House overrides minimum wage veto
On a vote of 100-49, the House voted to override Gov. Phil Scott’s veto of the minimum wage bill. The bill will raise the state’s minimum wage to $11.75 in 2021, and $12.55 in 2022, and ties minimum wage increases to inflation after those years. The current minimum wage is $10.78 and would have increased simply based on inflation next January 1.
The governor issued a statement following the override. “My concerns for this bill – based on fiscal analysis from the Legislature’s Joint Fiscal Office – have been that the negative impacts on Vermont’s economy, workers’ hours and jobs will outweigh the positive benefits, especially in our more rural areas.”
Later in the week, Joyce Manchester, Legislative Joint Fiscal Office reviewed a slide presentation describing the cost impact of the minimum wage on Medicaid providers. She noted that 75 percent of the costs for home and community based providers are attributable to wages, and that 90 percent of those wages are below $15 an hour. For home and community-based services she estimated an impact of about $600,000 for six months. The impact on facility-based services was also significant.
Several members of the committee noted that their local agencies have encouraged them to focus more on Choices for Care rates and program losses because market wage pressures have increased their wage costs.
Panel passes insulin bill
On a vote of 6-0-1, the Senate Finance Committee advanced S.296, a bill a bill that limits a beneficiary’s total out-of-pocket expenses for insulin medications to not more than $100 per 30-day supply, regardless of the amount or type of insulin needed. The $100 out-of-pocket spending will be applied to the individuals yearly deductible.
Committee proposes miscellaneous health care bill
The House Health Care Committee discussed areas to be addressed in an omnibushealth care committee bill on Tuesday. Committee member Anne Donahue, R-Northfield, led the committee discussion.
Once drafted, the bill will:
- Attempt to address affordability issues by allowing individuals or families with income levels up to 500 percent of the federal poverty level be eligible for premium assistance above 400 percent;
- Require insurance companies, the Green Mountain Care Board, and interested stakeholders to prioritize access to primary care and consider additional health care services not currently covered by insurance when designing plans for the 2022 plan year;
- Require that the Brattleboro Retreat be subject to the GMCB hospital budget review process;
- Transfer the costs of inpatient psychiatric care from the Department of Mental Health to the Department of Vermont Health Access in order to ensure equal access to mental health care in a manner equivalent to physical health care; and
- Require the Department of Financial Regulation to review the 2017 Milliman Research Report and assess whether commercial health insurers are meeting their obligations to ensure equal access to appropriate mental health care.
The committee will also consider adding the following to the committee bill:
- 796 – Directs the Agency of Human Services to develop recommendations on ownership of personal medical records.
- 826 – Changes statutes that uses “physician” with “health care provider” in order to recognize current prescribing for providers within their scope of practice.
- Establishes the council as envisioned in the Department of Mental Health “Vision 2030: A10- Year Plan for an Integrated and Holistic System of Care.”
Health care panel provides funding priority requests to the Appropriations Committee
The House Health Care Committee spent many hours over the past two weeks gathering budget testimony and crafting a letter to the House Appropriations Committee detailing their FY 2021 budget recommendations. Completed and approved late last Friday, the letter sets out the committee’s funding priorities, and administrative budget proposals they support, as well as proposals from the administration that they cannot support.
The recommendations include:
- Appropriating $100,000 to provide bridge funding for the Psychiatric Urgent Care for Kids program in Bennington to continue serving children in grades K-9 that are experiencing a mental health crisis while the organization seeks sustainable funding from OneCare or other sources;
- Providing $177,000 to the Department of Mental Health to expand the Zero Suicide prevention strategy and directing DMH to fully integrate its efforts with OneCare Vermont’s Zero Suicide initiatives;
- Allocating $223,000 to Pathways Vermont to enable its peer-supported warmline to be staffed 24/7;
- Allowing the Department of Vermont Health Access to manage HIV and AIDS-related medications by establishing a preferred drug list and will grandfather current and future Medicaid beneficiaries who are stabilized on a medication that may not be on the PDL;
- Appropriating $500,000 to the Rutland mobile crisis response unit;
- Providing $1 million in nursing scholarships at all levels (Gov. Phil Scott had proposed a $1 million tax credit for nurses); and
- Providing $370,000 in medical school scholarships for the University of Vermont Larner College of Medicine.
The House Appropriations Committee will be reviewing all policy committee memos over the next few weeks as they formulate its proposed budget to present to the full House in mid to late March.
