these women to prevent unintended pregnancy seemed fiscally prudent. More than 37,000 low-income women have been enrolled for Plan First! services since its inception, and analysis has shown significant savings to both the federal and state government.
On January 17, 2014, the Michigan Medicaid program released a policy bulletin proposing to discontinue Plan First! enrollment March 31, 2014; cease program benefits on June 30, 2014; and to not request renewal of the waiver. The rationale used in the bulletin is that the majority of Plan First! beneficiaries will be eligible for either Healthy Michigan (Michigan’s expanded Medicaid program that will provide coverage for those under 133% of poverty when it launches this spring), or for subsidized insurance through the Health Insurance Marketplace (individuals with income between 133% and 185% of poverty).
It is MPCA’s opinion that ending Plan First! on June 30 is premature. Tens of thousands of women will likely still be without coverage at that time because they either did not apply for, or elected to forgo, Healthy Michigan or private coverage. We further believe that even though preventive services are intended to be provided without cost sharing, perceptions and lack of understanding of cost sharing requirements could prevent women from seeking care. MPCA will submit comments on the draft policy bulletin, requesting that MDCH continue the Plan First! waiver for a period of time sufficient enough to assure that most women are covered by other insurance, and that the need for Plan First! does not appear necessary. We believe that most agencies serving Plan First! beneficiaries will assist them in acquiring more comprehensive coverage and, that over time, the need for Plan First! will diminish.
We encourage you to read the policy bulletin, and to also submit comments if you feel compelled. It is our belief that the more comments MDCH receives, the more likely it is that our request to extend the wavier will be considered and approved. The deadline to submit comments is February 16, 2014. MPCA will share our letter of comment in a future issue of the MPCA eUpdate.