Tag: 1332

GHF submits comment to federal government about Governor’s revised private insurance proposal

On July 9, 2020, Georgia’s Governor announced that his administration had revised his 1332 private insurance proposal. The new proposal consists of two parts:

  1. A reinsurance program to lower premiums; and
  2. The Georgia Access model—which would separate Georgia from healthcare.gov but would not replace it, instead directing consumers to insurers and web brokers to shop and enroll in coverage.

After a 15-day public comment period during which more than 600 comments were received from the public, Georgia’s Department of Community Health made no changes and submitted the proposal to the Centers for Medicare and Medicaid Services (CMS) for their review on July 31.

CMS deemed the waiver application complete on August 17. The designation began a 30-day public comment period, allowing Georgians, health advocates, and any other interested party to weigh in on the revised proposal. Because of technical difficulties with the comment submission link, the comment period was extended another seven days to September 23, 2020.

More than 1800 individuals and organizations commented during this time, including GHF. You can read GHF’s full comment letter here.


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GHF comments on Governor’s revised private insurance proposal

On July 9, 2020, Georgia’s Governor announced that the state was re-opening the public comment period on his 1332 private insurance proposal. The proposal was considerably revised since it was last considered in February of this year. The new plan still consists of two parts:

  1. A reinsurance program to lower premiums; and
  2. The Georgia Access model—which would separate Georgia from healthcare.gov but would not replace it, instead directing consumers to insurers and web brokers to shop and enroll in coverage.

Other provisions of the previously proposed Georgia Access model were dropped (cap on financial assistance, new kinds of health plans, etc.).

The Governor’s announcement began a 15-day public comment period on the new proposal, allowing Georgians, health advocates, and other interested parties to weigh in. Along with more than 600 others, GHF submitted comments to communicating our deep concerns about the plan’s continued shortcomings. You can read GHF’s full comments here.


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GHF comments on Governor’s proposed reinsurance program

On December 23, 2019, the Georgia Department of Community Health (DCH) submitted Governor Kemp’s 1332 private insurance proposal to federal health officials.

The plan consists of two parts:

  1. A reinsurance program to lower premiums; and
  2. A dramatic erosion of the ACA’s rules and structures, including provisions that privatize insurance enrollment; cap the financial assistance available to low- and middle-income consumers; and erode consumer protections in private insurance

DCH’s submission of the proposal to the Centers for Medicare & Medicaid Services (CMS) comes after a 30-day public comment period, during nearly 1000 Georgians weighed in with their opinions on the plan. Despite the overwhelming opposition to the second part of his plan, Governor Kemp and DCH sent the proposal to federal officials with no meaningful changes.

On February 5, 2020, Governor Kemp wrote a letter to requesting that the reinsurance program be considered separately from the second part of his proposal, and that CMS’s consideration of the second part of the plan be paused. CMS responded to Governor Kemp on February 6 in a letter that deemed the reinsurance program application complete and requested more information about the remaining parts of the Governor’s proposal.

CMS’s response began a 30-day public comment period on the proposed reinsurance program, allowing Georgians, health advocates, and any other interested party to weigh in.

GHF, along with several partner organizations, submitted a comment communicating our support of the reinsurance program, while noting our deep concerns about the remainder of the Governor’s proposal. You can read the full comment letter here.


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GHF comments on Governor’s health care proposals

In March, Georgia’s Governor and state legislature approved SB 106, legislation that allows the state to pursue an 1115 “waiver” to make changes to Georgia’s Medicaid program and a 1332 state innovation waiver to make changes to private insurance in the state. (Waivers allow a state to set aside or “waive” certain requirements imposed by the federal government and try new models of providing health coverage and care.)

In June, the Governor hired Deloitte Consulting to develop the proposals for Georgia’s Medicaid program and the private insurance market. Five months later, on October 31st and Nov. 4th respectively, Governor Kemp announced the details of his proposed plans.

The Governor’s proposed 1115 Medicaid waiver, called Georgia Pathways plan, would allow Georgians with incomes below the poverty line to enroll in Medicaid coverage but only if they can meet monthly work requirements (at least 80 hours per month of work, school, training, or volunteering per month). The plan would cover only a fraction of those who could be covered by a full Medicaid expansion.