Human Services Committee provides priorities to House Appropriations Committee
Joining other policy committees, the House Human Services Committee provided comments in response to the Scott administration proposed FY 2021 budget. The committee began by saying a level-funded budget is a misnomer and is actually a decrease in spending.
The committee recommendations include:
- Fully funding the higher case rate within Children’s Integrated Services;
- Supporting the Child Care Financial Assistance Program as recommended by the Governor;
- Providing for the operation of the Woodside Juvenile Detention Center past the proposed closure date of July 1 due to committee concerns that this is an unrealistic closure date;
- Supporting the Governor’s proposal to decentralize the General Assistance emergency housing and shelter services, but suggests an additional year of further planning;
- Rejecting the Scott administration proposal to zero out funding for the Micro Business Development Program as proven strategies to reduce poverty, to build the economy, and create economic security for low income Vermonters;
- Addressing the Choices for Care Moderate Needs Group waiting list by spending the one percent reserve;
- Providing $1.87 million in statutory home inflation; and
- Funding $1 million for the sustained home visiting program.
Panel continues discussion on Older Vermonters Act
The House Human Services Committee reviewed the latest draft of the Older Vermonters Act. The purpose of H.611 is to help aging Vermonters live independently and it describes a system of services, supports, and protections for Vermont residents 60 years of age or older. Rep. Theresa Wood, D- Waterbury walked the committee through the language changes.
The bill puts into law annual reports to the legislature by the Department of Disabilities, Aging and Independent Living regarding the Adult Protective Services Program. It establishes a Strategic Action Plan on Aging to be developed by the Secretary of Administration, in collaboration with DAIL and the Vermont Department of Health. The Strategic Plan would be implemented across state government, local government, the private sector, and philanthropies. It will provide strategies and cultivate partnerships for implementation across sectors to promote aging with health, choice, and dignity in order to establish and maintain an age-friendly state for all Vermonters.
The bill provides much-needed examination of the long-term care Choices for Care program reimbursement rates. It instructs the Department of Vermont Health Access and DAIL to conduct a rate study of reimbursements to Choices for Care home- and community-based service providers and report back to the legislature by January 2021. The study will establish a predictable schedule for Medicaid rates and rate updates and will identify ways to align Medicaid reimbursement methodologies with those of other payers. The bill also sets in place a procedure for establishing an annual inflation factor for home and community-based services in Choices for Care.
The committee will return to the bill after Town Meeting Week break.
Panel hears from retail druggist on GMCB authority over prescription drugs
Vermont Retail Druggists President Jeffrey Hochberg appeared before the Senate Health and Welfare Committee on Wednesday to support S.246, a bill that gives the Green Mountain Care Board authority over prescription drug costs. Hochberg said in order for the state to effectively control prescription drug prices, two things must happen: reduce the Pharmacy Benefit Manager’s control over the system through regulation and change the paradigm without causing systemic collapse.
Hochberg said the time has come to rewrite the fundamentals of an overly complex and expensive system. To do so, the state must achieve a sense of perspective so that it can better control and monitor continual efforts, as is proposed in S.246. He said the system is broken and pharmacy benefit managers are exerting far too much control over prescriptions drugs and have little to no regulatory oversight. He said there is no transparency in the system, there is no effective financial regulation of the system, there are potential consumer fraud issues, and there is no ability to fully monitor the effectiveness and impact of programs. The result is patient costs are rising, access is declining, and demographic needs are increasing.
Hochberg provided draft language for the committee to consider when the legislature returns from Town Meeting break. He encouraged the committee to consider identifying any potential partnerships, including sole source wholesale acquisition and distribution, that would further enhance the Board’s capability to analyze and monitor prescription drug products, the effect on consumer costs, and the effect of other prescription programs.
Panel advances Emergency Service Provider Wellness Commission
On Thursday, the Senate Health and Welfare Committee advanced S.243, a bill that would establish an Emergency Service Provider Wellness Commission. The large commission, established within the Agency of Human Services, would confidentially report health and wellness data on emergency service providers and recommend policies, training, legislation and services that increase support for the providers to improve health outcomes, job performance and personal well-being.
A provision that would expand the Emergency Services Fund to pay all emergency service providers licensure and certification costs was removed from the bill and will likely be addressed in another bill.
