June 30, 2019

Utah Department of Health

Division of Medicaid and Health Financing
PO Box 143106
Salt Lake City, UT 84114-3106
Attn: Jennifer Meyer-Smart

Re: Utah’s 1115 Per Capita Cap Waiver Application

We the undersigned members of the Utah Medical Care Advisory Committee (MCAC) are
opposed to changes proposed to Utah Medicaid as part of the 1115 Per Capita Cap Waiver
application which could risk the health and security of many Utah Medicaid beneficiaries.
As an advisory committee, we believe that many of the components and programs
proposed in this waiver application undermine the objectives of the Medicaid program and
the stated goals of the waiver which is “to furnish medical assistance [to individuals and
families] whose income and resources are insufficient to meet the costs of necessary
medical services and rehabilitation and other services to help such families and individuals
attain or retain capability for independence or self-care.” 42 U.S.C. § 1396- 1(1). These are
unprecedented changes with the potential for serious consequences in Utah and across the
nation. The advisory committee opposes:
• The per capita cap funding mechanism, which has the potential to put the financial
stability of the Medicaid program at risk by reducing available federal dollars.
• The request to limit participant enrollment, which could deny many the coverage
they need.
• The community engagement requirement, which could add administrative
complexities and barriers for Medicaid participants to receive needed care.
• The request to waive EPSDT benefits for 19-20 year olds, which will leave many
young adults without cost-effective prevention, screenings and early detection
services.

As members of the state Medicaid advisory committee, we wish for our opposition to these
programs and components to be included as part of state and federal comment record. The
proposed changes will make it more complex and difficult for Utah Medicaid participants to
access the care they need to improve their circumstances and become self-sufficient. We
urge state and federal officials to not move forward with these programs and components.
Thank you,

Chairperson: Dr. William Cosgrove

Provider Representative - Utah Physicians

Vice-Chairperson: Jessie Mandle

Consumer Representative - Consumer Advocate Groups/Non-Governmental Social Service
Agencies

Member-at-Large: Jennifer Lloyd

Provider Representative - Community Health Centers

Danny Harris
Consumer Representative - Senior Citizen Populations

Stephanie Burdick
Consumer Representative - Utah Independent Living Centers/Individuals with Disabilities

Adam Montgomery
Consumer Representative - Mental/Behavioral Health

Christine Evans
Consumer Representative - Medicaid Recipients

Gina Tuttle
Provider Representative - Local Health Departments

Joey Hanna
Consumer Representative - Medicaid Recipients/Individuals with Disabilities

Mary Kuzel
Provider Representative - Utah Pharmacies