Aligning Eligibility Criteria
As families’ and individuals’ income fluctuates, their eligibility for state health subsidy programs will change. Simplified and aligned eligibility criteria will help ensure continuous coverage for consumers across programs and plans.
*Milestone details:
*Full name: Align eligibility criteria across Medicaid, CHIP, the basic health program, if adopted, and federal tax credits through the Exchange to avoid gaps in eligibility for coverage regardless of income or changes in income.
*Relevance to the ACA:
The ACA requires Medicaid, CHIP and tax-subsidized Exchange coverage to use modified adjusted gross income (MAGI) to determine eligibility for most individuals. These provisions and others relevant to the alignment of eligibility criteria include:
§1411 – Eligibility determination procedures for the Exchange and federal tax credits.
§1413 – Requirements around data exchange and data matching for eligibility determinations in state health subsidy programs.
§2002 – Eligibility determination for Medicaid using MAGI.
§2101 – Eligibility determination for CHIP using MAGI.
§2201 – Requirements for coordination across Medicaid, CHIP and Exchange plans,
-- All health subsidy programs must screen and enroll applicants in or transfer applicants to the appropriate program.
-- All health subsidy programs must use secure electronic interfaces to allow for eligibility determinations across programs.
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District of Columbia
Is anyone aware of any bills that have been filed in the states related specifically to eligibility? I'm interested in bills in states that are likely to move ahead with Medicaid expansion, as well as bills in states that have made it clear they will not participate in expansion or build their own exchanges.
District of Columbia
Hello Erica, thanks for your question. Currently we know of a few states that have proposed legislation in support of the Medicaid expansion:
Legislators in New Jersey introduced Senate Concurrent Resolution No. 132 (SCR 132), which urges Governor Christie to support the Medicaid expansion: http://www.njleg.state.nj.us/bills/BillView.asp?billnumber=SCR132&db=LIS....
We have heard of a state bill in Pennsylvania in support of the expansion that Representative Frankel proposed this summer- here's the link to the press release: http://www.pahouse.com/PR/023071712.asp.
The Illinois House filed a bill (HB 6253) to expand Medicaid: http://www.ilga.gov/legislation/billstatus.asp?DocNum=6253&GAID=11&GA=97....
In terms of exchanges we know of the following legislation:
In June, Gov. Lynch signed HB 1297, which prohibits the state from creating a state-based exchange: http://www.gencourt.state.nh.us/legislation/2012/HB1297.html
There are also a number of other bills related to exchanges and health reform implementation posted here: http://www.statereforum.org/discussions/state-health-reform-laws.
District of Columbia
The Rutgers Center for State Health Policy released a report titled, "The Health Insurance Exchange, the Medicaid Program, and the Apportionment of Responsibility for Determining Eligibility and Effectuating Enrollment in New Jersey." The brief provides an overview of the ACA’s provisions related to eligibility determinations and renewals and reviews the following policy options: (1) the Exchange could be fully integrated with the Medicaid agency; (2) the Exchange could delegate certain functions to the Medicaid agency or vice versa; and (3) the exchange and the Medicaid agency could remain distinct, with entirely separate responsibilities, but collaborate closely with one another.
District of Columbia
The Centers for Medicare & Medicaid Services (CMS) recently made information available regarding the single, streamlined application for Medicaid, the Children’s Health Insurance Program and the Exchange to help establish the system of coverage envisioned by the Affordable Care Act. The data elements, open for comment, are available below. Public comments will be accepted until September 4, 2012. For more information about how to submit comments, please see the Federal Register notice on display at https://federalregister.gov/a/2012-16508.
Virginia
Enroll America submitted these comments on the interim final Medicaid eligibility regulations. They address privacy and security standards for data exchange, timeliness standards for Medicaid and CHIP eligibility determinations, and coordination of eligibility and enrollment processes between Medicaid, CHIP, and Exchanges.
Colorado
Colorado is hosting a Health and Human Services Summit on May 14-15, 2012. Attached is the Primer developed by Veritas HHS, Robert G. Williams, Ph.D.
District of Columbia
NASHP's "Maximizing Enrollment" program, funded by RWJF, developed this memo to identify the 10 things states should know about the final and interim final eligibility rules for Medicaid, CHIP and the exchange that CMS recently released. While not a complete summary of the rules, the memo highlights 10 major changes from prior rules and current policy that states will need to understand to implement new eligibility systems effectively. The memo also outlines the areas for which CMS is accepting comments until Monday, May 7th.
District of Columbia
The latest report from the State Health Reform Assistance Network, is an issue brief from the Center for Health Care Strategies (CHCS) on creating seamless coverage and care transitions between Medicaid and the exchanges. This brief examines how these transitions can be supported through
policies designed to provide continuous care for individuals moving between health
insurance products, plans, and providers. It reviews lessons from: (1) existing
exchange programs in Massachusetts; (2) transition coverage policies within Tennessee’s proposed exchange model; and (3) current transition practices between Medicaid managed care organizations (MCOs) and other programs.