Senate committee passes Interstate Nurse Licensure Compact bill
The Senate Health and Welfare Committee on Tuesday unanimously passed S.125, a bill that would authorize Vermont to adopt the Interstate Nurse Licensure Compact. Participation in the Compact would allow registered nurses and licensed practical nurses to practice in other Compact states without having to obtain individual state licenses. There are currently 34 states that have adopted the licensure compact. The intent of the bill is to address the severe nursing shortage in the state and to reduce Vermont’s costly dependence on contract nurses.
The Office of Professional Regulation will begin accepting applications for multistate licenses in March of 2021.
The committee rejected a second amendment that would have made the compact adoption contingent on the conclusions of a study on the potential impact of the compact on Vermont nurses. The study also would have examined salary differentials between regular nurses and contract nurses. Both the committee and OPR Director Lauren Hibbert believed that the Rural Health Task Force adequately covered the issue.
Senate panel reviews proposal to create an Agency of Health Care Administration
The Senate Government Operations Committee reviewed S.297, a bill that would create an Agency of Health Care Administration. Legislative Counsel Jen Carbee said the bill proposes to split the current Agency of Human Services into two agencies: the Agency of Human Services and the Agency of the Health Care Administration. If approved, the transfer would be complete by Jan. 1, 2023.
Sen. Jane Kitchel, D-Caledonia, said this is not the first time she has introduced this bill. Health care is our second highest area of spending and her main reason for proposing this is for accountability.
Kitchel said the legislature should look at proper function alignment. State government has siloed funding and this way of thinking allows the legislature to be comfortable with the current system. She feels two separate agencies could provide better accountability and potentially save money.
The committee will hear from AHS Secretary Mike Smith on March 11.
Groups respond to GMCB comments on health care reform bill
On Wednesday, the Senate Health and Welfare took additional testimony on S.290, a bill that proposes a long list of regulatory changes for entities regulated by the Green Mountain Care Board. The discussion focused on proposed revisions presented during the first round of testimony, primarily from the GMCB. The committee heard from provider trade associations and OneCare Vermont.
OneCare Vermont Chief Operating Officer Sara Barry reminded the committee that the state is still in the infancy of healthcare reform efforts under the All Payer Model and now is the time for patience and watchfulness as we let these new efforts percolate. Barry said it is too soon to make dramatic changes; we need to give these efforts a chance to work. Barry addressed language on multi-year relationships between the accountable care organization and providers. OneCare’s current arrangement with its participants is via a multi-year contract that extends through the entire term of the All Payer Model Agreement. Each year participants have a non-renewal clause they can activate. A non-renewal might happen if, for example a hospital board makes the determination that the financial risk of continued participation is too high.
Barry said OneCare cannot support making its workforce salary increases dependent on shared savings. The goal of the APM is to create predictability and stability for the system and it would be shortsighted to have its success or failure tied to shared savings or losses. She supports the bill’s contemplation of a two-year budget and reporting cycle. She proposed adding language to require an annual review of existing reporting requirements that would identify opportunities to align and streamline documentation, rather than add additional burden. Her testimony can be found here.
Vermont Medical Society Executive Director Jessa Barnard said VMS’s support for the APM has in part been premised on the fact that ACOs are providerâ€‘led and providerâ€‘directed. While VMS supports oversight and transparency for Vermont’s ACO, VMS is concerned that some of the requirements could add another administrative burden to already overburdened health care providers. She supports the requirement that at least one member of the GMCB be a licensed health care professional, but she also offered an alternative, a part-time or full-time Chief Medical Officer staff position on the GMCB. Finally, she recommended the committee consider extending existing provider bargaining group provisions to private payers. This would allow physicians and other health providers to collectively enter negotiations with insurers when and if such a need arises, rather than with every contract entered.
Vermont Association of Hospitals and Health Systems Vice President of Government Affairs Devon Green reiterated testimony from last week and stressed that providers need stability and predictability as the state moves forward with health care reform. She said the state already has its goals through the all payer model and to require news goals year after year would destabilize health care reform efforts.
Bi-state Primary Care Association Director of Vermont Policy Helen Labun agrees with comments made by OneCare and VAHHS. She recommended striking all references to “Preferred Provider Organizations” as this refers to participation in a specific federally-funded program via VDH which has its own requirements and review process. To bring their entire organization into a new regulatory structure as part of program participation is unreasonable.
