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Twenty-two independent consumer advocates signed a letter sent Friday to CMMI voicing concerns about CT’s SIM application. While advocates have many concerns, the letter focuses on the sudden planned shift to shared savings payments in Medicaid. Concerns include the prospect that shared savings incentives could drive inappropriate underservice and that state’s quality and financial monitoring resources will not be able to detect harm to people or financial gaming of the system. Shared savings is a very new payment model that other, more mature, health systems in other states are struggling to implement. CT’s recent failed HUSKY managed care program was driven by similar financial incentives; since we moved away from those incentives quality of care is up, costs are down and more providers have joined the program.

The independent advocates’ letter asks CMMI in negotiations over the grant application to require the state to return to the more reasoned, progressive Medicaid plan in the December SIM “final plan” – to first pilot shared savings through the thoughtful, consensus-led Medicaid health neighborhood program for dual eligibles very close to implementation. This would allow the state to identify challenges, learn from them, test solutions and evaluate results — improving the chances of sustainable success and limiting harm to people.