Here is a link to the report: http://www.statenetwork.org/resource/creating-seamless-coverage-transiti....
District of Columbia
This brief by Manatt Health Solutions provides an overview of the final and interim final Medicaid Eligibility rule. The two sections of the brief offer (1) a high level overview of important highlights, focusing on key areas that have changed or expanded upon previous guidance, and (2) a section-by-section summary of the regulation.
District of Columbia
The National Association of Medicaid Directors (NAMD) released an analysis of the final Medicaid Eligibility rule. This memo identifies some of the key changes from the proposed rule, outstanding issues and a detailed summary of CMCS' responses to NAMD's comments on the proposed regulation.
The analysis is posted on NAMD's website: http://medicaiddirectors.org/node/374.
District of Columbia
Tim Jost's latest blog for Health Affairs, "Implementing Health Reform: A Final Rule On Medicaid Eligibility," provides an overview and commentary on a few significant features as well as a section-by-section, side-by-side analysis of the final and proposed rule.
http://healthaffairs.org/blog/2012/03/18/implementing-health-reform-a-fi...
District of Columbia
On March 16, 2012, CMS released final eligibility regulations related to Medicaid and CHIP.
Massachusetts
Massachusetts received section 1115 Waiver Demonstration extension approval in December 2011. This extension includes permission for MA to renew eligibility for parents with children who are enrolled in SNAP through an Express Lane renewal process. MA has submitted both Medicaid and CHIP State Plan Amendments to include the children in this process. MA will be using Express Lane for renewals only, not initial enrollments. We have included a link to our Waiver Demonstration extension approval letter and documents.
District of Columbia
SHADAC has released a paper, written by Stan Dorn and others at the Urban Institute on express lane eligibility, entitled, "Louisiana Breaks New Ground: The Nation's First Use of Automatic Enrollment through Express Lane Eligibility." In it, the authors report on the remarkable success of ELE in enrolling children into Medicaid in Louisiana and the administrative savings the policy produced. For example, "According to state officials, the average cost of initial enrollment is approximately $116.48 per application processed using standard, non-ELE procedures. Taking into account the manual intervention required to prevent duplicative enrollment, the average cost of initial enrollment via ELE is between $11.59 and $15.45 per successful ELE application."
They also indicate a substantial return on investment, which is even more so due to the financial support provided by the Maximizing Enrollment program. It's a interesting read especially in light of the fact that the ELE is slated to sunset in the coming years.
You can find the paper here: http://www.shadac.org/publications/louisiana-breaks-new-ground-nations-f...
District of Columbia
SHADAC and Urban Institute Senior Fellow Stan Dorn released an update to the report, "Louisiana Breaks New Ground: The Nation's First Use of Automatic Enrollment through Express Lane Eligibility," his SHARE-funded research into Louisiana’s pioneering use of automated Medicaid and CHIP enrollment through express lane eligibility (ELE). The report now includes a discussion of the state’s most recent coverage survey in light of the state's ELE efforts. The results of this survey indicate that the proportion of uninsured children who were Medicaid-eligible (i.e., “eligible-but-uninsured”) dropped from 5.3 percent to 2.9 percent from 2009 to 2011.
Illinois
Illinois wishes to explore the possible use of Express Lane Eligibility to automate enrollment of SNAP recipients in Medicaid effective 1/1/2014 -- this would help us streamline enrollment into the new Medicaid group. Obviously, we'd need to obtain approval from CMS to use ELE for this purpose. Does anyone know of other states that are contemplating this possibility, or of any guidance or recommendations from CMS? I believe MA recently received approval to use ELE for parents of children covered by CHIP, but what we're contemplating stretches a bit further. Any information/ideas/suggestions will be most appreciated!
Connecticut
CT Supports the idea of extending the renewal procedures in §435.916(a) to beneficiaries eligible for Medicaid other than MAGI-based eligibility.
District of Columbia
Here are comments on the Tri-Regs from the National Health Law Program.
District of Columbia
NASHP's "Maximizing Enrollment" program, funded by RWJF, developed this Eligibility Regulatory Analysis grid. This grid outlines the key provisions of the three eligibility notices of proposed rulemaking (from CMS and IRS) that were issued on August 17, 2011. The grid provides a summary of the key provisions in each section of the rule, raises key questions or issues that states and the federal agencies will want to consider in finalizing the policy, and signals for states the areas where CMS has specifically asked for more guidance from them.
District of Columbia
I've added a new blog post recapping the full menu at the CMS Eligibility Conference that was held earlier this month. Read it here:
http://www.statereforum.org/node/8525
I've also included some detail on how the federal agencies plan to follow up with additional materials.
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