News | Go Solutions Group

The Honorable Kathleen Sebelius
Secretary, U.S. Department of Health and Human Services
7500 Security Boulevard
Baltimore, Maryland 21244

Re: Comments on Proposal 2287-P2

Dear Secretary Sebelius:

Go Solutions Group, Inc, on behalf of itself and the hundreds of local education agencies it services strongly supports enactment of CMS 2887-P2. We thank CMS for taking steps to rescind the final rule that would have eliminated federal Medicaid reimbursement for school-based Medicaid administrative and transportation services.
In response to your request for comments addressing the scope and nature of problems that would result if the final rule were implemented, we are convinced that Rule 2287-F would restrict availability of critically needed services to a particularly vulnerable group of children. Eliminating funds for school-based outreach and enrollment assistance at a time when there are currently more than six million children in America who are eligible for Medicaid but who are not enrolled in the program, makes little sense.

Additionally, elimination of Medicaid funding for transportation services otherwise covered under a State Plan unfairly discriminates against school providers and precludes them from accessing the federal match as intended by Congress. Problems associated with rule implementation would pose far more significant harm than any problems that might result from rescission of the final rule. There is insufficient evidence to support the approach taken by the final rule and we encourage CMS to investigate other, more appropriate methods of fulfilling its oversight role.

We agree that CMS can accomplish the objective of Rule 2287-F without eliminating critically needed federal funding of school-based Medicaid administrative and transportation services. CMS has already increased its administrative oversight following reports of improper claiming. Go Solutions Group, Inc. recommends that CMS further promote sound Medicaid program operation through clear guidance and technical assistance specifically addressing the unique settings and circumstances in which school-based services are delivered. Clarifying methodologies that allow schools to access funds legitimately available for Medicaid program services and administrative activities will provide the most effective means of serving beneficiaries while ensuring proper and efficient program administration.

We commend the Department on the proposed rescissions. The sweeping changes to longstanding practice contained in all three rules would inappropriately shift costs for mandated Medicaid benefits entirely to the states and erect new barriers to the timely delivery of necessary services. We also believe that the federal rulemaking requirements were not met for any of the three rules, in that the analyses of the fiscal impacts on consumers, individual industries, federal, state or local government agencies or geographic regions were not conducted, there was no discussion of the relative merits of alternative policies, and there was no determination of whether and how the proposed changes could affect family well-being.

As Congress wrestles with the complex task of defining a comprehensive national health care system, it would make no sense to allow a regulation to stand that would devastate the financial underpinnings of an existing health services delivery system.

Thank you for your consideration of our comments.


Go Solutions Group Inc.
5840 Enterprise Drive
Lansing, MI. 48911
1-800-260-2544