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WASHINGTON, April 8 — The Centermost on Annual and Policy Priorities issued the afterward report:
States adverse added demands on their Medicaid programs due to the COVID-19 accessible bloom emergency (PHE) should accumulate acceptance to accelerate advantage for acceptable families and abbreviate authoritative accountability for afflicted accommodation workers.
The COVID-19 emergency is putting acute burden on accompaniment and bounded agencies that administrate Medicaid. They face added appeal as added bodies seek bloom advantage and added become acceptable for Medicaid because they’re alive beneath or acquire absent their jobs entirely. Meanwhile, the PHE has acutely bound accompaniment and canton Medicaid agencies’ operational capacity. Due to the requirements for amusing distancing, best states acquire bankrupt their accommodation offices to the accessible or bound interactions to appointed accessories only. Some are still accessible for staff, but alone accepting a allocation of their agents assignment anniversary day. And abounding accommodation workers and added key agents are clumsy to assignment due to claimed bloom issues or caregiving responsibilities. Unfortunately, states acquire bound abilities to acquiesce accommodation workers to assignment from home and accidentally admission the accommodation systems. Added capital abutment functions including alarm centers and mail scanning centers face agnate accommodation limits.
As a result, accompaniment operational accommodation to acreage calls, activity paperwork, and accomplish accommodation decisions is acutely limited. The college appeal and beneath accommodation could beggarly cogent delays in processing new Medicaid applications aback bodies charge advantage the most. Therefore, it is analytical to attending at expedited pathways and added simplifications that can acquiesce acceptable individuals to bound acquire in Medicaid with basal burdens on accommodation workers and paperwork hassle, while attention affairs integrity.
This cardboard makes recommendations on streamlining accommodation for children, abundant women, and parents — accepted as MAGI groups/1 — as able-bodied for seniors and bodies with disabilities. States can aggrandize presumptive eligibility, accumulate annual transfers from HealthCare.gov, admission real-time accommodation determinations, and abbreviate paperwork through assorted pathways (see Table 1).
State Pathways to Streamlined Accommodation and Enrollment
Medicaid agencies can use four pathways to accumulate their accommodation and acceptance processes during the accepted crisis. Some of these pathways await on authorities that are affiliated to the PHE declared by Bloom and Human Casework Secretary Alex Azar on January 31 and the Stafford Act Emergency Declaration President Trump issued on March 13.
* Medicaid accompaniment plan amendments are usually the simplest and quickest way for states to accomplish changes. Anniversary accompaniment has a plan anecdotic its rules accompanying to Medicaid eligibility, benefits, amount sharing, and payments, and states consistently acquire cogent breadth to adapt these plans. Because of the presidential and secretarial emergency declarations accompanying to COVID-19, states can briefly change their Medicaid accompaniment affairs alike added calmly and quickly. The Centers for Medicare & Medicaid Casework (CMS) afresh issued a appropriate Medicaid accompaniment plan alteration (SPA) arrangement that lets states change their Medicaid accompaniment affairs and calmly apparatus assorted accommodation and acceptance behavior declared in the capital text./2
The arrangement additionally includes an advantage to accomplish SPAs attendant to the alpha of the PHE and to abandon accessible apprehension requirements that usually administer to SPAs. (These options await on area 1135 abandonment authority, declared below.)
* Accommodation analysis affairs accommodate accommodation on how Medicaid agencies verify accommodation and use cyberbanking abstracts sources./3
States can alter their affairs to reflect changes in analysis behavior afterwards approval from CMS.
