New KFF State Survey Data Provide a Benchmark for Measuring State Responses to COVID-19

On March 26, we posted our 18^th annual 50-state survey of Medicaid and CHIP eligibility, enrollment, renewal, and cost sharing policies. It continues to serve as the only comprehensive resource for information on these policies across states and provides information that has enabled tracking of state implementation of the Medicaid expansion and streamlined enrollment and renewal procedures under the ACA.

This year’s survey, which provides data on policies in place as of January 2020, now serves a new purpose by providing a benchmark against which we can measure state actions to respond to COVID-19 and the economic crisis. The survey findings document policies states must maintain in order to access temporary enhanced federal Medicaid funding as part of COVID-19 response efforts. The Families First Coronavirus Response Act provides states a temporary 6.2 percentage point increase in the federal Medicaid matching rate. To receive those enhanced funds, states cannot implement more restrictive eligibility policies than those in place as of January 1, 2020 and must provide continuous coverage to Medicaid enrollees through the emergency period. For example, states cannot reduce income eligibility limits or increase requirements to verify eligibility criteria.

The survey findings show that, as of January 2020, there is wide variation in state policies that affect individuals’ ability to access coverage and care. For example, more individuals can access Medicaid coverage in states that have implemented the ACA Medicaid expansion to low-income adults than in states that have not expanded, where poor adults continue to face a coverage gap. Largely because of the ACA, individuals can apply for Medicaid and CHIP online or via phone, and states can connect individuals to coverage quickly through real-time eligibility determinations and renewals using electronic data matches. Moreover, some states have taken up options that expedite access to coverage and facilitate continuity of coverage, such as presumptive eligibility and 12-month continuous eligibility for children. However, certain policies and processes may by contributing to coverage losses among eligible individuals. For example, some states conduct periodic data checks between renewal periods to identify potential changes that might affect eligibility, provide enrollees limited time (e.g., ten days) to respond to requests to verify ongoing eligibility, and only contact enrollees once by mail to request information before terminating coverage. Changes the federal government was pursuing as part of program integrity efforts prior to COVID-19 may have further increased coverage barriers for eligible individuals, but the Centers for Medicare and Medicaid Services (CMS) recently withdrew its planned regulatory changes that would have tightened eligibility requirements.

States can take a range of actions through Medicaid under current rules and waivers to enhance their response to COVID-19. They can take some of these actions quickly without federal approval. For example, they can allow self-attestation of eligibility criteria other than citizenship and immigration status and verify income post enrollment, which would make signup easier and faster. They also can provide greater flexibility to enroll individuals who have small differences between self-reported income and income available through data matches. Further, they can suspend or delay renewals and periodic data checks between renewals (as noted above, states must provide continuous coverage to Medicaid enrollees through the emergency period to receive enhanced federal funding). States can take other actions allowed under existing rules by submitting a state plan amendment (SPA). For example, states could expand eligibility, including implementing the ACA Medicaid expansion to low-income adults in states that have not yet expanded; adopt presumptive eligibility; or modify cost sharing requirements. Beyond these options, states can seek additional flexibility through Section 1135 and Section 1115 waivers. CMS has provided states SPA and waiver templates and checklists to facilitate implementation of changes to respond to COVID-19, and state Medicaid policies and processes already are evolving as states implement changes to expedite enrollment in coverage, keep enrollees covered, and facilitate access to services as part of COVID-19 response efforts.

State Medicaid and CHIP eligibility and enrollment policies will remain an important indicator to watch looking forward. As evidenced by previous recessions, states will likely see growing demand for Medicaid and CHIP as individuals lose jobs and incomes decrease amid the declining economy. The ability to connect these individuals to coverage quickly and to keep them connected to coverage over time will help ensure they can access care for COVID-19 and more broadly.