Medicaid Regulations Pave the Way to Simple Enrollment

By Jennifer Sullivan

Last week, we gave a quick summary of the changes made in the final exchange regulations, which were issued March 12. The Centers for Medicare and Medicaid Services (CMS) also issued final regulations on eligibility and enrollment for Medicaid and the Children’s Health Insurance Program (CHIP) late last week. The rule finalizes the Medicaid expansion to non-elderly adults with incomes up to 133 percent of the federal poverty level ($14,856 for an individual or $25,390 for a family of three). It also serves as a complement to the exchange eligibility rules, promoting a vision for simple and streamlined eligibility, enrollment, and renewal processes for consumers. The final rule includes a few changes that will make enrollment and renewal even easier:

  • Medicaid agencies will be allowed to delegate income-based Medicaid determinations to non-governmental exchanges, instead of just governmental exchanges as originally proposed.
  • Medicaid program information must be available on the program website, and it must be available in formats that people with limited English proficiency or disabilities can access.
  • Clarifies that people receiving an income-based Medicaid (or CHIP) eligibility determination are not subject to asset tests and cannot be required to complete an in-person interview as part of the application or renewal process.
  • Clarifies that states must use a pre-populated Medicaid (or CHIP) renewal form and cannot require enrollees to sign or return the form if there is no change in their circumstances.
  • Clarifies Medicaid and CHIP verification standards and requires states to rely primarily on electronic data sources to resolve inconsistencies between the information an applicant or enrollee provides and information available through electronic data matches.

As with the exchange regulations, a handful of provisions were issued as interim final. CMS is accepting public comments on the following provisions until mid-May:

  • 431.300(c)(1) and (d) and 431.305(b)(6) on sharing and protection of applicants’ eligibility-related information
  • 435.912 on proposed timeliness and performance standards for Medicaid eligibility determinations (The corresponding section for CHIP, which is also open for comment, is 457.340(d).)
  • 435.1200 on new options for coordination of eligibility determinations between Medicaid programs and health insurance exchanges (The corresponding sections for CHIP, which are also open for comments, are 457.348 and 457.350(a),(b),(c),(f),(i),(j), and (k).)

We’ll talk more about these rules and how they fit together with the exchange rules in the future, so be sure to check back!

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