25 April 2012

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Richard J. Gilfillan, M.D. Acting Director

Center for Medicare and Medicaid Innovation

Centers for Medicare & Medicaid Services

7500 Security Boulevard Baltimore, MD 21244

Dear Dr. Gilfillan:

The National Minority Quality Forum, and the co-signing organizations listed below, are writing to join with other concerned citizens groups to express our apprehensions about the proposed changes to the manner in which benefits for some Medicare enrollees are financed and provided. Our specific reference is to the state-based demonstrations of financial models to integrate care for Medicare and Medicaid dually eligible enrollees. We are aware of, and share, the concerns that have been communicated to you by patient advocacy groups and other organizations, but our issue with these demonstration projects is more fundamental.

According to CMS data, there are approximately 9 million dual eligibles. They encompass some of the poorest, the sickest and the costliest segments of the Medicare population. Moreover, dual eligibles face many other challenges in accessing care. They are more likely to be minorities, have disabilities, suffer from mental conditions, have educational disadvantage, or live in rural areas where care providers are more scarce.

As others, we are concerned that these demonstration projects could:  Cause disruptions to continuity of care and the resulting risk for poor or compromised outcomes of the care, and thus increased financial risk for the system;

• Compromise access to essential health and medical services;

• Create a third-class of beneficiary that will no longer have the protections associated with the Medicare social insurance safety net;

• Lead to the abrogation of the rights of these dual eligible, who will be massenrolled into programs that are economic experiments at best, and low-income healthcare gulags at the worst; and

• Employ metrics to measure the failure or success of these demonstrations that prioritize economic efficiencies over quality of care and outcomes of care.

We have a more fundamental concern, however. We have been watching with everincreasing dismay the endless promulgation of regulations, rule-making, and April 25, 2012 Letter to Richard J. Gilfillan, M.D. Page 2 implementation of demonstration projects which threaten to overwhelm our healthcare market. The proposed demonstration projects that this letter references are just another example of a CMS-sponsored activity that is not driven by or responsive to beneficiary demand, but is based on what, in our view, is a complete misread of how the Medicare and Medicaid programs can provide real value to the American people in shaping our future.

This avalanche of regulations and demonstration projects seems to be emanating from the idea that consumer demand for healthcare in general, and in the Medicare and Medicaid programs more specifically, will necessarily have undesirable consequences. To thwart these rising consumer expectations, there is a belief that government intervention is needed to suppress them by instituting price controls, shifting costs to beneficiaries, reducing the availability of new therapies while promoting older, less expensive treatments, and micro-regulating the practice of medicine.

Government should not be alarmed by a rise in consumer demand for healthcare. The American population is both aging and becoming more ethnically diverse. For each group there will be increased demand for quality healthcare. Rather than an undesirable factor, this is the type of consumer demand that can power our economy, ushering in a new era of American prosperity — an age in which we have a healthier, more productive, and more competitive workforce and business sector. Historically our economy has thrived on this kind of market opportunity. Government should play an active role in encouraging it to build capacity for the emerging healthcare market. We look forward to discussing these issues with you.

Sincerely,

Gary A. Puckrein,

PhD President and CEO

Co-Signers:

Mervyn M. Dymally, PhD, President, Central Neighborhood Health Foundation

Bambi W. Gaddist, DrPH, Executive Director, South Carolina HIV/AIDS Council

Loretta Jones, Founder & Executive Director, Healthy African American Families, Phase II

Randall Maxey, MD, PhD, Executive Director, Community Life Improvement Program

Curren D. Price, Jr., JD, State Senator (District 26), California State Assembly

Aubry Stone, President/CEO, California Black Chamber of Commerce

Andre Williams, Executive Director/CEO, Association of Black Cardiologists, Inc.

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About The Forum

The National Minority Quality Forum (NMQF) is a 501(c)(3) not-for-profit, non-partisan, independent research and education organization. The vision of NMQF is a health services research, delivery and financing system that provides quality and effective health services to the biodiverse American general population of the 21st century. NMQF helps assure that national and local quality improvement initiatives are informed by scientific evidence, and place a priority on the quality of care and patient outcomes in all populations.