From: Ed Dieringer
To: Jani Iwamoto, Johnny Anderson, Brad King, dlayton, Jim Nielson, Daniel Thatcher, Brian Shiozawa, rmenlove, Scott H. Chew, ryanwilcox, Sandra Hollins, Allen Christensen, Becky Edwards, Jeremy Peterson, Wayne Harper, Dean Sanpei, Jack Draxler, Marc Roberts, Norm Thurston, Jon Cox, David Hinkins, Dixon Pitcher, Margaret Dayton, Richard Cunningham, Brian King, John Westwood, Marie Poulson, Eric Hutchings, pjones, Brad Wilson, Lowry Snow, Keith Grover, Steve Eliason, lwiley, Paul Ray, Justin J. Miller, Ken Ivory, Luz Escamilla, Patrice Arent, Ralph Okerlund, Daniel McCay, Raymond Ward, Jim Dabakis, Merrill Nelson, rogerbarrus, jvalentine, Kim Coleman, janicefisher, Jon Stanard, Susan Duckworth, Jacob Anderegg, Deidre Henderson, Rebecca Houck, John Knotwell, jseelig, Jim Dunnigan, Stewart Barlow, jmathis, Kevin Van Tassell, Scott Sandall, jbird, Keven John Stratton, Gene Davis, tcosgrove, Howard Stephenson, Brad Dee, Sophia DiCaro, Michael McKell, Joel Briscoe, Steve Handy, Wayne Niederhauser, Lee Perry, Scott Jenkins, Fred Cox, Francis Gibson, Curtis Oda, Val Peterson, Bruce Cutler, Don Ipson, Greg Hughes, Mark Madsen, Steve Urquhart, Doug Sagers, Dale Smith, Lyle Hillyard, Aaron Osmond, Timothy D. Hawkes, Kraig Powell, Earl Tanner, Peter Knudson, Mark A. Wheatley, Bradley Daw, screid, mbean, Brian Greene, Mike Schultz, lhemingway, Evan Vickers, jerryanderson, Carol Moss, Robert Spendlove, Craig Hall, Stuart Adams, Angela Romero, LaVar Christensen, Karen Mayne, Edward Redd, Brad Last, Melvin Brown, Gage Froerer, Justin Fawson, Kay Christofferson, David Lifferth, rgreenwood, Mike Kennedy, Todd Weiler, Curt Webb, Kay Mciff, Jerry Stevenson, petercorroon,
Subject: Medicaid Expansion Tax
Date: Tue Sep 29 20:15:10 MDT 2015
I have been informed that the Healthcare Reform Task Force is planning to propose a tax be assessed on certain Healthcare providers to pay for the cost of the Medicaid Expansion.  I understand that this proposal is to happen at the Healthcare Reform Tax Meeting on October 6, 2015.   I have been further informed by Medicaid that this proposal will include the taxation of ALL Home Health and Personal Care Agencies, including those that are not allowed to participate in the Medicaid program by exclusion from ACO contract, County Waiver contract, or by choice.  I have been informed further that this tax will NOT be assessed on hospice and other medical providers without explanation. 

The Utah Association for Home Care (UAHC), representing Utah's home health (HHA) and (PCA) personal care agencies, does NOT support this Tax/Fee on ALL HH and PCA providers because:
1)  a great majority of the HHA and PCAs are unable to participate in the Medicaid program, mainly due to exclusion by ACO and County Waiver contracts.  For most of these agencies, this exclusion is not by the agency's choice, but rather, the payers' choice.  A fundamental change to allow ALL willing providers to participate and, at a reasonable reimbursement rate, would at least create a level and fair playing field that would allow those agencies previously excluded to earn the revenues to pay the tax. 
2) PCAs provide "nonmedical" services.  If the Medicaid expansion plan includes providers that are nonmedical, then, why not tax any other nonmedical (and other medical that the proposal has decided not to tax) entity licensed under department of health? And, applying a consistent policy, as with PCAs, these other nonmedical entities would not have to have any participation with Medicaid or provide related services to be assessed the tax.
3) PCAs that are able to contract with Medicaid ACOs and County Waiver programs are reimbursed at rates that barely cover the cost of services rendered.  Additionally, most PCAs, and many HHAs, are small businesses that operate on very low profit margins.  Adding any tax, let alone this arbitrary and capricious one, will be very damaging for them.  
4) HHAs have been under significant financial duress by Medicare and Medicaid payers for years, losing about 3% revenues a year over the past 5 years.  As Medicaid ACOs and MedAdvantage plans become more prominent, rates are being cut even more drastically and payment methodologies are implemented that result in inaccurate and untimely reimbursement, causing HHA administrative and collection costs to rise significantly.
5) As providers are forced to raise rates to pay the tax or fail to survive, vulnerable clients' and their caregivers' ability to access affordable and reasonable healthcare and related services will get even worse.      

UAHC supports Medicaid Expansion.  UAHC does NOT support a plan to tax HHA and PCA providers to fund Medicaid Expansion because it arbitrarily excludes taxing certain medically-based entities while including many that do not participate in Medicaid and/or are not medically-based.  Additionally, this tax directly hurts small businesses and their employees.  If Medicaid ACOs are included in the list of those being taxed, HHAs and PCAs can expect further financial duress.  The end result of this proposed provider tax will be the opposite of the reason for Medicaid expansion; access to necessary healthcare and related services won't improve, but rather get worse.  Rather than creating this arbitrary and unfair system that fails our society at so many levels, the State must assure Medicaid expansion is funded through a process that at least levels the playing field.  And, this is best achieved by funding through its regular social welfare programs budgeting process.

Ed Dieringer, PT
Executive Director 
Utah Association for Home Care