Although there has been enough federal guidance issued lately to get anyone’s summer reading list off to a strong start, we’ve got another set of documents to add to your pile. Or better yet, check out the enrollment-related highlights below and save yourself a bit of time. CMS just issued a set of Q&As that address some of the most frequently asked questions it has received from states about the Medicaid expansion, eligibility coordination, and enrollment simplification.
Topics covered include:
- Eligibility and Enrollment Systems
- Eligibility Policy
- Coordination Across Insurance Affordability Programs
- Section 1115 Waiver Transitions
- Children’s Health Insurance Program
- Benefits/Delivery System
- Federal Medical Assistance Percentages
- What’s the latest on the data hub? The Eligibility and Enrollment Systems Q&A provides an update. CMS is in the process of establishing the data requirements for eligibility and enrollment systems. These requirements will be used to guide states and to ensure that these systems are functional and comply with federal regulations. CMS is also working with states to ensure they are ready to interface with the Federal Data Services Hub by January 2014.
- When can a state rely on self-attestation? The Eligibility Policy Q&A clarifies one of our favorite parts of the eligibility and enrollment regulations: Self-attestation is allowed for all eligibility factors except citizenship and immigration status. The fewer documentation barriers states put up, the more people will enroll. Are you speaking up to encourage your state to accept attestation for as many aspects of eligibility as possible?
- Will Medicaid/CHIP verification plans be publicly available? Verification plans do not need to be part of a state’s Medicaid/CHIP State Plan, but they do need to be a written plan that will be publicly available on request. Verification plans have to include information about which data sources the state uses to verify different eligibility criteria, how the state will define reasonable compatibility, and when self-attestation will be accepted. This information will be crucial to ensuring coordination between Medicaid, CHIP, and exchanges, so keep an eye out for it in your state!
- Will Medicaid/exchange coordination plans be publicly available? On a related note, the Coordination Q&A mentions that the required coordination plans between Medicaid agencies and exchanges will be available to the Secretary of HHS upon request, and they will be obtainable through freedom of information requests. States will not be required to share them publicly, but they can choose to make them publicly available. Stakeholders should encourage states to do this.
- What’s a shared eligibility service? The “shared eligibility service” includes three major parts: the application, verification rules, and business rules. Together, these three elements determine whether someone is eligible for Medicaid, CHIP, or the exchange (and premium tax credits). And even if a state’s Medicaid agency retains ultimate authority to make Medicaid determinations, “the underlying business rules and processes are nearly identical, and should, to the maximum extent practicable, rely upon a shared IT service(s) and infrastructure.”
- Can exchanges make Medicaid eligibility determinations? The Coordination Q&A also clarifies that Federally-Facilitated Exchanges can determine MAGI-related Medicaid eligibility if the state chooses to allow this arrangement. State-based exchanges can make both MAGI and non-MAGI Medicaid eligibility determinations if the state chooses.
The Q&As provide insight into CMS’s latest thinking on these and other important enrollment issues.