Proposed Medicaid rules will create new barriers to employment; reduce public safety
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  • on April 12, 2018 -

Proposed Medicaid rules will create new barriers to employment; reduce public safety

Access to employment is essential to a meaningful second chance for justice-involved people. It is also good public policy: it promotes public safety by reducing recidivism, it increases the number of available workers for businesses, and it adds taxpayers to communities.

Unfortunately, some well-meaning policymakers adopt counter-productive and exclusionary policies that create more barriers to employment for justice-involved people.

Medicaid rules proposed by the Michigan Department of Health and Human Services (MDHHS) last October are a good example of a counter-productive policy.

The proposed Provider Fitness Enrollment Criteria (1635-PE) governing providers’ participation in Michigan’s Medicaid program would terminate a provider’s enrollment in Michigan’s Medicaid program if the provider, any agent of a provider, or any other professional providing services under Medicaid, has a been convicted of a federal or state felony or misdemeanor within the last 10 years.

A wide range of provider and advocacy organizations were extremely concerned about the impact of these rules, especially on the ability to employ peer counselors, who play a key role in Michigan’s response to the opioid crisis. Prior justice-involvement is key to peer counselors’ effectiveness with these patients.

MDHHS received over 300 opposing public comments about the proposed rule before the November 2017 deadline, including from CAPPS. The rule was also opposed by the Behavioral Health and Developmental Disabilities Administration – another unit of MDHHS.

Though the new rules were scheduled to go into effect on January 1, the public outcry led MDHHS to withdraw them for revision based on the public comments. CAPPS is among the organizations monitoring the rewriting of these rules closely and will report on any new developments.

Read>> MDHHS Notice of Proposed Policy

Read>> Behavior Health and Development Disabilities Administration opposition letter to Margo Sharp dated November 15, 2017

Read>> CAPPS opposition letter to Margo Sharp dated November 17, 2017

 

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