Medicaid Program; State Flexibility for Medicaid Benefit

March 13, 2008 Kerry Weems Administrator, Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, DC 20201 Re: CMS- 2232?P-- Medicaid Program; State Flexibility for Medicaid Benefit Packages Dear Administrator Weems: Although we understand your desire to give state Medicaid programs flexibility regarding administering their benefits, we want to emphasize that Non-emergency medical transportation is essential in the delivery of health care to approximately 36 million Americans covered under Medicaid. The poor, mentally and physically disabled and elderly patients who often have barriers to health care will be unable to receive life sustaining health care treatments such as dialysis. As you examine this issue, the patient needs to remain front and center. The final rule specifies that states should ?create innovative Medicaid programs that further strengthen and support the overall health care system to provide patient-centered care to maximize health outcomes for individuals.? We would be concerned about any benefit changes that would limit the patient?s ability and flexibility to have programs available to meet their transportation needs or jeopardize their well- being. Specifically we are asking for consideration of the following: ? Safeguards for ESRD population - End stage renal disease (ESRD) is a chronic health condition resulting in death unless treated. Treatment options for ESRD are transplant and dialysis. Dialysis is usually needed when 85 to 90 percent of kidney function is lost and access to this life-saving treatment should be a priority! Today, more than 400,000 Americans are living with ESRD, leaving them dependent upon life-saving dialysis three to four times each week. Approximately 93% of these patients are Medicare and Medicaid beneficiaries. If finalized, this rule will limit access to the needed services, jeopardize the care the most vulnerable population and place substantial hardships on ESRD patients and their families. ?The severity of the complications of missing dialysis treatments--Patients with ESRD often have additional comorbidities, such as diabetes or heart disease, as well as mental health conditions such as depression and anxiety. This extensive regimin requires transportation to dialysis on average 3 times per week. Missing dialysis treatments leads to excessive fluid gains, build up of toxins, and increased hospitalizations. I cannot begin to imagine my Medicaid patients not being able to use Medicaid contracted transportation. In fact there are so many other patients who don't qualify for Medicaid who struggle to either drive themselves, have family members take off work to provide transportation, or who struggle to pay for transportation that the idea of the Medicaid patients lose this option could truly be life-threatening because many will have no other way to get to dialysis treatment. Think of the patients in wheelchairs or the patients who live in cities with no public transportation . Thank you, Brandy Smith, LCSW