Florida recently submitted a Section 1115 Medicaid waiver request to eliminate 90-day retroactive coverage for everyone in Florida’s Medicaid program, except children and pregnant women. As we wrote in our joint comments, this is a bad idea that will expose families to medical debt and providers to higher uncompensated care costs. There is absolutely no reasonable policy justification and there appears to be a blatant attempt to cut costs by delaying coverage and long-term care for people who need help now, not later.

As our comments noted, this policy change poses the greatest risk to low-income seniors and people with disabilities applying for long-term care. The federal public comment period recently closed. An analysis of those comments found that well over 100 comments were submitted and not a single comment was filed in favor of this change. Groups opposing the change (to name a few!) include doctors (FL Chapter of the Academy of Pediatrics, the American College of Obstetricians and Gynecologists, Family Physicians) other providers (Safety Net Hospital Alliance of Florida, the Florida Health Care Association, BayCare Health System) and patient advocacy organizations (Cancer Action Network, National Alliance on Mental Illness, AARP, American Heart Association).

This comment submitted by a Floridian typifies the human cost of these policies:

“I wish to beg you NOT to reduce the Retroactive Eligibility Period. Here is my experience. My mother has Alzheimer’s and is now in Assisted Living care. Our family is paying for her care out of our combined savings, which will not last forever, and hopefully there will be some left for me when I am old. We are willing to pay for mom’s care as long as we can, but we are only working people. Just last week I called the people who do Medicaid applications to ask how to apply in case we have a financial emergency or a medical emergency where she would have to be moved to a higher level of care. I was told about the Retroactive Eligibility Period, which would give us time to get my mother placed and then make the application after she is safe!!. If the nursing home can be assured of getting paid, they will be more willing to admit her. I know the state claims their costs will be “more predictable” if this amendment is approved, but medical emergencies are NOT PREDICTABLE.”

(Author’s note: Thanks to my research assistant, Alexandra Corcoran, for analyzing the comments that were submitted to CMS.)