Committee advances telehealth legislation
The House Health Care Committee advanced H.723, a bill to require health insurance reimbursement for expanded telehealth services. The bill would require reimbursement for a category of telehealth services, store-and-forward, which is commonly used for provider-to-provider consultations, also known as eConsults. Although health care systems regularly use eConsult technology for a wide range of specialties, Vermont statutes allow reimbursement only for dermatology and ophthalmology services.
The committee added legislative intent language that states increasing Vermonters’ access to health care services through expansion of telehealth services will be done without increasing social isolation or supplanting the role of local, community based health care providers throughout rural Vermont.
Panel reviews legislation to eliminate cost-sharing for primary care
The Senate Finance Committee took additional testimony on Thursday from Green Mountain Care Board Health Policy Advisor Michele Degree and Department of Vermont Health Access Director of Legislative Affairs Nissa James on the results of a study required by Act 17 of 2019. The committee requested the testimony as part of its consideration of S.245, a bill that proposes eliminating cost sharing requirements for primary care.
Degree and James said the stakeholder working group achieved consensus for a definition of primary care that met participants’ expectations and is in alignment with the Milbank Memorial Fund report. Notable findings from the stakeholder working group include:
- The stakeholder working group achieved consensus for a definition of primary care that met participant’s expectations and conveyed broad understanding, and was in alignment with the Milbank Memorial Fund report;
- Use of that definition resulted in a calculation total primary care spend (claims-based and non-claims-based) of 10.2 percent for primary care in 2018, but percentages both differed by payer and were calculated with data limitations necessary for consideration prior to any conclusions being developed;
- Claims-based or traditional fee-for-service primary care spend was 8.9 percent in 2018, but percentages both differed by payer and were calculated with data limitations necessary for consideration prior to any conclusions being developed;
- Approximately $86 million in prospective capitated payments for primary care and acute services are not included due to data limitations that did not allow the group to quantify the proportion of primary care spending with sufficient accuracy;
- A consistent methodology for reporting and analyzing “would have paid” or “shadow” claims across providers and payers is needed to more precisely determine the proportion of health care spending allocated to primary care; and
- Future analysis would also benefit from the tracking and analysis of utilization metrics.
Next steps for this bill are unclear.
Committee passes mental health mobile response pilot
On a vote of 4-0-1, the Senate Health and Welfare Committee passed S.302, a bill that establishes a mental health mobile response unit pilot program in Rutland county. The committee also reduced the appropriation from $600,000 to $400,000, although it was noted that the committee will not have the final say on the amount.
Committee passes board of medical practice license changes
The House Health Care Committee passed H.438 on Thursday. The bill is largely clean up language to amend the laws of the Board of Medical Practice to align with current practice. The legislation includes a change in the reporting of disciplinary action. After extensive negotiations with provider organizations, an agreement was reached for reporting by employers in cases where actions put patient safety at risk are known to the employer, but never known to the Board.
Regional planning commissions expected to develop plans against climate change and health risk
The Senate Health and Welfare Committee heard testimony on both S.185 and S.225 on Thursday and are likely to combine both bills. S.185 directs the Department of Health to develop a climate change response plan for the state and to develop a communication plans that establishes responses to climate change related health risks with the regional planning commissions. S.225 directs RPCs to identify health care related needs in each region. Concerning S.225, Senior Fiscal Analyst Nolan Langweil said that his initial understanding was that the RPCs do not have any expertise in health care or the resources.
But the RPCs appeared up to the task. The RPCs asked to also be included in the development of the climate change response plans outlined in S.185. RPC representatives also suggested proposed plans integrated to existing plans where possible to reduce the resource demand. The committee requested that the RPCs return to the committee with any suggested language, an outline of what is currently being done with emergency disaster responses, how to find people in need, and how RPCs link in with the Department of Public Safety and local governments during disaster events.
E911 Board Executive Director, Barb Neal provided an overview of the Citizens Assistance Registry for Emergencies, a voluntary registry of any potential challenges an individual could encounter in an emergency such as medication needs. The program was a success in Lamoille County during Tropical Storm Irene. The program links the individual’s information into the 911 database and would be available before, during, and after a disaster hits. Sen. Ginny Lyons, D-Chittenden, said, “We don’t want to regulate and control everything, but we want something in statute about a coordination system and getting that information out there. Everything you’ve been doing has been outstanding.”