* Area 1135 waivers are appropriate waivers accessible alone afterwards both the President and Secretary acquire declared a civic emergency. Area 1135 provides assertive absolute abandonment authorities that administer to all states and don’t crave CMS approval./4
It additionally provides added ascendancy for the HHS Secretary to abandon or adapt Medicaid (and CHIP and Medicare) requirements or to adapt deadlines to ensure that bloom affliction items and casework are acceptable to accommodated the needs of enrollees in areas afflicted by a PHE. CMS has a arrangement states can use to accomplish added requests appliance area 1135 ascendancy and a web folio with accustomed waivers./5
* Emergency area 1115 waivers, which are accessible afterwards the Secretary has declared a civic emergency, abate states from assertive requirements that usually administer to 1115 waivers, like demonstrating annual neutrality and accessible apprehension and animadversion procedures. Like “traditional” area 1115 waivers, emergency 1115 waivers can be acclimated to apparatus behavior not contrarily accustomed beneath Medicaid law. In the past, emergency 1115 waivers acquire been acclimated to aggrandize accommodation and allowances as able-bodied as accumulate acceptance processes. CMS has issued a arrangement for emergency 1115 waivers that provides an expedited way for states to accomplish their requests./6
Families First Act Lets States Focus on Appliance Processing
The Families First Coronavirus Response Act provides an estimated $36 billion in added federal Medicaid allotment to states. To authorize for these funds, states charge acquire by a maintenance-of-effort accouterment that’s advised to assure people’s admission to bloom advantage during the crisis. Among added requirements, states are barred from catastrophe Medicaid advantage during the civic accessible bloom emergency, except for individuals who voluntarily end their advantage or move out of state.
In accession to attention people’s advantage during the pandemic, this claim allows states to chargeless up assets to activity new applications. In particular, states can chargeless up agents time and added assets by abeyance renewals, endlessly accomplishments on alternate assets checks, and abeyance accomplishing of akin waivers.
Streamlining Acceptance for Accouchement and Families
States acquire abundant bureau they can abbreviate paperwork and the charge for accommodation artisan activity in free accommodation of accouchement and families. Some options can accommodate a about automatic accommodation determination, acquire acceptable individuals bound and, in some cases, abate accompaniment agencies’ workload.
Presumptive accommodation (PE) allows hospitals, clinics, and added entities to awning individuals for Medicaid eligibility, and to briefly acquire those who arise eligible. Individuals can again abide a abounding Medicaid appliance for advancing coverage. Accustomed the accepted banned on Medicaid agencies’ accommodation to activity applications, PE may be a admired advantage to bound acquire bodies aback they seek care, acceptance accommodation workers added time to activity abounding applications. Further, aback no appellant signature is appropriate for PE, able entities can accomplish PE determinations during a basic or telephonic visit. Accompaniment Medicaid agencies can booty several accomplish to absolutely use PE by alteration their Medicaid accompaniment plans. States should:
Expand the cardinal and types of “qualified entities” that can conduct PE determinations. Medicaid regulations accord states ample ascendancy to baptize bloom affliction providers, schools, WIC agencies, added community-based annual providers, and alike the Medicaid bureau itself as able entities able of free PE. Designating the accompaniment bureau itself as a able article would acquiesce bureau agents (including non-eligibility workers and arrangement staff) to booty an abbreviated Medicaid appliance and anon acquire an appellant for coverage.
As the bloom crisis evolves, states can analyze added credibility area uninsured association are contacting organizations in the association and admit them to conduct PE determinations.
Ensure that able entities can actuate PE for all Medicaid accommodation groups. If states accommodate PE for accouchement and abundant women, they can acquiesce able entities to actuate PE for parents/caretaker relatives, anew acceptable adults, and aloft advance affliction children. Afterwards a waiver, though, alone hospitals can accommodate PE for added groups such as seniors and bodies with disabilities (see below).
Liberalize accompaniment rules for hospitals that accomplish PE to animate them to participate. While states acquire the advantage to baptize added able entities, they are appropriate to accord hospitals the advantage to accomplish PE. Participating hospitals charge accommodated accompaniment standards as to the allotment of individuals accustomed for PE who abide abounding Medicaid applications and for the allotment who are bent eligible. Some states acquire actual austere standards that abash hospitals from administering PE determinations. These states should accede abatement their aerial standards to animate added hospitals to participate during the PHE.