The Governor’s proposal to re-shape the state’s private health insurance market consists of two parts:

  1. A reinsurance program to lower premiums; and
  2. A dramatic erosion of the Affordable Care Act’s rules and structures, including provisions that privatize insurance enrollment; cap the financial assistance available to low- and middle-income consumers; and erode consumer protections (like the requirement that health plans cover essential health services).

This plan would result in many Georgians who currently have health insurance becoming uninsured or underinsured.

The announcement of the Governor’s plans kicked off a 30-day public comment period during which Georgians impacted by these proposals, health advocates, health care industry stakeholders, and others could weigh in on the plans. 

Georgia’s 1115 waiver process. Note: the 1332 waiver process runs through the Department of Insurance, rather than Community Health

The Governor’s Medicaid proposal does not go far enough towards closing Georgia’s coverage gap and his plan to dramatically scale back the ACA in Georgia would turn back the clock on Georgians with pre-existing conditions and consumers who need financial help to afford private coverage, among many others. GHF submitted comments to state officials communicating our deep concerns about both plans. You can read GHF’s full comments here:


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The Georgia Access Plan: A Bad Deal for Consumers

Cover Georgia logo

On November 4, 2019, Governor Brian Kemp released a draft plan that, if approved, would drastically undermine comprehensive coverage for the 417,000 consumers who now have comprehensive coverage through the marketplace. Federal law allows states to make changes to the Affordable Care Act (ACA) so long as a comparable number of Georgians have coverage that is at least as comprehensive and affordable as they would have under the ACA, and the changes do not increase the federal deficit. Even under the most forgiving interpretation of these guardrails, Governor Kemp’s proposal fails to meet the test.

Fortunately, there’s still time to fight back! The state is required to seek public comments on this plan and will be accepting comments until December 3, 2019. Comments can be submitted online at CoverGA.org, at in-person comment hearings. This is an opportunity for Georgians to tell state leaders how this plan will impact their health and finances, and the health and finances of their loved ones.

Instead of undermining the coverage that so many Georgians rely on, state leaders should focus on preserving critical consumer protections, strengthening comprehensive coverage, investing in outreach and enrollment to Georgia communities, and working to address the rising health care costs for low-and middle-income Georgians. 


Hannah, a Georgia mom who says “My family can’t survive without the ACA.”

Disrupts coverage for more than 400,000 Georgians with a privatized marketplace 

Governor Kemp’s proposal seeks to expand coverage to approximately 30,000 out of more than one million uninsured Georgians at the peril of those consumers currently enrolled in comprehensive coverage using a risky new program. 

At the center of his plan, Governor Kemp aims to decentralize how consumers currently enroll in individual market coverage in favor of private web brokers and insurers. This means that consumers would no longer have an unbiased place to compare plan options and instead would be forced to rely on private entities who would have the incentive to enroll consumers in plans that offered the highest commission and not necessarily the plan that best fits their health needs.

Likely result: Georgia consumers will struggle to navigate numerous websites, translate the sales lingo of insurers, and disentangle conflicting information. For many, it may be harder to find in a plan that they feel good about.


Limits financial assistance, increasing out-of-pocket costs

Along with dismantling healthcare.gov, Governor Kemp plans to restructure financial assistance in a way that would raise premium costs for comprehensive coverage and likely cause many Georgians to lose coverage altogether. Under his plan, consumers could use financial assistance to purchase skimpier coverage, like short-term plans, that don’t have to meet the ACA’s minimum standards. Additionally, his plan doesn’t address whether or not cost-sharing reductions would be required, which currently help to lower deductibles and other out-of-pocket costs for certain low-income consumers. As a result, Georgia consumers should expect to pay more out-of-pocket to get the care they need.

To make matters worse, because financial help is based on premiums for comprehensive coverage that will likely become more expensive under this plan, providing financial help to all eligible Georgians will cost more than what is currently budgeted. This means that some consumers who currently receive (or are eligible for) financial help would lose this valuable benefit.

Likely result: Premiums for comprehensive coverage will rise. At the same time, fewer Georgians will receive financial help to purchase coverage. Georgians will pay more out-of-pocket when they need health care.