Vermont health providers may be held liable for out-of-network referrals
The Senate Finance Committee continued to take testimony on S.309, a bill that would hold health care providers responsible for the bill when referring patients out-of-network. The stakeholders convened and came to a partial compromise on the bill, agreeing that the Department of Financial Regulation would conduct a study to set a baseline determining the scope of the problem and to better understand why patients are seeing out-of-network providers. DFR did not appear opposed to the task but said that the parameters of the study should be better clarified.
Compromise was not found on the provision that would prohibit health insurers from shifting liability for out-of-pocket expenses to referring providers when they refer a patient out of network. Provider groups are proposing the study occur before taking any action against all providers and Blue Cross Blue Shield is requesting to maintain their current practice in current contracts. BCBS already has provisions currently in place in contracts with providers that will penalize providers for repeatedly referring out of network. The committee will plan to address this bill and the proposed partial compromise, with the question of whether to allow BCBS to continue their current practice as a significant concern.
Residents to benefit from long-term care facility regulations
The House Human Services Committee voted 11-0 in favor of H. 635, a bill that aims to regulate long-term care facilities and protect the residents from harm of poor management. Representatives from the Office of the Attorney General and the Department of Disabilities, Aging and Independent Living supported the bill as amended. The Vermont Health Care Association was pleased the bill passed despite the rejection of the association’s recommendations.
The bill was amended to include a definition for “insolvent” that is in line with the definition provided in the Uniform Commercial Code. The amendments also included adding mental harm in addition to physical harm as an enforcement action. The committee rejected the VHCA’s proposal to use the language ‘harm to mental health’. The AGO said a resident may suffer from mental harm without having mental health issues, and if mental health was included then a diagnosis may be required before taking action. DAIL pointed out that mental harm is consistent with language in other related statutes and the department’s regulations in section 4.15.e that govern residential care homes.
Additionally, the amendment included a provision that any facility owner being charged would not be able to benefit from the remedial actions of the temporary receiver.
Price transparency dashboard in the works
The House Committee on Health Care considered a proposal to address consumer health care price transparency. Consumers would be able to compare prices by procedure, by location and by health insurance. Rep. Lucy Rogers, D- Waterville presented the Price Transparency Language and explained that she had drafted the language in coordination with the Green Mountain Care Board. The Board has been planning a project to post public Vermont Health Care Uniform Reporting and Evaluation System, VHCURES, data on a web “dashboard” of their creation, so that is it accessible to the public. Rogers’ language codifies the effort and lays out a schedule of deliverables and reporting.
GMCB will report to the House Committee on Health Care and the Senate Committees on Health and Welfare and on Finance in February 2021 on their efforts to develop and implementing a public, interactive, internet-based price transparency dashboard for use by health care consumers. Part of the effort will be validating VHCURES data with hospital discharge data and information from insurers. The Board will also work with the various payers to incorporate location information into VHCURES data. The Board will be asked to demonstrate the use of the interactive price transparency dashboard legislative committees in February of 2022.
VHCURES data is statutorily intended to be available to the public but there is no good tool currently available to accomplish that. Christina McLaughlin Health Policy Analyst Green Mountain Care Board said that in a small state, protecting patient privacy can be a challenge but the data tool will be able to do so.
Another aspect of the proposal is intended to provide parameters around what can be charged to uninsured people. It limits the private-pay rate for a health care service provided at a hospital or hospital affiliated practice to not exceed the maximum amount an insurer would pay for the same service. Health care price information on the uninsured is not included in VHCURES because the data consists of information that is shared by payers.
Committee Chair Bill Lippert, D-Hinesburg said they would need to take significant testimony on this part of proposal, but would likely move the dashboard language more quickly.
Panel continues EMS discussion
The Senate Committee on Government Operations took further testimony on the Emergency Medical Services bill language. The language will be moved to S.124 and will no longer be included with S.243. After much discussion some conclusions and steps forward were made.
The committee would like to have a person providing ambulance services first obtain a certificate of need from the Green Mountain Care Board before obtaining a licensing. The committee decided not to strike language that would remove the authority of EMS district boards to repeal a credentialing rule proposed by the Vermont Department of Health. Legislative Counsel BetsyAnn Wrask noted that this is not the usual way rulemaking is repealed, but the committee maintained this per the request of EMS district representatives.
