From: Ed Dieringer
To: Legislative Fiscal Analyst Office Dropbox,
Subject: Fwd: UAHC opposes the current Utah Access+ cost sharing plan
Date: Mon Oct 12 00:02:07 MDT 2015

---------- Forwarded message ----------
From: Ed Dieringer <>
Date: Sun, Oct 11, 2015 at 6:00 PM
Subject: UAHC opposes the current Utah Access+ cost sharing plan

To The Utah Healthcare Reform Task Force:

I was disappointed that I was on the October 6th Meeting Agenda to speak for our association and then was passed over.  Therefore, this letter is now submitted as public comment to Utah Access+ cost sharing plan.   

TheUtah Association for Home Care supports Medicaid Expansion to assure access to healthcare, improve health outcomes, and better manage healthcare costs.  Unfortunately, the Utah Access+ cost sharing plan, dually taxing home health agencies (HHAs) and their professional staff while failing to assure sufficient reimbursement, and in most cases, any reimbursement at all, is a plan unable to achieve the intended ends.  Without the benefit of improved earnings to pay for the taxes levied, the trajectory is not only unsustainable but also counter-productive, leading to loss of businesses and quality healthcare professionals, less access to healthcare, decreased ability to improve health outcomes, and increased costs to all. For this reason UAHC does not support the current Utah Access+ cost sharing plan. 


Home Health is already under significant financial stress with yearly reimbursement cuts from all payers. Medicaid ACOs and commercial payer reimbursement rates already fail to cover the costs of HHA skilled services.   With no ability to shift costs to clients, HHAs will only suffer greater losses when the Utah Access+ plan levies its taxes.  The imagined benefits in this plan become penalties instead.


Of particular note is that most HHAs in Utah are excluded from participating in ACOs and Commercial insurance plans.  These HHAs have absolutely no ability to recoup the assessed tax except to increase workloads, and/or cut wages and benefits to employees.  Professional employees may leave the State or move to another more profitable industry, while less skilled employees could end up relying on the state for their healthcare benefits or, under this plan, could potentially become uninsured.  I see unnecessary escalation of healthcare and insurance costs to the state and fewer providers to pay an increasing tax, rendering this plan unsustainable and a probable death knell for Utah’s many HHAs that are small businesses.  In fact, this plan is the antithesis of improved access to healthcare, better health outcomes, decreased costs, and preserving a highly skilled workforce. Further, it violates Utah’s espoused goals to support a thriving and competitive small business environment.


Medicaid Expansion cannot be built on the backs of a healthcare service providers and their employees, particularly when those providers and employees do not have the opportunity to increase revenues to pay the Utah Access+ tax.  UAHC expects that, even prior to any additional fees being added, at least 30% of Utah's Medicare certified home health agencies will be operating at a loss in 2016.  The Utah Association for Home Care looks forward to participating in creating more productive, sustainable solutions.  


Respectfully Submitted: 

Ed Dieringer, PT, Executive Director

Utah Association for Home Care   801-487-8242

Ed Dieringer, PT
Executive Director
Utah Association for Home Care
Utah Hospice and Palliative Care Organization