Katherine, a Georgian with a pre-existing condition and ACA coverage

Weakens consumer protections

In order to allow private companies to run enrollment, the Governor’s plan seeks to eliminate crucial consumer protections. The protections that may be suspended include the requirement that insurance plans include enough doctors and hospitals so people can get care (called “network adequacy”); requirements about what information insurers must provide to consumers and how that information is presented; and mental health parity, which requires insurers to cover mental health services in a similar way as other health care. The Governor’s plan assumes these new skimpy plans will provide 90% of the benefits that comprehensive coverage under the ACA provides. There is no explanation or evidence to support this assumption.

Removing the requirement to cover the ten essential health benefits and mental health parity threatens access to critical services for many consumers with pre-existing conditions. For example, treatment and recovery services for people with substance use disorders would be threatened at a time when the state continues to struggle with opioid-related deaths and substance use disorders in general. These consumer protections enable people with mental illness and substance use disorders to obtain insurance that covers their conditions without bankrupting them. Without them, consumers will have to pay out-of-pocket for life-saving care, opening them up to thousands of dollars of medical debt.

Likely impact: Skimpy plans that do not offer basic health services like prescription drugs, maternity care, or mental health services will become commonplace. As a result, Georgians will have a harder time accessing needed care and will pay more out-of-pocket.


The bottom line is Governor Kemp’s plan is terrible for Georgians. Any rational analysis will find it doesn’t meet even the laxest requirements of federal law. Georgians should weigh in today to reject this plan!   


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Philip’s story: Rural Georgians continue to struggle without health coverage

Philip is a 57 year old part-time roofer who resides in Fort Gaines, Georgia, a rural community in the southwest region of the state.

Philip suffered a knee injury along with a herniated disc in his back while repairing a roof. Because he is uninsured he has been repeatedly refused medical care because of his inability to pay. Despite making financial sacrifices to see several doctors and specialists, he has been unable to receive adequate help and get the treatment he needs. Philip says that if he had health coverage he would find the right specialist, get an MRI, and have his back fixed so he would no longer be in severe pain every day.

For the time being, Philip is able to see Dr. Karen Kinsell, the last practicing physician in Clay County. Dr. Kinsell is a volunteer physician who provides medical care to approximately 3,000 patients in a small office building that once served as a Tastee Freeze stand. Dr. Kinsell has advised Philip to stop roofing in order to ease the pain in his back but roofing is currently his family’s only income and Philip says there are no other viable job options for him in the area.

Philip believes access to health care is important and that significant changes need to be made so more people can access care. “Fix the issue, fix the problem, health insurance isn’t affordable for low-income people trying to work. Help us.”

Like Philip, 360,000 low-income Georgians, many of whom are uninsured, live in small towns and rural areas across the state. These areas have the most at stake in the debate over whether or not to close Georgia’s health insurance coverage gap. For rural Georgia residents like Philip, health coverage would open doors to the physicians and other health services that they need to stay employed or get back to work. For rural communities like Fort Gaines, more residents with health coverage could attract another primary care physician to the area.

Right now, Georgia’s policy makers are drafting two health care “waivers”. One of the waivers could be used to extend coverage to all low-income adults, including Philip and his southwest Georgia neighbors. Or state leaders could continue to ignore the needs of low-income, rural Georgians with a more limited plan.

The details of these waivers will be announced in the coming weeks and state leaders must offer online and in-person opportunities to hear public feedback. GHF will keep you up-to-date about what the waivers will mean for Georgians like you and Philip, and help you weigh in during the public comment periods!


Your story is powerful! Stories help to put a human face to health care issues in Georgia. When you share your story, you help others understand the issue, its impact on Georgia, and why it’s important.

Your health care story is valuable because the reader may be your neighbor, friend, someone in your congregation, or your legislator. It may inspire others to share their stories or to become advocates. It is an opportunity for individuals who receive Medicaid or fall into the coverage gap, their family members, their physicians and concerned Georgia citizens to show that there are real people with real needs who will be impacted by the health policy decisions made by Congress and Georgia’s state leaders.

Share your story here!


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