NAMI Montana's Comments on the Montana Medicaid HELP Demonstration Waiver

Dear Montana DPHHS,

Congratulations on the draft of your HELP Demonstration Waiver. We are very grateful for your work—particularly for the focus on developing a strong indirect validation process for the community service requirements. We believe these indirect processes will prevent a significant number of unfair disenrollments.

We have three recommended changes to the HELP Demonstration Waiver:

A. Ensure Direct Validation Does Not Begin Until Indirect Validation Is Functional

Pages 13 and 14 describe the Indirect and Direct Validation processes for the Community Service Requirement. NAMI Montana applauds DPHHS’s reliance on indirect validation, which will reduce the communication burden on Montana enrollees, DPHHS employees, and DPHHS contractors. This will be a critical step forward for Montana Medicaid.

However, we recommend clarifying that Montana Medicaid will not begin any Direct Validation processes until the majority of Indirect Validation processes are functional. This will ensure that Montana DPHHS fully focuses on developing functional indirect validation processes—reducing bureaucratic red tape and preventing unfair disenrollments.

B. Reduce the Disability Rating Requirement for Exempt Veterans from 100% to 50%

Page 12 lists population groups exempt from the Community Engagement requirement. One exempt group is currently described as:

“A veteran with a disability rated as total under section 1155 of title 38, United States Code.”

We believe a 50% disability rating is more appropriate, particularly due to a provision within the Veterans Administration’s rating system that recognizes some veterans with a 50% rating may have service-connected disabilities that prevent them from maintaining substantially gainful employment. This is known as Total Disability based on Individual Unemployability (TDIU).

While it may be possible to expand the definition to include TDIU, that would still exclude veterans with a 50% rating who are currently in the process of being evaluated for TDIU. For that reason, we recommend changing the language from “total” to:

“50% or more.”

C. Add Mental Health Programming as Criteria to Prevent Disenrollment

Page 16 describes criteria that can prevent disenrollment when there is an issue with paying premiums, including:

“Participation in any of the following healthy behavior plans developed by a health care provider or a third-party administrator, if any, or as approved by DPHHS.”

We recommend adding:

“Mental health prevention program designed to support recovery from mental health symptoms for a person or their family.”

Montana DPHHS supports a variety of these programs through the Behavioral Health Block Grant, such as NAMI Peer-to-Peer, Family-to-Family, Connections Support Group, and Family Support Group. Including these programs would be consistent with other programming designed to address obesity, cardiovascular conditions, and related health challenges.

Thank you very much for your consideration. Please let us know if you have any questions.

Sincerely,

Matt Kuntz, JD, MHA
Executive Director
www.namimt.org