Legal Advocacy Materials
- IHAC Comments in Opposition of the proposed Administration Cuts to the Health Safety Net
- Final Comments to MassHealth on EOHHS Payment & Care Delivery
- Legislative Testimony on CMSP Bill
HLA Attorney Andrew Cohen testified on Nov. 17, 2015 before the Joint Committee on Children, Families, and Persons with Disabilities on S. 66, An Act Improving the Children's Medical Security Program.
- HLA Comments on the ACA Non-Discrimination Provision
HLA submitted comments to the U.S. Department of Health and Human Services on Sec. 1557 of the ACA, which prohibits discrimination by health care entities receiving public funding.
- Final Comments on the Governor's Executive Order #562
HLA and Health Care for All submitted written comments to the Division of Insurance on #562, which requires all state agencies under the Governor's control to review their current regulations and eliminate "unnecessary" provisions based on certain criteria.
- Additional DOI Comments on State SUD Law
HLA Staff Attorneys Laura Goodman and Clare McGorrian submitted additional comments on June 15th, asking DOI to take a broad view of their services classified as residential where such services are legally required to be covered. These comments followed a second DOI listening session on Chapter 258 on June 9th.
- Federal Medicaid Parity Comments
HLA attorney Laura Goodman drafted and submitted comments on June 9, 2015 to the Centers for Medicare & Medicaid Services on proposed regulations implementing federal parity law in Medicaid managed care plans.
- DOI Comments on State SUD Law
HLA attorney Laura Goodman submitted comments to DOI on enforcement of Chapter 258 of the Acts of 2014, which requires certain coverage for SUD treatment.
- Final Comments from the Transgender Health Coalition
- HLA Comments on Proposed Health Safety Net Regulations
- Immigrants and Health Care Reform - An Advocacy Perspective
A 'white paper' report by HLA Executive Director, Matt Selig; Litigation Director, Lorianne Sainsbury-Wong; Staff Attorney/Parmet Fellow, Andrew P. Cohen and former HLA Staff Attorney, Monica McEnrue.
- HLA et al. Comments on Finalized Regulations for Implementing MHPAEA
- HLA testifies at State House on H. 1051 – an act preventing unnecessary medical debt
HLA's Gavriela Bogin-Farber testified at the State House on H. 1051, an act that establishes new charity care policies, debt collection practices, and procedures to prevent patients from incurring medical debt in the first place.
- HLA testifies at the Dept. of Public Health’s hearing on proposed closure of child psych. inpatient beds
- Congressional Mental Health Parity Letter
- State Legislators Mental Health Parity Letter
- HLA and other organizations commented on Division of Insurance proposed regulations on enforcement of Mental Health Parity, 211 CMR 154.00
- HLA and other organizations submitted comments to proposed regulatory changes to 130 CMR 450.117
- HLA submitted comments to the Connector Authority which had invited public input on the definition of Minimum Creditable Coverage
MCC is sound policy in the Commonwealth and ensures that health plans remain robust and provide residents with quality and affordable health plans that supplement the Essential Health Benefits under the ACA.
- HLA advocates for parity compliance in plans to be offered in 2014
HLA and 11 other organizations joined with the Association for Behavioral Healthcare to urge the Massachusetts Division of Insurance and the Health Connector to make sure that health plans offered through the exchange in 2014 comply with the federal parity law.
- HLA comments to MA Division of Insurance on parity regulations
HLA and a number of colleagues provided written comments to the MA Division of Insurance about crucial issues that the agency should address in their forthcoming parity regulations.
- HLA urges US Depts. of Labor and Health and Human Services to release final federal parity regulations as soon as possible
HLA advocated with the US Departments of Labor and Health and Human Services to urge the agencies to release final federal parity regulations as soon as possible, and to address problems that were not resolved by the existing interim regulations. Twelve organizations of consumer advocates and providers signed on to this letter with HLA.
- HLA submits comments to the Centers for Medicare & Medicaid Services regarding the revised definition of ‘lawfully present’ individuals
HLA specifically responded to regulations that eliminate eligibility from federally- supported ACA health insurance exchanges only as to Deferred Action Childhood Arrivals under the DREAM Act, who are generally young adults.
