March 31, 2015 Roderick L. Bremby Commissioner Department of Social Services 55 Farmington Avenue Hartford, CT 06105-3730 Kate McEvoy Health Services Director Department of Social Services 55 Farmington Avenue Hartford, CT 06105-3730 Dear Commissioner Bremby and Director McEvoy: The Connecticut State Medical Society (“CSMS”), on behalf of its more than 6,000 physicians and physicians in training, along with the undersigned medical societies, medical groups, medical institutions and medical professionals, write to you to raise significant concerns regarding the proposed dramatic cuts in reimbursement for obstetric, facility obstetric, and related services in the Husky program. These draconian cuts will have an immediate and irreversible impact on access to care for expectant mothers in the Medicaid program in Connecticut. Further, these reductions, many of them 20% to 40% cuts in payment for care delivery, will further erode the already fragile safety net that the undersigned parties have tried to build up over the last decade. At the outset, we raise the issue that the majority of the undersigned parties were unaware of any notice of these proposed cuts until last week when the fee schedule itself was published. We recognize the existence of a February 2015 bulletin, but there is no record of delivery or receipt of this bulletin to any of the impacted physicians. Providing a week or less to update billing and claims processing systems is not sufficient to ensure correct submission of claims and correct claims payment. We raise these concerns at a time when more individuals in Connecticut, including expectant mothers, are covered under Medicaid as both state and federal laws have sought to increase coverage of care for this vulnerable population. Unfortunately, these cuts will have an immediate and adverse effect on access to care delivery services for this population. We are at a crossroads in health care and faced with an emerging population of young mothers that need greater access to prenatal, perinatal and maternal care services. Reducing reimbursement for imaging, preventive, and delivery services will provide significantly fewer choices for expectant Roderick L. Bremby Kate McEvoy Page 2 March 31, 2015 women as to where they receive pre- and post- natal care. Patients will be forced to travel 20 or 30 miles or more to seek care in this state, and many patients in this population simply do not have the means or ability to travel significant distances to receive the frequent care that is required throughout a pregnancy. In our initial analysis, it appears that the dramatic reductions in reimbursements for critical care delivery services will result in significant reductions to those presently providing these services to this vulnerable population. Many of these practices and institutions can ill afford these cuts and the financial viability of continuing to participate in the state Medicaid program will be called into serious question. In addition, while the February 2015 bulletin indicates that the rates would be tied into the 2007 Medicare rate, the previously mentioned analysis of the proposed cuts seems to suggest otherwise as many of the rates are significantly less than the Medicare rates that were in effect in Connecticut in 2007. In fact, many of the rates noted in the revised fee schedule appear to be almost half as much as the indicated rates for payment in Connecticut. CSMS and the undersigned parties ask the Connecticut Department of Social Services (DSS) to delay the implementation of the proposed rate reductions until such time as discussions can take place as to the impact of these proposed cuts on payment for delivery services. The undersigned parties believe that these cuts will have a dramatic, profound, and detrimental impact on access to care for this state’s vulnerable expectant mothers and their children. We ask for an immediate meeting with you to further discuss these proposed cuts that jeopardize access to care for expectant mothers who rely on Medicaid as their sole source of coverage. Providing coverage for medical services is simply not enough when access to care has and continues to be eviscerated through historic cuts in reimbursement for delivery-related services for expectant mothers. [Signature page to follow] Roderick L. Bremby Kate McEvoy Page 3 March 31, 2015 Sincerely, Connecticut State Medical Society Connecticut Chapter of the American Congress of Obstetricians and Gynecologists Connecticut Academy of Family Physicians Connecticut Medical Group Management Association Yale Medical Group Women’s Health Connecticut Adam F. Borgida, MD, Chair, Obstetrics and Gynecology, Hartford Hospital William Cusick, MD, Chairperson Department Obstetrics and Gynecology, St. Vincent’s Medical Center Daniel Gottschall, MD, FACOG, Chief Medical Officer, Women’s Health Connecticut Michael E. Ivy, MD, Chief Medical Officer, Bridgeport Hospital Michael O’Reilly, Chairman, Department of Obstetrics and Gynecology, Griffin Hospital John F. Rodis, MD, EVP and COO, St. Francis Hospital and Medical Center cc: Honorable Dannel Malloy, Governor Honorable Nancy Wyman, Lieutenant Governor Senator Terry Gerratana, Co-Chair Public Health Representative Matthew Ritter, Co-Chair Public Health Senator Marilyn Moore, Co-Chair Human Service Representative Catherine Abercrombie, Co-Chair Human Service Senator Martin M. Looney, President Pro Temp Senator Len Fasano, Senate Minority Leader Representative Brendan Sharkey, Speaker of the House Representative Themis Klarides, House Republican Leader Senator Beth Bye, Senate Chair Appropriations Representative Toni Walker, House Chair Appropriations Members: Council on Medical Assistance Program Oversight (MAPOC) Robert Russo, MD, CSMS, President David Emmel, MD, CSMS Legislative Chair Susan Richman, MD, CT ACOG Chair Mark DeFrancesco, MD, ACOG President-Elect Mark Schuman, CAFP and CMGMA, Executive Director Ronald Vendor, MD, Yale Medical Group, Medical Director Kenneth Ferrucci, CSMS Senior Vice President
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