Ohio's Proposed Changes to White Part B and OhDAP

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Greetings, The Ohio Department of Health has redrafted a new set of White Part B eligibility rules and has begun a public comment period on those draft rules. I have attached the PDF copies of the draft rules as well as have provided the links below. I have tried to translate the effects of these rules into a more understandable format. 3701-44-03- Administrative rule that explains an overview of the new restrictions in the program as listed in Appendix A (New Medical guidelines) and Appendix B (New Financial Guidelines)This section also lists the ability of the Director to Restrict, Reduce or terminate programs subject to available funding. The most troublesome language in this section is that there is no mandate to give anyone any notice of any changes prior to implementation. THESE CHANGES INCLUDE ALL RYAN WHITE PART B PROGRAMS. Appendix A – Medical Guidelines – The guidelines in this section would apply to anyone that was placed on a waiting list for OhDAP services. This rule could be interpreted as to include clients who were placed on a waiting list because of an expired or incomplete renewal application. The term Nadir means the lowest CD4 count of a HIV positive person. There is no mention to a crucial element in HIV care which is the Viral load. Appendix B- Financial Guidelines- The guidelines in this section at this time mandates that the Income limit is 300% of the Federal Poverty Line or approximately $ 32,670 for a single person.The Chart for the Federal Poverty Level for different percentage or household sizes may be found at: http://www.coverageforall.org/pdf/FHCE_FedPovertyLevel.pdfAgain, this section will give the Director the ability to singlehandedly change the income guidelines AT ANYTIME WITH NO NOTICE to a level as low as 100% of the Federal Poverty Level. In addition, if these draft rules are enacted, the Department will not have to solicit any input from the community regarding any future changes. Also, the memo states that the White Part B Clinical Subcommittee is in support of the medical guidelines. Any support for the changes in Financial Guidelines is absent. It is crucial that ODH receives written comments for and against regarding these draft rules by January 23, 2012. Therefore, it is requested that this information be distributed very widely throughout your own networks to ensure a vigorous community response. We will keep you posted when the rules change from a DRAFT status to a PROPOSED status. http://www.odh.ohio.gov/ASSETS/4535DE108EDD41C0B76BF5B74619FD88/DR44-MIP.pdf Memo http://www.odh.ohio.gov/ASSETS/89A613A800194939B243D6EAC726E8D0/DR44-03.pdf 3701-44-03 http://www.odh.ohio.gov/ASSETS/05C749AB62574049B74356D90B2574AB/FR44_03-ApdxA.pdf Appendix A Medical Guidelines http://www.odh.ohio.gov/ASSETS/55B3E2940670479A97D636BD63162054/FR44_03-ApdxB.pdf Appendix B: Financial Eligibility Guidelines for OHDAP/HIPP/Spenddown. Thank you,