How Can Medicaid Enhance State Capacity to Respond to COVID-19?

• Allow self-attestation to verify eligibility for all criteria except citizenship and immigration status on a case-by-case basis; verify assets if financial institution unable to verify due to disaster; verify incurred medical expenses for spend down eligibility
• Extend renewal timeframes
• Exempt enrollees from premiums
• Temporarily suspend periodic data checks on case-by-case basis
• Temporarily delay acting on certain changes in circumstances affecting eligibility
• Reinstate services or eligibility if discontinued because whereabouts unknown due to evacuation, after whereabouts become known and if still eligible
• Consider people evacuated from state as temporarily absent to maintain enrollment
• Treat Federally facilitated Marketplace assessments as eligibility determinations or fully delegate eligibility determination authority to Federally facilitated Marketplace
• Expand application processing times
• Suspend adverse actions for those in disaster area where state has completed determination but has not yet sent notice or state believes notice likely not received
• Temporarily increase HCBS waiver service payment rates if no change to rate methodology and no impact on cost neutrality

• Accept self-attestation and conduct post-enrollment verification for eligibility criteria other than citizenship and immigration status (beyond case-by-case basis)
• Adopt or increase reasonable compatibility thresholds for income inconsistencies
• Allow reasonable explanation of inconsistencies in lieu of paper documentation
• Temporarily suspend periodic data checks (beyond case-by-case basis)

• Increase financial eligibility thresholds (e.g., adopt ACA expansion, cover nonelderly MAGI group above 138% FPL)
• Cover non-residents or state-defined subset of non-residents such as those living temporarily in state due to disaster in home state
• Apply host state’s asset limit, or if less restrictive, asset limit from state where individual evacuated (if statewide rule)

• Adopt or extend presumptive eligibility for certain populations
• Extend hospital presumptive eligibility to non-MAGI groups
• Establish state as presumptive eligibility qualified entity to enroll individuals based on preliminary application information
• Provide 12-month continuous eligibility for children
• Develop simplified paper application for affected areas
• Extend reasonable opportunity period to provide documentation for immigration status

• Temporarily modify copayment requirements to support access to services (if rule applies statewide)
• Offer additional benefits (if comparable for all categorically needy groups and statewide with free choice of provider, or via alternative benefit plan with free choice of provider)
• Change amount, duration, or scope of covered benefits
• Amend payment methodology to account for increased cost of personal protective equipment for home care workers

• Temporarily suspend out of network requirements for managed care enrollees
• Require health plans to expedite processing of new prior authorization requests and allow flexibility in documentation (e.g., physician signature)

• Increase eligibility limits for specific categories in specific geographic regions

Enrollment & Renewal:

• Provide 12-month continuous eligibility for adults or for a subset of children
• Allow self-attestation for citizenship and immigration status if unable to verify by data sources and individual unable to document due to disaster

Benefits:

• Provide benefits to targeted group of enrollees impacted by disaster
• Temporarily modify copayment requirements to support access to services (less than statewide)
• Authorize off-island coverage for those in territories eligible for FEMA transitional shelter assistance who are temporarily relocated to a state

Long-Term Services and Supports:

• Temporarily suspend requirement to be institutionalized at least 30 days and have income below 300% SSI to be eligible for special income group
• Temporarily suspend asset transfer rules for those placed in nursing homes
• Apply host state’s asset limit, or if less restrictive, asset limit from state where individual evacuated (if less than statewide)
• Do not reduce institutional provider payments by post-eligibility treatment of income

• Temporarily suspend fee-for-service prior authorization requirements and/or require providers to extend prior authorization through the termination of emergency declaration

• Temporarily waive requirements for out-of-state providers to be licensed in state where they are providing services if provider is licensed by another state Medicaid agency or Medicare
• Temporarily waive provider screening requirements, such as application fees, criminal background checks, and site visits, to ensure sufficient number of providers
• Temporarily cease revalidation of providers in state or who are otherwise directly impacted by disaster
• Temporarily suspend pending enforcement or termination actions or payment denial sanction to specific provider
• Allow facilities to provide services in alternative settings such as temporary shelters when provider facility is inaccessible
• Temporarily allow non-emergency ambulance providers

Long-Term Services and Supports:

• Provide nursing home care to evacuees in host state for less than 30 days if individual is Medicaid-eligible in home state
• Temporarily suspend pre-admission screening and annual resident review assessments for 30 days
• Extend minimum data set authorizations for nursing home and skilled nursing facility residents
• Temporarily suspend requirement that home health agency aides be supervised for 2 weeks by registered nurse
• Temporarily suspend requirement that hospice aides be supervised by registered nurse every 14 days
• Modify or suspend certain state survey agency activities

Appeals:

• Allow direct access to fair hearing without first exhausting managed care appeal
• Extend timeframes for individuals to request managed care appeals or state fair hearings

•  Increase number of unduplicated waiver enrollees
• Temporarily increase individual cost limit to assure health and welfare
• Modify eligibility targeting criteria to serve more enrollees and forestall institutionalization in emergency
• Extend level of care authorizations for 12 months

Benefits:

• Add covered services not expressly authorized in statute if necessary to assist waiver enrollees to avoid institutionalization
• Modify scope of covered services and temporarily exceed individual service limits to ensure health and welfare
• Institute or expand self-direction
• Temporarily suspend prior authorization and extend medical necessity authorizations
• Modify person-centered planning process, including qualifications of individuals required to develop plan

Providers:

• Temporarily increase payment rates with a temporary change in rate methodology and/or impact on cost neutrality
• Amend payment methodology to account for increased cost of personal protective equipment for home care workers
• Allow payment for services provided by family caregivers or legally responsible relatives
• Temporarily modify provider types, qualifications, and licensure or other setting requirements
• Include retainer payments to personal care assistants when waiver enrollee is hospitalized or absent from home up to 30 days
• Expand covered settings to include out-of-state
• Temporarily allow payment for waiver services up to 30 days to support enrollees in acute care hospital or short-term institutional stay when services are required for communication and behavioral stabilization and not provided by institution