Alliance Comments on Medicaid Proposed Rule

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Federal Policy Brief | February 19, 2013

Files: Medicaid Comments (PDF | 157 KB | 4 pages)

This is an excerpt from the document. To download the full document, please use the link above.

This resource provides the National Alliance to End Homelessness (the Alliance) comments on the  Medicaid Proposed Rule. Published on January 22, 2013, the proposal would implement various provisions of the ACA, including rules for Medicaid enrollment and eligibility, essential health benefits, and cost-sharing. The Alliance's comments address several issues that affect vulnerable adults who are chronically homeless, at-risk of becoming chronically homeless, or recovering from chronic homelessness in permanent supportive housing (PSH).

Access to health care is vital to ending homelessness. The most vulnerable homeless individuals are those who struggle with complex physical and behavioral health conditions, even after they have found permanent housing in the community (i.e., are no longer homeless). In fact, access to supportive services is the key to maintaining a stable housing situation, which in turn contributes to positive health outcomes.

Further, improving health and stability is a prominent goal of Opening Doors, the federal strategic plan to end homelessness, released in 2010. In particular, the federal plan calls for integrating primary and behavioral health care services with housing solutions, to “reduce people’s vulnerability to and the impacts of homelessness.” (Objective 7). Access to integrated housing and health care services is also part of the Strategic Plan’s approach to reducing the risk of homelessness among young adults who have been in foster care as children. (Objective 8).

The Alliance actively supports the federal agenda to end homelessness, including its emphasis on housing and health together. To the extent that health care reform can advance integration in community-based service delivery for vulnerable populations, we have a close interest in ACA rulemaking.

Through various provisions, the ACA encourages states to expand Medicaid eligibility and service capacity, while increasing state flexibility to serve vulnerable people in the community, including those who experience chronic homelessness. In addition, the ACA modernizes processes for enrolling people in Medicaid, promising more timely and streamlined access to services. The Alliance's comments address Medicaid enrollment procedures, coverage of former foster youth, and cost-sharing requirements.