- HLA, other advocacy organizations and health insurers petition state officials to back multi-state health plan compliance with Mass. consumer protections
- HLA and HCFA Submit Comments to DOI on Regulating Risk-Bearing Provider Organizations
Health Care For All and Health Law Advocates provided comments to the Division of Insurance (DOI) regarding regulations implementing Section 216 of Chapter 224 of the Acts of 2012.
- HLA contributed amicus brief to help uphold ACA before Supreme Court
When the ACA was challenged in court, HLA helped defend the law with an amicus brief submitted to the United States Supreme Court on behalf of HLA, Health Care For All, Community Catalyst, Greater Boston Interfaith Organization, the Massachusetts League of Community Health Centers and the Massachusetts Hospital Association.
- HLA, HCFA and others submit comments on regulations implementing Affordable Care Act provisions expanding health insurance to those in low-income households.
- HLA Testifies on Massachusetts’ Emergency Dental Regulations
On August 11, 2010, Staff Attorney Audrey Perlow testified before the Office of Medicaid regarding the state’s recent cuts in adult dental services.
- HLA Joins Other Advocates Urging Strong Federal Parity Regulations
HLA, with advocates for health care consumers and providers, submitted comments urging the federal government to finalize regulations to broadly expand insurance coverage for mental health services.
- HLA Attorney Testifies at Attorney General's Discount Health Plan Regulation Hearing
Discount health plans, which are not insurance and do not meet Massachusetts’ mandate that all residents have minimum creditable coverage, are often marketed to consumers in intentionally confusing ways to give the illusion that they offer more healthcare coverage than they actually do. HLA attorney Audrey Perlow testified at the hearing, applauding the Attorney General’s decision to regulate discount health plans and offering suggestions to strengthen the proposed regulations.
- HLA Executive Director Testifies Before the Division of Health Care Finance and Policy
On Tuesday, March 16, 2010, HLA’s Executive Director Matt Selig testified before the Division of Health Care Finance and Policy on the issue of Health Care Provider and Payer Costs and Cost Trends. He testified with a panel of consumer advocates from Health Care For All, AARP, the Harvard School of Public Health, the Greater Boston Interfaith Organization and Community Catalyst.
Attorney Selig’s testimony described the extraordinary hardships faced by HLA clients who have excessive cost-sharing terms in their insurance plans or that bear cost of care that should have been paid by a third-party.
He submitted written testimony to the Division and made separate remarks at the hearing.
The Division is required by Massachusetts law to hold annual public hearings on the issue of health care cost.
- HLA encourages the Division of Health Care Finance and Policy to adopt additional low-income patient protections for Health Safety Net services.
HLA attorneys Matthew Fox and Lorianne Saisbury-Wong and Legal Fellow Mary Gribbon ask the Division to (1) confirm that medical providers are restricted in collection efforts; (2) protect consumers form collection efforts by the Division so long as the consumers cooperate; and (3) provide a safety net for low and moderate income consumers who are faced with unaffordable employer-sponsored health plans.
- HLA Clients Testify at Commonwealth Care Eligibility Regulations Hearing
HLA clients Linda, Rhonda and Sue speak out at a Public Hearing to demonstrate rising medical costs, increased medical debt, and a concern over consumers being uninsured as they transition between state subsidized health care programs.
Click here to read client testimony from the Public Hearing.
- HLA Comments on 956 C.M.R. 3.00 “Amendments to Eligibility and Hearing Process for Commonwealth Care”
HLA and its clients testified in-person at a Public Hearing regarding 956 CMR 3.00 Commonwealth Care eligibility regulations. HLA and its clients addressed the inequities in current regulations that terminate CommCare members who cannot pay their premiums and thereby lose all Free Care or Health Safety Net benefits, resulting in medical debt. HLA and its clients urge the Connector to maintain payment plan options for members with past due balances and to avoid narrowly interpretations of the Financial Hardship Waiver process for members who seek financial assistance with monthly premium payments.