After receiving support from representatives of University of Vermont, EMS districts, and the Vermont Ambulance Association, the committee choose to have the VDH provide three levels of emergency personnel training as opposed to two. Current instructors will be grandfathered into the system and will not be required to go through the proposed training. The committee decided to expand the credentialing term to be in line with the term of the National Registry of Emergency Medical Technicians certification. The committee is also proposing to reduce burdens on training by removing the state credentialing system requirement through VDH since everyone still must acquire NREMT certification.
EMS district representatives expressed that while there is money currently in the fund, many districts have yet to request reimbursements from last year and to not consider the money unused. Committee chair Jeanette White, D-Windham, believes the funding should come from the general fund and not the Emergency Medical Services Fund because that fund receives money from insurance companies. Insurance companies would see a 62 percent increase in the amount they would be contributing to the fund, resulting in an increase in premiums for customers. The committee expects to have a bill to vote out after Town Meeting week.
Green Mountain Care Board
The Green Mountain Care Board had a full agenda on Wednesday with presentations on the FY 2019 year-end actual reporting for Vermont hospitals, an update on the all payer model, and an overview of the draft sustainability plan for hospitals.
The overall message on hospital year-end reporting is that hospitals continue to be in a fragile state with a shift in revenue from commercial payers to government payers. Director of Health Finance Analytics Patrick Rooney provided an overview and summary assessment, a systemwide analysis, and finished with a hospital-by-hospital summary. Hospitals reported cost drivers as contract staffing, drug costs, and unfavorable health insurance claims. Rooney said the results are bleak, but not a surprise. He also said there has been turnover at the executive level. Since 2017, every hospital except Southwestern Vermont Medical Center has lost a CEO or CFO. In all, nine positions changed in 2019, according to the report from the care board.
GMCB staff members Sarah Lindberg and Michele Degree presented the 2018 Total Cost of Care Report. They said this is the first year for the Medicare and commercial payers participation in the accountable care organization and year two for Medicaid. Though the Medicaid ACO program has two years of experience, the network has changed substantially between performance years. Lindberg said future analysis will include risk adjustments and other meaningful factors both in and out of the ACO which will allow for comparative analysis. Lindberg said in 2018, little spending was under the control of the ACO. The results are only intended to reflect the state’s performance. The board is taking public comment through March 10.
GMCB Alena Berube and Patrick Rooney provided the detailed framework for hospital sustainability plans. Berube said the GMCB memorialized their concern for hospital sustainability in the FY 2020 Hospital Budget Orders with the requirement for six of 14 hospitals to submit sustainability plans. Each submission is required to have the signatures of the chief executive officer, the chief financial officer, and the board chair. Berube said the goal of the sustainability plans are:
- Engage in a robust conversation on community access to essential services and barriers to the sustainability of our rural health care system;
- Ensure that hospital leadership, boards, and communities are working together to address sustainability challenges and formalizing their approach in their strategic plans over time;
- Identify hospital-led strategies for sustainability, including efforts to “right-size” hospital operations, particularly in the face of Vermont’s demographic challenges and payment reform efforts;
- Identify barriers to sustainability that are more aptly addressed by other stakeholders, policy-makers, or regulatory bodies; and
- Insights gained through hospital sustainability plans may be leveraged as the state begins to think about its subsequent proposal to the All-Payer ACO Model 2.0.
Vermont Association of Hospitals and Health System President Jeff Tieman provided public comment. He said this is the first time he has seen the details required for the sustainability plans. His initial reaction is that this new reporting requirement will absolutely add burden for hospitals and will require a lot of staff and resources. Hospitals already have lots of other regulatory obligations to abide to. He appreciates that the GMCB would like to do this right versus fast. Finally, Tieman said the GMCB must guarantee confidentiality to the hospital’s satisfaction in order for them to comply with the requirements. The information being asked by the board could create discord in their communities, cause further workforce issues as providers leave in anticipation of service line closures, and ultimately cause the hospitals to fail. The Board will take public comment until March 11.
Legislative Committee on Administrative Rules
The Legislative Committee on Administrative Rules unanimously passed a rule that sets forth the criteria for Medicaid coverage and reimbursement for Choices for Care services under Vermont’s Medicaid program. It revises and will replace the current Choices for Care 1115 Long-term Care Medicaid Waiver Regulations. The rule will be adopted and incorporated into the Health Care Administrative Rules, which are designed to improve public accessibility and comprehension of the numerous rules concerning the operation of Vermont’s Medicaid program.