Advocates' comments on proposed MassHealth regulations implementing ACA-related changes

In mid-October MassHealth released an extensive set of proposed changes to the MassHealth and Health Safety Net regulations related to implementing the Affordable Care Act and amendments to the 1115 Demonstration on  Jan. 1, 2014. These changes will end MassHealth Basic, Essential and the Insurance Partnership and create two new MassHealth programs, CarePlus and the Small Business Premium Assistance Program, change the current way income is counted by using Gross Income to a methodology based on taxable income called Modified Adjusted Gross Income (MAGI) and many other changes. Attached are comments filed on Nov. 5, 2013 supporting many of the policy decisions, asking for clarification of many specific provisions and urging changes to certain harmful proposals such as restricted home nursing benefits in CarePlus.