Tricare Extended Care Health Option (ECHO) and Branch of Service Respite
EFMP Advisory Council
EFMP Assignment Transparency
Guard and Reserve families should have permanent or reasonable access to EFMP while on orders. It would directly affect readiness, resiliency, and retention by establishing a much needed chain of support for programs that require EFMP enrollment to benefit the most vulnerable in the military community. The first step we ask for is sponsoring 2023 NDAA language for the GAO study to identify Guard and Reserve families that are eligible for EFMP. If you'd like to contact us about the the EFMP programing for Guard and Reserve Families, please contact us via the "contact us tab" or email us at email@example.com.
We support the independent review of the ACD in the 2022 NDAA and recommend the implementation of the policy changes should be put on hold pending the outcome of the independent review. Military families have already had therapy services disrupted, negatively impacting Autistic loved ones. The changes may not survive the scrutiny of the review by the National Academies of Sciences, Engineering and Medicine (NASEM). EFM is concerned that stakeholders will not be heard during this review. We ask for the restrictions to the community and school settings to be reversed and the Activities of Daily Living (ADLs) such as toileting to be allowed back into the ACD. Lastly, we are asking for the parent stress assessments to be eliminated entirely. There is an equity barrier for Autisic families as no other disability category is required to fill out these assessments as a requirement to receive care. If you'd like to contact us about the Autism Demonstration changes, please contact us via the "contact us tab" or email us at Autism@exceptionalmilitaryfam.com.
The Defense Health Board concluded that military children are disadvantaged from receiving necessary services because Tricare does not utilize a pediatric specific medical necessity standard and hierarchy of evidence. Nor do military children enjoy the same standard of care as civilian children covered by Medicaid’s EPSDT requirement which ensures necessary health care, diagnostic services, treatment, and screenings. Ostensibly, DHA adopted the AAP timeline for preventive care, Bright Futures, in 2018, however, it has been difficult to know whether or how the new policy has been implemented.
These failures to account for the unique needs of kids is especially harmful in the context of the mental health crisis facing our nation’s children and youth because these specific pediatric coverages are crucial to the prevention, screening and early intervention that can help reduce need for higher acuity and crisis care down the road.
Children in military and veteran families face all the typical stressors impacting their civilian counterparts, as well as unique factors such as a parent regularly in harm’s way, or a parent's service-related injuries. While some challenges such as provider shortages are universal, there are barriers that Congress can fix. For example, Tricare mental health copays have more than doubled since 2017. Also, recent changes to the Autism Care Demonstration have disrupted care for families, even while those controversial changes are undergoing independent review ordered by the FY22 NDAA.
The Coalition urges continued focus on strengthening commitment to MEB health for children of military families.
Military families must be able to easily access current and accurate directory information for Tricare authorized providers. Often, the categories are not specific enough to contemplate the universe of pediatric specialties, subspecialties and age ranges that are necessary information when seeking care for children with complex and chronic conditions. Problems for institutional providers are exacerbated by lack of ability to search outside a fixed area, and inconsistency with TRICARE policy identifying provider types. There will not be adequate, if any, institutional providers in most zip codes or communities, and families should be able to see the geographic locations relative to family members, friends, or other trusted resources if the treatment placement is not close to home.
Furthermore, because basing decisions for Exceptional Family Member Program (EFMP) participants rely on provider directories, the fact they are often inaccurate, incomplete, or not specific enough, results in denials of duty stations unnecessarily, or placements where children’s needs cannot be met. When care can be found using directories, extensive wait times are not taken into account, flooding the market with additional care needs resulting in longer wait times for both military and civilian patients.
The ECHO program, created by Congress to guarantee that military families would be able to utilize the same type of home and community-based services that are offered through the states but generally too difficult for mobile military families to access, must be updated to ensure those services are comparable to those offered through the states. The FY 2022 NDAA directed a study of ECHO continuity of care, due in March 2022. Pending its outcome, additional solution sets may be identified. Meanwhile, the following issues are still unresolved.
Habilitation is intended to help “attain, keep or improve” skills or functions and critical for developing children, but is not covered by ECHO, nor are residence and vehicle adaptations, especially egregious given the shortage of ADA accessible military housing. ECHO may cover service and modification of durable equipment and assistive technology but this has not been codified, which would ensure its application.
Certain medical equipment or services for rare or unusual conditions, even when covered, are not available. They remain unfulfilled because there are no providers willing or able to contract to provide them. This issue appears to be almost entirely one of reimbursement. This is a small volume but a key constituency – the most vulnerable whose needs most often go unmet to the detriment of their health and wellbeing.
Additionally, there is a great deal of confusion and misinformation for Guard and Reserve families who may become eligible for ECHO and EFMP, regarding their eligibility and responsibilities. Because there is not a defined universe of those eligible, it is difficult to disseminate correct information to combat the misunderstandings.
Adult incapacitated children (AIC) of service members and retirees are dependents, which ensures Uniformed Services IDs, Tricare eligibility and any other rights and privileges afforded to military families, but DoD policy and practice is inconsistent and out of step with existing civilian dependency and guardianship principles.
At the very least, the process for determining dependency for adult incapacitated children must be clear, streamlined, nondiscriminatory, consistent and provide due process. However, we believe determinations of disability are more appropriately made pursuant to established disability law and policy, as it is not a core DoD expertise, allowing DoD to simply recognize and accept determinations made by federal and state authorities with jurisdiction and expertise.
An FY22 NDAA required report, due February 2022, has not yet been made available as of March 18. Without that report it is unclear whether or when families will see relief. Clearly, no action has yet been taken, resulting in continued “increased hardships for military families” per the June 2020 GAO report that cataloged many of the issues and led to the FY22 NDAA provision.
Also of great concern is the MHS inconsistency in policy and practice for incapacitated adult patients. Often, parents are told they cannot be given laboratory results or ask about consults, even with documented dependency and guardianship.
Congress should improve accountability by directing DHA to stand up a mechanism for beneficiaries/families and purchased and direct care providers to report complaints and concerns about Tricare coverage, denials, incorrect provider directories, network adequacy, access to specialized care, overdue or consistently inaccurate payments, and other related issues.
Align Tricare with a benefit that has been available to civilian families since 2010. This coverage into young adulthood is more important now than ever for military-connected youth, as the nation emerges from 1) twenty years of war, the burden of which has been borne squarely on the shoulders of their families and communities, and 2) a pandemic that has upended teens’ routines, plans and disrupted their typical trajectories with ramifications that we have yet to fully evaluate or understand.
Medical billet cuts and restructuring could harm families’ access to care and potentially have negative unintended and long-term consequences, including disruptions to the medical education pipelines that are integral to training pediatricians for military connected children and all children. We strongly support the precautions and pauses in previous NDAAs and continued Congressional oversight.
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