Dion Trahan, Esq., LL.M.

Our last and next president has tried to distance himself from #Project2025, claiming he "has no idea who is behind it." But it was developed by a broad coalition of conservative organizations, spearheaded by the Heritage Foundation, perhaps the leading conservative think tank in the U.S., "for the next conservative administration." And at least 140 people who worked in the Trump administration had a hand in Project 2025. These include Roger Severino, the Trump appointee who led the HHS Office for Civil Rights through its many successful efforts to rescind regulations clarifying civil rights in health care and drastically expand the rights of health care providers and staff to deny their patients essential care. Severino currently serves as Heritage's VP of Domestic Policy and authored Project 2025's plans for HHS: a frightening playbook to narrow health care access (including abortion) and related civil rights across the entire country, using mechanisms that will affect those in seemingly "safe" states (e.g., those that have passed ballot initiatives and legislation to strengthen state abortion rights). I previously wrote about some of the plan's most frightening proposals for Medicaid, the ACA, and Section 504 of the Rehabilitation Act in the National Health Law Program blog post below. It doesn't stop there. Six of his former Cabinet secretaries co-authored or collaborated on Project 2025. Four of his ambassadors and several enforcers of his racist immigration agenda were involved. About 20 pages are credited to his first deputy chief of staff. Democracy Forward has a great resource summarizing what Project 2025 will mean to the American people, called "The People's Guide to Project 2025." https://lnkd.in/e79aAJxe. As Democracy Forward writes, "these threats aren't hypothetical. These are their real plans." It's important to not give into despair. We cannot give up hope; we must keep fighting to hold the line on health care access and democracy at large. But first, for those who have not already done so, it is time to understand and steel yourselves for what's to come. https://lnkd.in/epmRHi8Y

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"Last year, #Maryland established the Maryland Commission on Public Health to recommend improvements for delivering public health services, including how to reform how it uses technology and shares data." Without steady funding, public health agencies slow to upgrade old tech, report shows via StateScoop https://lnkd.in/eCJ5pZUY

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More evidence that #Medicaid state-directed payments (SDPs) to hospitals are out-of-control (see Table 1) and fueled by hospital provider taxes (see Figure 14). It's even worse than it appears because some states, like North Carolina (not included in table below), are adding new taxes to pull down additional SDPs for behavioral health facilities. This isn't just bad for the federal budget and for all the other health care needs that are shortchanged (like community mental health), but as behavioral health facilities raise their commercial prices, more families--at a time of terrible distress-- will incur medical debt. There are so many other unintended consequences like over-hospitalization likely to occur from this policy. In Delaware, they've enacted a hospital provider tax for the first time (not shown below) to draw down SDPs. Delaware only has 6-8 acute care hospitals (including 1 children's hospital) and 3-4 systems, depending on how you count them. One large system with 1,000+ beds by itself can drive the average commercial rate higher by raising its prices, thereby effectively setting its own Medicaid rates. All this federal Medicaid funding is going to pad hospital margins while in most states home care aides are making $10-$15/per hour and nursing facilities say they can't afford better staffing ratios. States can and some do use state-directed payments to increases long-term care wages, but hospitals resist using "their" provider tax revenue to fund non-hospital SDPs. LTC doesn't have the capacity to leverage provider taxes the way hospitals can and has to rely on state general fund dollars to finance services. Massachusetts and New York (see report) want to add provider taxes on health plans. This could cascade provider taxes on top of each other, further compounding the impact on the federal budget and the commercial market, including ACA marketplaces, undermining affordability for ACA consumers and working families. It's not going to be fun or easy to halt this enormous inequitable shift in health care resources, but halt it we must. KFF Shawn Gremminger Claire Brockbank Joshua Gordon https://lnkd.in/eDteMcJT

