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As requested, the Medicaid Study Group has drafted comments to DSS on current design proposals for MQISSP, CT’s Medicaid reform plan. The Medicaid Study Group, with over twenty independent consumer advocates, has taken a deep dive into the health reform literature and the experience of Medicaid reforms in other states, and providing feedback and recommendations to DSS as they design MQISSP. Our latest comments address concerns about networks that include non-person-centered medical home (PCMH) practices. We are especially concerned about the danger of internal cherry-picking which could result in moving patients who need it most out of PCMHs, and overspending in the program by segmenting risk and generating false “savings”. We offer suggestions to mitigate that risk. The comments also address communications, governance, entity oversight, Community Care Team inclusion, the role of SIM’s CCIP program, procurement, and shared savings methodology and distribution.