Green Mountain Care Board seeks extra staff for AHEAD transition and outlines impacts of proposed CON threshold changes

Tara Foster, chair of the Green Mountain Care Board, told the Senate Health and Welfare Committee at a committee meeting that the board supports the governor’s recommended budget and is requesting additional staff if Vermont moves forward with the AHEAD model, and that proposed changes to certificate-of-need (CON) thresholds would shift fee burdens to hospitals and insurers.

The board’s Administrative Services Director, Jean Stetter, said the board’s mission is “to drive system wide improvements in access, affordability, and quality of healthcare to improve the health of Vermonters.” Stetter described the board’s budget composition, recent increases tied to new drug-pricing work under Act 134 and staffing requests linked to the possible federal AHEAD demonstration.

The nut graf: The board told legislators it needs more people and more billing flexibility to handle a likely gap year between OneCare Vermont winding down and any new AHEAD implementation; at the same time, the committee is considering H.96, a CON-reform bill that would raise jurisdictional thresholds and exempt some state-funded projects, changes the board says will modestly reduce its application fee revenue and shift costs to hospitals and private insurers.

Stetter outlined the budget math: excluding prescription-drug staffing and governor-requested positions, the board’s base budget is roughly 5% higher than the prior year. Funding for Act 134 work on drug pricing increased the board’s request by about 14.9% in that line. Stetter said the board received an allocation of $245,000 intended for two positions for prescription-drug work but that hiring a more senior data-and-analytics director increased costs above that estimate. The governor’s office made available roughly $750,000 the board could use to request three positions from the administration’s pool.

On AHEAD staffing, Stetter said: “If AHEAD moves forward, the Green Mountain Care Board would need 2 more permanent positions in FY '26, to be able to continue with AHEAD. So it would be the 3 that are requested here plus 2 more. And in addition, based on our understanding of the roles and responsibilities of the board during AHEAD, we would need an additional 15, permanent positions in FY '27.” She also described a separate request for two limited-term FY26 automation positions intended to automate reporting, improve processes and aid staff retention; those positions are described as intended to sunset.

Foster described the board’s formal action on the AHEAD decision: “We support the governor’s recommend,” and later explained the board voted to endorse the model conditionally and that she, as chair, must issue a termination notice if certain conditions are not met. The board’s contingencies, as Foster described them, include securing sufficient staffing (the five positions in year one and the additional 15 in year two that Stetter outlined) and protections around funds flow to prevent Vermont money from indirectly financing non‑Vermont hospitals. Foster said she expects to issue a termination notice if those conditions are not satisfied and flagged a likely September 30 deadline for taking that step.

Stetter and committee members also discussed the fiscal effects of OneCare Vermont ceasing operations. Stetter said removing the OneCare allocation from the board’s bill-back formula would increase the amount billed to hospitals and insurers; she said last year’s shift was roughly $570,000 and that, under the proposed statutory change, the bulk of that shift would fall to hospitals, with a smaller share to insurers. She also said the board had not included fees to ACOs in the CON-fee package because those fees are linked to potential changes in ACO regulation.

Committee members asked for more granular figures on the revenue the board currently bills for CON and other ACO-related work; Stetter said she would provide the amount billed for jurisdictional CON review. Committee members also raised programmatic concerns: several members cited possible funding gaps in programs that have received ACO or OneCare funds in prior years, naming Blueprint, SASH and primary care supports as examples. Stetter cautioned that the board cannot move money between agencies and that some gap-closing would require legislative budget action or changes in payer rates that the board regulates.

On H.96, committee staff and the board walked through proposed threshold changes and exclusions in a draft strike-all amendment. Those draft changes include raising the construction threshold from roughly $1.5 million to $10 million for nonhospital health-care projects, raising equipment thresholds (the draft reflects differing figures for diagnostic/therapeutic equipment in the bill text), and setting the threshold for offering a health-care service or technology to an annual operating level of $3 million in some proposals. The draft also preserves a $50 million conceptual-development-based CON for very large projects. Committee staff explained the draft would change language from “includes” to a limiting “means” to create a static definition of a new health-care project.

The draft contains exclusions that committee members pressed the board and Agency of Human Services (AHS) about: items funded in whole or in substantial part by the state, facilities owned or operated by the state, ambulance services (including ground ambulance), and routine replacement of fully depreciated medical equipment. The draft’s effective date in the bill as introduced was 07/01/2025; committee staff proposed language so that applications filed before that date would be decided under the thresholds that applied when filed.

Ashley Johnson, staff attorney for the Agency of Human Services, said the agency reviews need and funding before issuing an RFP or committing state funds and that, when the state funds a project, the agency already analyses need prior to a procurement. She told the committee: “If the state of Vermont, especially the Agency of Human Services specifically, is going to fund a project, we're looking at that need before we agree to that funding, before we go through that RFP process.” AHS staff and the board discussed whether a state‑funded project should be exempt from CON review and flagged edge cases (for example, where the state provides a relatively small grant toward a very large private project).

Committee members and board staff also discussed implementation mechanics: the board said CON fees are modest in the aggregate (the fee formula is a percentage capped at $20,000 per application), and that raising thresholds would reduce revenue from high-fee applications but not, in the board’s view, “break the budget.”

The meeting closed with legislative staff and the committee planning a markup and a floor vote on the CON reform language; committee leadership told members they expected to vote on the draft the next day and asked witnesses to provide suggested statutory language and fee figures in writing.

Ending: The board left the committee with two immediate deliverables: (1) a written summary of the CON fee amounts and how much revenue the board bills for CON/jurisdictional review, and (2) suggested statutory language to implement the board’s requests for billing flexibility and ACO fee changes. The committee scheduled a markup and expected a committee vote on the CON draft the following day.