A group of consumer and disease-specific advocacy organizations said in a press release Wednesday that up until now the Department of Social Services has solicited input into the development of the plan “only from HMOs that might contract with it to run the program, leaving the consumers who might benefit from it out of the loop.”

DSS spokesman David Dearborn disagrees. In phone conversation Thursday, Mr. Dearborn said “Anyone is welcome to comment on the plans.” He said the agency has discussed the plan with provider groups, legislators, and advocates. He said the agency even set up a special web site and email address: DSS.HealthCare@ct.gov to solicit comments about the plan prior to the RFP.

Advocates also argue that what the state has put forward up to this point will likely be unattractive to the uninsured, “given its limited benefits and questionable consumer protections.”

There is a proposed limited drug benefit of only $2,500 a year and a $2,000 a year benefit for medical equipment.

Don Zettervall, director of the Diabetes Center of Old Saybrook, said “If the coverage for diabetes currently required under state law is not contained in the Charter Oak Plan, I’m concerned that people will not be properly educated about how to self-manage their diabetes.” He said the proposed annual caps for medications and medical equipment are “wholly inadequate,” for diabetes patients.

Mr. Dearborn said the plan was “not proposed as the Rolls Royce of programs.” And it was by no means meant to be “universal” coverage, he said. He said it’s “affordable, credible coverage,” for those unable to obtain health benefits from their employers or aren’t old enough to qualify for Medicare.

But the more answers advocates get from the state, the less satisfied they are with it.

State Healthcare Advocate Kevin Lembo said Thursday there are still too many unanswered questions regarding consumer protections. Based on the correspondence Mr. Lembo received from the state Insurance Department Nov. 5, it looks like hard-won insurance mandates that exist under Connecticut law do not exist under the Charter Oak plan.

“My legal staff has reviewed Public Act 07-2 regarding the Charter Oak Health Plan and has opined that the Insurance Department’s jurisdiction over this plan is limited based on the language found,” in the plan, Insurance Commissioner Thomas Sullivan wrote in a letter to Mr. Lembo.

“The Insurance Department does not regulate benefits, forms, and rates related to social programs, which are not sold in the commercial insurance market,” Mr. Sullivan wrote.

In response to Mr. Sullivan’s letter, Mr. Lembo wrote that “the Department has much broader jurisdiction and responsibility than it has opined.” Mr. Lembo disagrees with Mr. Sullivan’s conclusion that the Charter Oak plan is a “social program” because it will be open to consumers of all incomes, many of whom won’t receive a subsidy.

The subsidy will be provided to those under 300 percent of the federal poverty level, Mr. Dearborn said. And coverage would not be restricted for people with pre-existing medical conditions.

Lembo said he expects there will be many chronically ill people who chose to enroll in the Charter Oak plan because they can’t obtain individual insurance. “It is these people that I am especially concerned for, given the representations of limited prescription drug coverage of $2,500 per year, other limited benefits and the potential lack of broad oversight by your department of this plan,” Mr. Lembo wrote in his letter to Mr. Sullivan.

Mr. Sullivan has yet to respond to Mr. Lembo’s Nov. 16 letter.

The legislative forum, which includes the Appropriations, Human Services and Insurance and Real Estate Committees, will be held at 1 p.m. Wednesday, Dec. 5 in Room 2C of the Legislative Office Building.