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Beverly Mackereth, Secretary Pennsylvania Department of Public Welfare Health & Welfare Building 625 Forster Street Harrisburg, PA 17120 Submitted via email to ra-PWHealthyPA1115@pa.gov Re: Draft Healthy Pennsylvania 1115 Demonstration Application Dear Secretary Mackereth, Thank you for the opportunity to comment on the Draft Healthy Pennsylvania 1115 Demonstration Waiver Application (Healthy PA). The Philadelphia Department of Behavioral Health and Intellectual disabilities Services ( DBHIDS) has submitted comments that highlight the major concerns for our behavioral health community however, I wish to add additional comments on behalf of Community Behavioral Health (CBH) the not for profit administrative entity that administers the Behavioral Health Program on behalf of Philadelphias 470,000 Medicaid recipients. We believe, as DBHIDS has commented, that Medicaid Expansion is in the best interest of the individuals that we serve; however, in the absence of that opportunity, we strongly recommend that individuals with any behavioral health challenge as self identified or as determined by a physician or other health care practitioner be provided the opportunity to be enrolled in the behavioral health HealthChoices program. For individuals with behavioral health needs, Medicaid administered through the HealthChoices Behavioral Health program provides health insurance that supports a comprehensive array of integrated behavioral health services to prevent, treat and support individuals recovery in our community. Commercial Insurers have limited expertise and a poor track record in Pennsylvania in treating individuals with behavioral health needs. Medicaid and community safety net programs were established because commercial insurers abandoned individuals with behavioral health needs by establishing discriminating lifetime limits, offering limited benefit options, and implementing differential co-payments and deductibles. The Insurance Federation, representing commercial insurers, in the late 1980s and early 1990s fought vigorously against any mandated mental health benefit, or parity in benefits, and successfully limited the parity bill offered under the Ridge Administration to adding only nominal benefits for individuals with Serious Mental Illness. Parity was not fully supported until Pennsylvania legislation was passed in 2009, following the passage at the federal level. 1|Page
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Respectfully submitted,
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