Overview - MassHealth has proposed changing its benefit for durable medical equipment (DME) in ways that would effectively end the hearing healthcare benefit currently in place for MassHealth members. This change has been proposed during the pandemic with very little public notice. Hearing Partnership/Beauport Hearing Care submitted the following comments:
As a licensed hearing health care practice in Massachusetts, we see many patients with MassHealth benefits. We find that many persons with MassHealth face physical, emotional, and financial challenges that inhibit them from accessing services and optimal care. In general, MassHealth must morally ensure that persons with disabilities and their providers are able to focus as much time and energy as possible on addressing patient disability and need. It is cruel to require persons with disabilities and their providers to spend extra time and energy overcoming administrative hurdles and excessive requirements to qualify for benefits and payments for necessary durable medical equipment (DME).
- More restrictive Medicare rules must NOT be the basis for MassHealth to deny paying for durable medical equipment (DME). If a person needs DME for a medical reason, benefits and DME must be easily accessed. And the provider administrative burden to obtain payments must be as simple and easy as possible. In this way, providers and patients are able to focus on care and treatment to secure optimal health benefit for the patient. Moreover, MassHealth adoption of restrictive Medicare rules that do not cover DME hearing aids would immediately terminate all of our MassHealth patients from receiving the hearing healthcare they need to function and live normal lives.
- MassHealth rules and policies must not require unnecessary appeals of denial of claims for DME by Medicare and other health insurance providers. If DME is covered by MassHealth, then MassHealth should pay for it when another payer will not. Requiring appeals of such denials by other payers would only add unnecessary administrative steps that serve no purpose whatsoever. Such an unnecessary administrative burden is cruel to patients with disabilities and their health care providers. Focus should always be the best health interests of the patients.
- MassHealth must not be allowed to deny paying for DME whenever there is a conflict between MassHealth rules and sub-regulatory documents. Sub-regulatory documents have not been subjected to the same kind of notification, public comment and consultation as rules that have been devised through a full regulatory review process. The full rule-making process allows the public to comment and influence how rules are written and later interpreted. MassHealth must NOT deny claims to pay for DME on the basis of policy that has not been vetted by the public rulemaking process.
Thank you for the opportunity to comment.
Submitted via email to email@example.com on July 20, 2020.