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A recent report has unsurprising findings about the challenges in accessing and assessing Medicaid HCBS, and includes a necessary call for improving how Medicaid HCBS is delivered! "A maze of federal legal authorities has resulted in inconsistent and inequitable access to [long-term] care among [Medicaid] beneficiaries and across geographies. The many programs are difficult to understand, even for researchers and regulators trying to measure outcomes." #Medicaid #longtermcare #caregiving #HCBS

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Very exciting news from HHS, CDC and OCCHE! Today, the Centers for Disease Control and Prevention (CDC) and the Agency for Toxic Substances and Disease Registry (ATSDR), in partnership with the U.S. Department of Health and Human Services (HHS) Office of Climate Change and Health Equity (OCCHE) and HHS Office of the Assistant Secretary (OASH), have released the Heat and Health Index (HHI) as the latest in a set of tools and resources intended to improve the nation’s ability to stay safe during heat events.  The HHI combines historic temperature data and Emergency Medical Services (EMS) data on heat-related emergency responses from the past three years, as well as data on community characteristics, including pre-existing health conditions, socio-demographic information, and characteristics of the natural and built environment, to provide a final heat and health index ranking by ZIP code, which can be used to empower strategic, data-informed decision-making. Access the HHI and explore its capabilities at https://lnkd.in/git_9mMa. This link will guide you to the landing page of the Heat and Health Tracker; please click on “Heat and Health Index” in the left navigation pane of this landing page to access the HHI.

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Register Today! PENNSYLVANIA DEPARTMENT OF HEALTH Data Modernization Initiative overview at https://lnkd.in/egT3Whi This presentation will provide an overview and background of the Data Modernization Initiative focusing on “What is DMI?”, highlight the CDC’s public health data strategy and explain how the public health data strategy aligns to the initiatives at PA Department of Health. We will highlight our work creating modernized data foundations, formalizing data governance, and how we are educating our staff on data and DMI related initiatives. Muneeza Iqbal, MPH, Rae Ann Ginter, Ariana Winder & @Kelly Friday

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There are some excellent recommendations in this thoughtful article focused on advancing state based Medicaid innovations (particularly CMS speeding up the 1115 review and approval process) yet would be strengthend by recommendations for support for fundamental research on the ROI from managed care 15% cost ($72 billion in 2023) of administrative services focused on MCO/State redundancies, rate impact on non-participating providers, and value based payment model(s) impact on the SPMI, SED, Child Welfare, and other high needs/cost populations. #pushingthemargin

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CMS’ newly finalized rules on #Medicaid access, managed care, and HCBS aim to modernize the framework for defining, measuring, and enforcing the standards for access to care in Medicaid and #CHIP. Sharing this helpful summary from my colleagues that outlines the key details of the rules and implications for enrollees, states, providers, and managed care organizations: 

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Another section of the #FinalRule has been released by #CMS aimed at enhancing #access to and #transparency of #Medicaid services, including #HCBS. This rule pairs with two other final rules published in April 2024 that focus on improving Medicaid #eligibility and access to Medicaid services. This rule is focused on an #FFS system, but the impact could involve changes to underlying FFS rates in base #data for #ratesetting and program #oversight in #MLTSS. Dianne Heffron and Meredith Mayer of Mercer US Government have conducted a review of the proposed and finalized rules. https://bit.ly/3QuGRXe

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Ahead of #WHA77 next week, GHTC is urging policymakers to prioritize and advance policy reforms on #AMR, maternal and child health, #TB and #NTDs, and #PandemicPreparedness to deliver a more fit-for-purpose, equitable R&D ecosystem. https://lnkd.in/e6QbT_Xu

