September4, 2015
The Honorable Van Mitchell
Secretary, Department of Health and Mental Hygiene
Chair, Maryland Health Benefit Exchange
201 West Preston Street
Baltimore, MD21201
Carolyn Quattrocki
Executive Director
Maryland Health Benefit Exchange
750 East Pratt St., 16th floor
Baltimore, MD 21202
Re: Comments on Network Adequacy and Essential Community Providers Workgroup Report
Dear Secretary Mitchell and Ms. Quattrocki,
We would like to thank the Maryland Health Benefit Exchange (MHBE) for convening the Network Adequacy and Essential Community Providers (ECP) Workgroup. MRHA was grateful to have the opportunity to work with this group, Hilltop, and MHBE. We fully endorse the six policy options that gained consensus during the process. However, these few consensus recommendations will only make small in roads on ensuring we have appropriate access to primary care physicians and other health providers for our newly insured in rural Maryland.
Despite having an adequate number of primary care and psychiatric care providers in the state; 10 of the 18 Maryland rural counties have partial or full designation as primary health care professional shortage areas. 17 out of 18 rural counties have some type of federal mental health professional shortage area. Geography in Maryland plays a role in the access to health care. First, there are well documented differences in the quality of health outcomes between our geographic areas both urban and rural. Second, the physical distance to health care providers can seriously impact the ability of low-income consumers to utilize health care services even if they are insured. Third, barriers of language and culture can have a serious impact on the ability of consumers to receive quality of care. For these reasons it is critical that consumers have appropriate access to the services they need.
In our letter dated September 10, 2014, we stated that we hoped the group would look at the possibility for plans to have provider-to-enrollee ratios; maximum patient travel time; maximum patient travel distance; maximum patient appointment wait time; and a minimum percentage of available providers within a service area to help ensure that we were providing sufficient number and geographic distribution of ECPs across the state. A year later Maryland is now in the minority of states that has no single metric in place beyond the qualitative standard of unreasonable delay. A timeframe to lay out potential quantitative standards could not even reach consensus by the group and was extremely discouraging as a participant.
Consumers need to understand what timely and unreasonable access means through sufficient, clear, and specific standards so that they can best utilize new insurance especially for preventative primary and behavioral health care. We need consumers to get the most out of their investment in new coverage and be able to obtain preventative care so the whole system can continue to be affordable and accessible. The reality is that coverage without access to care means little to helping to keep Marylanders healthy and will hinder the goals of the new All Payor Model.
Thank you for the work you do on behalf of Maryland’s healthcare system and Maryland’s uninsured. To help ensure this ongoing work MRHA recommends that at least two rural stakeholders, representing different rural regions of the state that experience inadequate network of providers, be added to the Standing Advisory Committee (SAC) of MHBE. This could help strengthen the SAC’s work on advising the MHBE on our access to care issues in rural areas. If you or your staff have any questions please do not hesitate to give me a call at 410-302-4650 or email me .
Sincerely,
Michelle G Clark
Michelle Green Clark, MSW, MPH
Executive Director
Maryland Rural Health Association