Click here to read the comments submitted by HLA Staff Attorney Lorianne Sainsbury-Wong.
- HLA Comments on DOI Bulletin Regarding Mandated Benefits Under the State Mental Health Parity Laws
The Division of Insurance, working with the Department of Mental Health, issued a draft bulletin designed to outline, for providers, insurers and the insured, the types of intermediate and outpatient mental health services that are mandated benefits under the state mental health parity laws. HLA, with several other groups, submitted comments to DOI regarding their bulletin as we had numerous concerns about the effects of some of the language in the draft bulletin. Our comments, which were submitted in redline form on the draft issued by DOI, are attached along with a cover letter outlining our concerns.
- HLA Affordability Schedule Comment 03 06 09
HLA requests the Connector Board take no action to further increase the Affordability Schedule. HLA’s client base demonstrates that a broader definition of affordability and income is needed, especially in current economic climate. The Affordability Schedule should protect consumers from vulnerability to overall health care costs, not just premiums. HLA further emphasizes that even having health insurance is no guarantee that Massachusetts residents will avoid overwhelming medical bills.
- HLA comments to Medicaid re 130 CMR 450
HLA Opposes the Elimination of Non-Emergency Medical Transportation and Wheelchair Van Services. The proposed regulation will cut benefits now in place for certain MassHealth members. Specifically, the proposed regulation seeks to eliminate MassHealth member coverage for nonemergency ambulance and wheelchair van services for MassHealth members receiving MassHealth Essential, MassHealth Family Assistance with direct coverage, and MassHealth
- Comments on 114.6 CMR 13.00: Health Safety Net Eligible Services
- Comments on 956 CMR 5.00 “Minimum Creditable Coverage”
Minimum Creditable Coverage (“MCC”). The MCC requirements were created to “… provide individuals (and dependents) purchasing the coverage with financial access to a broad range of health care services, including preventive health care, without incurring severe financial losses as a result of serious illness or injury.” 956 CMR 5.01 Residents who do not have affordable and creditable health plans will pay a tax penalty for noncompliance with the Individual Mandate.
- Comments on key issues that respond to proposed changes to “MassHealth Citizenship and Immigration,” 130 CMR 504.00 and 518.00.
Health Law Advocates, Inc (“HLA”), Massachusetts Immigrant and Refugee Advocacy Coalition (“MIRA”) and Massachusetts Law Reform Institute (“MLRI”) comment on several key issues that respond to the specific proposed regulatory changes to 130 CMR 504.00 and 518.00 “MassHealth Citizenship and Immigration.” We also offer our suggestions as health care advocates for low-income, noncitizen, limited English proficiency residents of the Commonwealth.
- Support Letter: An Act to Improve, Promote and Protect the Oral Health of the Commonwealth (S 2478)
- HLA Urges State to Provide Retroactive Insurance Coverage for those Wrongfully Terminated
- Testimony regarding 956 CMR 3.00 “Amendments to Eligibility and Hearing Process for Commonwealth Care”
- Testimony re: Affordability Schedule in 956 CMR 6.00
- Testimony opposing a proposed rule that would leave consumers with ambulance bills
- Comments Relative to 956 CMR 3.00 and 956 CMR 6.00
- Comments to Proposed Changes to 130 CMR § 420.000 Dental Regulations
- Testimony on An Act to Improve the Oral Health of the Commonwealth SB 1217 / HB 2085
- Public Hearing Relative to EOHHS Budget Priorities
- Testimony Regarding Proposed Dental Services Rate Increases
- Testimony In Support of House Bill No. 2226 and Senate Bill 1277
- Testimony In Support of HB 2226 and SB 1277 and suggested changes
- Testimony Regarding Consumer Medical Debt and Fair Debt Collection Practices by Providers
- Testimony Regarding Dental Services 114.6 CMR 13.00: Health Safety Net Eligible Services
- Support letter: An Act Expanding Access to Dental Coverage & An Act Strengthening Health Reform
- Department of Public Health Testimony on Oral Health