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CMS’ “Year 2” IRA Guidance Concedes Agency Patient Engagement Has Been a Bust A number of patient groups have quietly expressed frustration with #CMS’ “listening sessions” on the #InflationReductionAct “fair price” negotiations. If you read CMS’ “year 2” guidance carefully, it effectively admits the patient complaints are real and legitimate. The Complaints: Patient groups sat on the sidelines in the litigation challenging the constitutionality of the IRA, at least in part, because they believed that they could shape IRA implementation through agency engagement. But some groups are now expressing frustration. They expected CMS to explain how it was approaching negotiation and the underlying evaluation of the selected drugs. With that context, they expected to be able to provide meaningful feedback to CMS’ plans and preliminary assessments. According to the groups I have spoken to, that is not how things have gone. CMS is tight-lipped—in “listen only” mode. Unclear what CMS is considering and how it sees the “value” question, “patient interaction” on the IRA has devolved into CMS and patient groups staring at each other blankly. Confirmation: When you read the “year 2” guidance, it confirms the patient complaints. Deploying diplomatic “regulatory speak”, CMS says it “intends to improve upon the design of the patient-focused listening sessions”. Note the reference to “listening sessions”—confirming the agency has been in “listen only” mode. CMS admits the need for change, saying it “is soliciting comments from interested parties on event format, scope, and logistics”; it then indicates it “is considering events where there is discussion among speakers and in which CMS may ask clarifying questions”. But even this proposal isn’t getting to the core of the problem—patient groups shouldn’t have to be expert mind readers regarding CMS’ intent based on a few interspersed “clarifying questions”. CMS offers some other alternatives, too: “CMS is also weighing different event formats, such as round table sessions on broader topics with a mix of speaker types (e.g., patients, providers, and health data experts) or focus groups on targeted topics with one speaker type (e.g., patients or caregivers)”. But all that doesn’t commit CMS to doing any speaking. Just that others—patients, providers, and “experts” will be asked to speak. Patient groups can’t react in, or to, a vacuum. No Time: The guidance concedes that they can’t fix the problem for “year 1”. After all, July 31, 2024 is the deadline for manufacturers of selected drug to accept or reject CMS's final MFP offer. Indeed, CMS acknowledges that its proposed changes in patient engagement will be effective only “for…price…year 2027”. So, in another words, at least for “year 1”, we are going to get “fair prices” that don’t reflect meaningful patient input. #drugdevelopment #drugpricing #Medicare #managedcare #rarediseases #patientsfirst #lifesciences

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National Association of Medicaid Directors #13November2023 #IssueBrief : #Why #did #they #do #it #that #way? "Check out NAMD’s latest issue brief to learn more about #Medicaid #eligibility #policy."

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💰 Yesterday the Congressional Budget Office published a report on the cost of #obesity medications that, not surprisingly, shows they come with a high price tag. The cost to #Medicare was estimated to be $35 Billion from 2026 through 2034. ⚕ The Academy of Nutrition and Dietetics supports access to obesity medications, but we are committed to #PartB services including intensive behavioral therapy (#IBT) as a frontline treatment that stands alone or is used in combination with other therapies. The #CBO report is not a score for the Treat and Reduce Obesity Act (#TROA) because it does not estimate costs of both the Part D and B sections. We are committed to working with policy makers and our BGR Group partners to continue to advocate for comprehensive care. 📖 Read the Academy's statement for more information! https://lnkd.in/efYqgV_M 📣 If you are interested in joining our advocacy efforts, join us for the monthly MNT Access Advocacy Affinity Group. https://lnkd.in/eTyEEbJ8 https://lnkd.in/ekG3xeQp

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Interesting perspective on #TechnologicalDebt in health care by Dave Lamar focused on the provider market, but we seem the same issues within state depts and payers. While good data governance practices are key, there must be a better way to solve this common - if not universal - challenge in health care, if only by offloading some of the administrative responsibilities that require the individual management and administration of no-value-add administrative functions. #healthdata

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MACPAC met last week and released new data showing HUGE increases in Medicaid state-directed payments. Make no mistake--it's SDPs for hospitals, funded w/provider taxes and IGTs, driving this growth. MACPAC noted that the link to better HOSPITAL access is tenuous at best for these payments. We'll have a new Congress and Administration in January, and this spending category is surely going to be a target--even if Florida and Texas hospitals are among the biggest beneficiaries of this spending. We've been here before (yeah, I'm old enough to remember). Those of us who care about #Medicaid need to call for hard caps on these payments, more accountability from those who receive them, and shifting them out of expensive hospital systems and into community-based care. And provider taxes must be reformed, too, so that they are more re-distributive and fund a range of high-value services. Rebecca Pifer MACPAC - Medicaid and CHIP Payment and Access Commission #Medicaid