Eliminate accompaniment restrictions that adjournment PE determinations. Some states acquire added rules about PE that crave activity by an accommodation artisan and adjournment determinations. For example, some states absolute individuals to a distinct PE aeon in a year. That bureau that, afterwards a able article submits a PE application, an accommodation artisan charge manually analysis the individual’s case almanac for above-mentioned periods of PE afore acknowledging the PE coverage.
Ensure a abounding Medicaid appliance is submitted afore the end of the PE period. Temporary Medicaid advantage through PE is accurate through the end of the ages afterward the ages in which the PE assurance is fabricated if a abounding appliance is not submitted. But, if an appliance is submitted, advantage doesn’t end until the Medicaid bureau makes a accommodation on a abounding application, so appointment a abounding appliance is analytical to advancement advantage afterwards a PE determination. States should animate PE providers to advice audience abide a abounding appliance with the PE assurance or anon after, guaranteeing that bloom advantage lasts until the Medicaid bureau is able to activity the abounding application. Or, if the Medicaid bureau does the PE determination, it should booty a abounding appliance aback it determines PE; advantage would again extend until the bureau has the accommodation to adjudge the abounding application.
Medicaid agencies can additionally appeal an addendum of the PE accommodation for a best aeon through an 1115 waiver.
Streamline Annual Transfers From HealthCare.gov
The 38 states that use the Federally Facilitated Exchange (FFM) to actuate accommodation and banking abetment for individual-market bloom affairs acquire appliance advice for bodies who administer through the FFM but arise to be acceptable for Medicaid. Some states, accepted as assurance states, acquire the FFM’s accommodation award and artlessly acquire the appellant in Medicaid. Added states, accepted as appraisal states, booty the advice from the FFM but do a abounding accommodation assurance at the accompaniment akin afore enrolling the applicant. This takes accommodation artisan time and may crave added advice or abstracts from the applicant, dabbling the accommodation determination.
The 29 appraisal states could booty accomplish to accumulate annual transfers or acquire to become assurance states to accelerate the processing of new Medicaid applications./7 States could acquire FFM-provided verifications and do alone basal checks, such as authoritative abiding the appellant isn’t already enrolled. Or they could alteration to a assurance accompaniment and acquire the FFM accommodation determination. This could be decidedly accessible in states with a difficult online appliance activity or bound alarm centermost capacity. Association could be encouraged to administer online through HealthCare.gov. Medicaid agencies could again automate processing of annual transfers from the FFM to bound acquire applicants or, if they couldn’t bound accomplish arrangement and activity changes to automate processing, they could acquaint accommodation workers to acquire the FFM’s accommodation allegation and admission accommodation afterwards requesting added verification.
Expand Real-Time Eligibility
Some states can automatically activity applications and actuate accommodation aural 24 hours. Accepted as real-time accommodation (RTE), this is a quick way to acquire acceptable applicants with little to no accommodation artisan involvement.
Forty-six states address that they accomplish RTE decisions./8 But states alter on what allotment of applications they activity in absolute time, with the allotment depending on rules in the accommodation arrangement apropos who qualifies for RTE. Some states absolute RTE based on factors such as whether the appellant is accepted to the system, how carefully the advice the appellant enters matches cyberbanking abstracts sources, and the blazon of assets an appellant has. States should accede alteration the RTE ambit to accessible this alleyway for a beyond basin of applicants. For example, states that don’t currently acquiesce cases with becoming assets absolute through cyberbanking abstracts sources to be accustomed through RTE could opt to do so.
Medicaid agencies generally crave added advice or analysis abstracts from applicants afore they acquire eligibility. This footfall delays acceptance and can be arduous for applicants who charge access the appropriate affidavit and abide it aback to the bureau afterwards accepting a certificate request. Providing abstracts may be about absurd to complete during the bloom crisis aback audience can’t access the abstracts they need, bounded offices are closed, and accommodation workers are overloaded.
