ACA Medicaid/CHIP Eligibility Policy Changes & Their System Implica>ons
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1 ACA Medicaid/CHIP Eligibility Policy Changes & Their System Implica>ons Anne Marie Costello, Director of the Division of Eligibility, Enrollment and Outreach, CMCS Jessica Kahn, Ac>ng Director of the Division of State Systems, CMCS
2 Session Purpose To iden>fy the key changes to Medicaid and CHIP policy that are triggering changes to eligibility and enrollment systems
3 Policy #1: The Applica>on Single, streamlined applica>on for all insurance affordability programs Applica>on developed by the Secretary States may use an alterna>ve if approved by the Secretary Can be no more burdensome than applica>on developed by the Secretary and must ensure coordina>on across programs Mul> benefit human services applica>ons may be considered Applica>on may be submiged through mul>ple channels Online, over the telephone, by mail and in person
4 System Response Online account crea>on Either crea>ng or modifying an exis>ng online applica>on on consumer portal Dynamic use of business rules Dynamic use of verifica>ons in real >me ID proofing because of data disclosures if real >me Telephonic signatures Worker portal for paper and in person applicants
5 Policy #2: Automated Verifica>ons A streamlined approach to verifica>on though: Primary reliance upon electronic data sources Use of the hub for mul>ple verifica>ons Local data sources will also be used Increased reliance on self agesta>on and use of post eligibility data matching Decreased reliance on documenta>on May not be the primary source of verifica>on, and may only be requested when electronic data is unavailable or not reasonably compa>ble
6 System Response Enhance or modify exis>ng interfaces with the required data sources to increase capacity for electronic data verifica>on: e.g. SSA, DHS, state wage data either through the Federal Data Services Hub or an exis>ng data portal Development Tes>ng Security safeguards Mini State hubs
7 Policy #3: MAGI Household and Income Coun>ng Rules Align financial eligibility rules across all insurance affordability programs MAGI is a methodology for how income is counted and how household composi>on and family size are determined MAGI is based on federal tax rules for determining adjusted gross income (with some modifica>on) Family = Taxpayer (includes married taxpayers filing jointly) and all claimed tax dependents. Family size = Number of individuals in the family. Household composi>on based on filer and non filer rules Household income = The sum of the taxpayer s MAGI plus the MAGI of tax dependents in the family if required to file. No asset test or disregards (except across the board 5% disregard, bringing income standard for adults to 138%)
8 System Response New rules engine or modify exis>ng rules engine to include MAGI rules For 10/1 12/31, balance two rules engines (current eligibility rules and the MAGI rules) Challenges: Reuse. Development. Tes>ng.
9 Policy #4: Coordina>on with the Marketplace For individuals determined as not eligible by Medicaid/CHIP agency: Evaluates the individual for poten>al eligibility for other insurance affordability programs Transfers the individual s electronic account to the appropriate insurance affordability program (electronic account includes all informa>on/documenta>on collected to determine eligibility) Coordinated eligibility determina>ons with FFM Marketplace makes Medicaid/CHIP MAGI eligibility determina>ons using State eligibility rules and standard verifica>on OR makes ini>al assessment of Medicaid/CHIP eligibility; State Medicaid and CHIP agencies make the final determina>on
10 System Response Business rules and logic designed to for eligibility assessments or determina>ons for Medicaid, CHIP or APTC/CSR (State based Marketplaces and the FFM only) No>ce language Increases complexity of case management, person matching, etc. Account transfers to/from Medicaid/CHIP and the Marketplace
11 Policy #5: No>ces Combined Eligibility No>ce: Single combined no>ce for MAGI based eligibility required to the maximum extent feasible, across all insurance affordability programs and enrollment in a QHP Single combined no>ce generated by the agency that completed the last step in the eligibility determina>on Proposed that states have in place by January 1, 2015 Coordinated content: Informa>on on the transfer of an individual s account to another program for review Required when a combined no>ce is not feasible or prior to implementa>on of a combined no>ce Electronic no>ces permiged at applicant/beneficiary s op>on
12 System Response Programming new kinds of no>ce language Logic for when no>ce is required Electronic no>ces (online portal/account)
13 Policy #6: Renewal Agency renews eligibility based on informa>on in account or other more current available informa>on If beneficiary can be renewed based on available informa>on, agency no>fies individual, but cannot require a signature If the beneficiary cannot be renewed based on the available informa>on Agency must provide a pre populated renewal form with available informa>on and requests any addi>onal informa>on needed to complete eligibility determina>on Beneficiary must be able to respond in same manner as applica>on
14 System Response System analy>cs/logic to run eligibility determina>on based on available informa>on Development of pre populated renewal form System support to renew online
15 Ques>ons/Contact Info
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