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KFF #HealthData Drop: How States Are Spending Opioid Settlement Funds I wasn't planning on posting today, but... KFF Health News, w/ the incredible Johns Hopkins Bloomberg School of Public Health (the most productive #PublicHealth policy shop in the country IMO) and Shatterproof, just released detailed results from its 50-state survey of how states are spending $6B+ in #opioid settlement funds. Upshots: ▶️ 90k+ Americans died of overdoses in the year ending Jul. 24, w/ rates continuing to rise in Black and AI/AN communities (see previous post) ▪️ FYI: The Oregonian / OregonLive.com and Elizabeth McCarthy just reported that #OR state deaths grew by 33% in 2023 to a new state record (i.e., the #opioidepidemic continues to rage) ▶️ State and local govts received $6B in settlement funds in 2022/23, of which: ▪️ 1/3 has been committed ▪️ 1/3 is being reserved for future use ▪️ 1/3 is "untrackable" (I'll come back to this) ▶️ Opioid settlement payouts are expected to total ~$50B over the next two decades. So this is a bit of a warm up. ▶️ Of the ~$2.1B in committed settlement funds: ▪️18% to addiction and mental health treatment ▪️15% to recovery services ▪️11% to harm reduction efforts ▪️10% to prevention programs ▪️41% to a bevvy of "other" programs ▪️Not enough to babies to address neonatal abstinence syndrome So three additional observations: ▶️ KFF/JHU found that govts spent $240M+ on purposes that did not qualify as opioid remediation. While settlements allow for spending up to 15% of funds in this way - i.e., state "TPA" services? - its use highlights the challenges in addressing systemic issues as other interest scavenge for funds. ▶️ Untrackable? Really? Govts should be able to report how every dollar of revenue is spent. It's a cornerstone of #GoodGovernment. From the article, one activist was quoted stating: "When people know that people aren’t watching and there’s no accountability, then they can kind of do what they want... That’s why we have to have some kind of database and accountability.” Glad KFF/JHU is bringing the #Transparency. ▶️ My amazing Empire State of #NY gets a special shout-out and case example from KFF, allocating $22 million for programs that make the "gold standard" of care as accessible as possible. Nice work. * KFF Article here: https://lnkd.in/eGFT9fbV h/t to author Aneri Pattani + to Samuel C. Roods and Claudia Williams who taught me what "h/t" means OR Live Article: https://lnkd.in/e2KcStJd

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Within the new #hti2 rule are some critical signals: 1. It is a joint effort between Office of the National Coordinator for Health Information Technology (ONC) and Centers for Disease Control and Prevention —and also heavily influenced by recent rules from Centers for Medicare & Medicaid Services 2. #mfa (multi-factor authentication) is called out as required in some use cases 3. #ai algorithms for #caremanagement will need to be more transparent. 4. It attempts to harmonize #tefca from the The Sequoia Project 4. It sets specific versions of USCDI, and #fhir. https://lnkd.in/edb7NpaZ

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Do you have a plan? Environmental Public Health is uniquely able to provide the first and best proof of value for AI use in public health. The permits, inspections, and related documents are public records, making them great training data for an LLM. Add in all the regulations, research, and training materials every local EH operation has and the ability to keep the public informed is unparalleled in any other field of public health. If we work with the industry, like adding IOT devices to see real time temperatures and hand washing practices, the AI systems could be a food manager alert system between inspections and support a food safety culture. Alternately, building a machine learning tool with image recognition could make onsite sewage system inspections faster and more reliable. This is just scratching the surface. make a plan to participate as this technology evolves. It will be ubiquitous within this decade.

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