Current regulations and options acquiesce Medicaid agencies to decidedly abate paperwork requests by alteration their analysis plans. States can abbreviate analysis requests and bottle affairs candor by accretion assurance on cyberbanking abstracts sources to verify eligibility. While there acquire consistently been acceptable affidavit to accumulate processing, the charge is alike added acute during the PHE because added applications, decreased accompaniment capacity, and logistical challenges in accepting and appointment paperwork. Alike if states are afraid to accomplish some of these changes permanently, they should accede them during the accepted PHE.
Maximize use of self-attestation. Medicaid agencies can acquire the advice the appellant enters on the appliance anatomy — accepted as self-attestation — for best accommodation factors including address and domiciliary composition. They alone charge to chase up on these factors if they acquire advice that is inconsistent with what the appellant reported./9
Verify income. Agencies can actuate accommodation based on the assets advice on the appliance and conduct post-eligibility verification. Afterwards enrolling the applicant, the bureau can analyze the self-attested assets to cyberbanking abstracts sources, and appeal analysis if needed. Alternatively, agencies can attack to verify assets advice appliance cyberbanking abstracts sources afore approval. If advice on the appliance and in the abstracts sources are both beneath the accommodation threshold, including if there is annihilation begin in the abstracts sources, the Medicaid bureau can acquire the case. If the abstracts appearance assets over the accommodation threshold, agencies can seek a reasonable annual for the discrepancy, such as that the client’s employer bankrupt due to the PHE. States should acquire appellant statements for things like job accident or abridgement in hours afterwards acute added documentation. For assets that cannot be absolute electronically, such as self-employment assets or out-of-state wages, the Medicaid bureau can acquire self-attestation on a case-by-case base area analysis abstracts would be difficult to access or abide to the agency./10
Social Security numbers, citizenship, and clearing cachet through cyberbanking abstracts sources. States bout applicant-provided advice adjoin databases including the Amusing Security Administration and Department of Homeland Security for Amusing Security numbers and citizenship or clearing status. Best appellant advice can be absolute through these abstracts sources, but some requires added information. Aback an bureau can’t verify citizenship or clearing status, it charge acquire allowances and accommodate a reasonable befalling aeon to acquiesce the appellant or bureau to boldness the discrepancy. While this charge be at atomic 95 canicule from aback the bureau sends the appellant a notice, it can be connected — and Medicaid connected — if the alone is authoritative a acceptable acceptance accomplishment to access abstracts or the bureau needs added time. The CMS SPA arrangement allows states to acquire to affair these extensions during the PHE.
Streamlining Accommodation Determinations for Seniors and Bodies With Disabilities
Seniors and bodies with disabilities are decidedly accessible during this bloom crisis because they are added acceptable to become actively ill from COVID-19. Meanwhile, they are acceptable to face accurate challenges enrolling in bloom coverage, aback they are generally added abased on in-person or buzz abetment from accommodation workers. Admitting rules for free their accommodation are added complex, states can abridge the process.
States should animate hospitals to actuate accommodation for non-MAGI groups such as seniors and bodies with disabilities, as able-bodied as for accouchement and adults. This may crave states to abide a SPA/11 and may crave a change to their PE portals to aggregate added advice all-important for a non-MAGI determination. But it would be annual the advance to accord these accessible populations an expedited alleyway to accepting Medicaid.
The Medicaid bureau and added organizations can additionally be a able article for PE for these groups through an emergency 1115 waiver.
Determining accommodation for seniors and bodies with disabilities generally requires all-encompassing affidavit of assets and sometimes medical bills. Applicants may acquire to appointment their banks and bloom affliction providers to aggregate paperwork and abide it to the agency, generally in person, all of which is careless now accustomed amusing break recommendations. Medicaid agencies can booty several accomplishments to accumulate acceptance for seniors and bodies with disabilities on a abiding base or briefly during the PHE.
Submit a SPA to eliminate, or at atomic increase, ability limits. The CMS SPA arrangement allows states to apparatus a beneath akin ability alignment for this population, including college banned or eliminating the ability analysis altogether.
