Renewals in Medicaid and CHIP: Implementation of Streamlined ACA Policies and the Potential Role of Managed Care Plans
Issue Brief
C. Mann and L. Summer, “Instability of Public Health Insurance Coverage for Children and Their Families: Causes, Consequences, and Remedies,” The Commonwealth Fund, June 2006, available at http://www.commonwealthfund.org/~/media/files/publications/fund-report/2006/jun/instability-of-public-health-insurance-coverage-for-children-and-their-families--causes--consequence/summer_instabilitypubhltinschildren_935-pdf.pdf
Medicaid Program; Eligibility Changes Under the Affordable Care Act of 2010; Final Rule, March 23, 2012, available at http://www.gpo.gov/fdsys/pkg/FR-2012-03-23/pdf/2012-6560.pdf
States may only collect “information that is necessary to determine ongoing eligibility and that relates to circumstances that are subject to change, such as income and residency. States cannot require individuals to provide information that is not relevant to their ongoing eligibility, or that has already been provided with respect to an eligibility factor that is not subject to change, such as date of birth or United States citizenship.” Health Care Financing Administration, Letter to State Medicaid Directors from Tim Westmoreland, April 7, 2000, available at http://downloads.cms.gov/cmsgov/archived-downloads/SMDL/downloads/smd040700.pdf
The hub is designed to provide states and the federal government with coordinated and real-time access to information about applicants, including their quarterly wages, citizenship and immigration status, and other eligibility criteria.
42 CFR 435.916(a)(1)
With the exception of states that have adopted 12 months continuous eligibility for children in CHIP/Medicaid.
42 CFR 435.916(c) and (d)
42 CFR 435.916(a)(3)(iv)
CMS offered states an enhanced 90 percent federal Medicaid matching rate to build new eligibility and enrollment systems and a 75 percent matching rate for upgrading existing systems and supporting ongoing maintenance and operating costs Medicaid Program; Federal Funding for Medicaid Eligibility Determination and Enrollment Activities; Final Rule, April 19, 2011; available http://www.gpo.gov/fdsys/pkg/FR-2011-04-19/pdf/2011-9340.pdf. CMS recently proposed to extend this enhanced match rate on a permanent basis. Letter from Cindy Mann to National Association of Medicaid Directors and the American Public Human Services Association indicating CMS’ intent to publish a proposed regulation that will permanently extend the availability of the 90% and 75% matching funds for E & E systems modernization activities. The letter also discusses an extension of the OMB Circular A-87 waiver that enables states to pursue integrated eligibility systems with other human services programs. October 28, 2014, available at http://www.medicaid.gov/medicaid-chip-program-information/by-topics/data-and-systems/downloads/medicaid-90/10-funding-extension.pdf. The proposed rule is available at http://www.gpo.gov/fdsys/pkg/FR-2015-04-16/pdf/2015-08754.pdf
T. Brooks, J. Touschner, S. Artiga, J. Stephens, A. Gates, “Modern Era Medicaid: Findings from a 50-State Survey of Eligibility, Enrollment, Renewal, and Cost-Sharing Policies in Medicaid and CHIP as of January 2015,” January 20, 2015, available at https://www.kff.org/health-reform/report/modern-era-medicaid-findings-from-a-50-state-survey-of-eligibility-enrollment-renewal-and-cost-sharing-policies-in-medicaid-and-chip-as-of-january-2015/.
For detailed information about the new renewal options, see Medicaid.gov at http://www.medicaid.gov/state-resource-center/mac-learning-collaboratives/learning-collaborative-state-toolbox/downloads/all-state-call-renewal-refresher-7-31-14.pdf
Medicaid and CHIP enrollment has continued to increase, both in states that have expanded Medicaid and those that have not. For more information see CMS monthly Medicaid/CHIP Application, Eligibility Determination and Enrollment Reports, available at http://www.medicaid.gov/medicaid-chip-program-information/program-information/medicaid-and-chip-enrollment-data/medicaid-and-chip-application-eligibility-determination-and-enrollment-data.html
Author interviews with CMS officials, March and April 2015.
Martha Heberlein, Georgetown Center for Children and Families blog post, “FMAP Guidance on 12-Month Continuous Eligibility for Adults,” February 16, 2014, available at http://ccf.georgetown.edu/all/fmap-guidance-on-12-month-continuous-eligibility-for-adults/
Author interview with Mary Wood, Director of Eligibility Policy and Service Delivery, Washington State Health Care Authority, April 13, 2015 and follow-up email conversations on May 20 and June 16, 2015 and author interview with Amy Lapierre, Administrator, Rhode Island Executive Office of Health and Human Services, April 16, 2015.
Although individuals have 30 days to respond before termination can take place.
Center for Medicaid & CHIP Services Frequently Asked Questions, January 16, 2015, available at http://www.medicaid.gov/Federal-Policy-Guidance/Downloads/FAQ-01-16-2015.pdf
See 42 CFR Section 438.104 of the May 26, 2015 proposed rule, “Medicaid and Children’s Health Insurance Program (CHIP) Programs; Medicaid Managed Care, CHIP Delivered in Managed Care, Medicaid and CHIP Comprehensive Quality Strategies, and Revisions Related to Third Party Liability; Proposed Rules,” p.31273. Available at http://www.gpo.gov/fdsys/pkg/FR-2015-06-01/pdf/2015-12965.pdf.
Appendix
42 CFR 435.916(a)(2)
42 CFR 435.916(a)(2)
42 CFR 435.916(a)(3)(i)
The regulation requires that the state give the individual at least 30 days from the date of receipt of the renewal form. States generally send the form well in advance of the end date of coverage so that they can give the person the 30 days to respond and for the state to receive the form and have time to process it prior to the coverage end date.
42 CFR 435.907(f) and 435.916(a)(3)(i)(B)
42 CFR 435.916(a)(2)
42 CFR 435.916(a)(3)(iii)
42 CFR 435.916(f)
For more information see 42 CFR 435.1200
42 CFR 435.916(b)
Author conversations with CMS/CMCS.