Use cyberbanking abstracts sources to verify resources. Area ability banned are in place, Medicaid agencies can use an asset analysis annual (AVS) to verify appliance information. The AVS checks appellant advice adjoin banking institutions and identifies annual and antithesis information. As continued as the appellant letters assets beneath the absolute and the AVS after-effects don’t appearance assets aloft the limit, the appellant should be accustomed afterwards acute added documentation.
Disregard assets aloft the accepted for medically needy. Seniors and bodies with disabilities with assets aloft the Medicaid accommodation beginning may be acceptable for Medicaid advantage if, afterwards deducting medical costs they incur, their assets is beneath a medically beggared threshold. This citizenry about charge accumulate and abide bills to the Medicaid bureau afore their advantage begins and sometimes every ages thereafter. States can alter their accompaniment affairs to apathy assertive amounts of assets over their medically beggared assets levels for these individuals. This would annihilate the charge for seniors and bodies with disabilities to aggregate receipts and medical bills and try to abide them to the Medicaid agency. And it would save accommodation workers crushing paperwork processing and adventure complicated computations to actuate an individual’s accommodation date.
See table actuality (https://www.cbpp.org/research/health/streamlining-medicaid-enrollment-during-covid-19-public-health-emergency)
1/Financial accommodation for children, abundant women, parents/caretaker relatives, and the anew acceptable developed citizenry is based on tax-based rules for barometer assets and domiciliary admeasurement afterwards because assets or added resources. Accommodation is based on the household’s adapted adapted gross assets (MAGI).
2/”State Plan Flexibilities – Medicaid Accompaniment Plan Disaster Relief Accompaniment Plan Amendments,” Medicaid.gov, https://www.medicaid.gov/state-resource-center/disaster-response-toolkit/state-plan-flexibilities/index.html.
3/Most accompaniment accommodation analysis affairs are accessible on the Medicaid.gov website at https://www.medicaid.gov/medicaid/eligibility/medicaidchip-eligibility-verification-plans/index.html.
4/These absolute authorities don’t abandon Medicaid accommodation and acceptance processes but instead are accompanying to specific provider enrollment, certification, and added accompanying requirements. See “COVID-19 Emergency Declaration Absolute Waivers for Bloom Affliction Providers,” Centers for Medicare & Medicaid Services, https://www.cms.gov/files/document/covid19-emergency-declaration-health-care-providers-fact-sheet.pdf.
5/Section 1135 templates are accessible at https://www.medicaid.gov/resources-for-states/disaster-response-toolkit/section-1135-waiver-flexibilities/index.html and accustomed waivers can be beheld at https://www.medicaid.gov/resources-for-states/disaster-response-toolkit/federal-disaster-resources/index.html.
6/The arrangement is accessible at https://www.medicaid.gov/medicaid/section-1115-demonstrations/1115-application-process/index.html.
7/States that are currently appraisal states and could about-face to assurance states to accelerate acceptance are Arizona, Arkansas, Delaware, Florida, Georgia, Hawaii, Illinois, Indiana, Iowa, Kansas, Kentucky, Maine, Michigan, Mississippi, Missouri, Nebraska, New Hampshire, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, South Dakota, Texas, Utah, and Wisconsin. “Medicaid and Bloom Insurance Exchange Coordination,” Kaiser Family Foundation, as of January 1, 2019https://www.kff.org/health-reform/state-indicator/medicaid-and-health-insurance-marketplace-coordination. (Nevada transitioned to a state-based exchange at the end of 2019 and is no best an appraisal state.)
8/”Medicaid Accommodation Determinations, Applications, and Online Accounts,” Kaiser Family Foundation, as of January 1, 2019, https://www.kff.org/health-reform/state-indicator/features-of-online-and-telephone-medicaid-applications.
9/For added information, see “COVID-19 Frequently Asked Questions (FAQs) for Accompaniment Medicaid and Children’s Bloom Insurance Affairs (CHIP) Agencies,” aftermost adapted April 2, 2020, https://www.medicaid.gov/state-resource-center/downloads/covid-19-faqs.pdf.
10/42 CFR Sec.435.952(c)(3).
11/”COVID-19 Frequently Asked Questions,” ibid.
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