State Medicaid Snapshot: Affordable Care Act Implementation

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Ernest Banks
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State Medicaid Snapshot: Affordable Care Act Implementation As of September 15 th, 2013 The periodic State Medicaid Snapshot is a tool that allows Medicaid Directors to monitor their state s work to

1 State Medicaid Snapshot: Affordable Care Act Implementation As of September 15 th, 2013 The periodic State Medicaid Snapshot is a tool that allows Medicaid Directors to monitor their state s work to move forward with the Affordable Care Act s (ACA) Medicaid-related requirements in relation to other states. As with NAMD s first publication, this is a snapshot of progress based on NAMD s outreach to a representative cross section of states. This report captures state implementation status at a point from July 31st through early September In the final days before a major implementation deadline, states have had to prioritize work on the items essential to October 1. While states work through some tasks in advance of the October 1 go-live, they will also continue to develop and refine other aspects throughout the initial implementation period. This report focuses on these two separate but parallel tracks. The report provides a point in time snapshot across Medicaid s functions to determine state progress amidst major program development and addresses the significant system complexities that states are experiencing during the implementation process. 444 North Capitol Street, Suite 524 Washington, DC Phone:

2 Progress Summary Status of PCP Rate Increase Almost all states surveyed are currently paying the enhanced primary care rate. Some states have reported making retro-active payments as needed. Eligibility and Enrollment (E&E) Systems- States continue to work with vendors to refine system details and are moving through a series of testing phases. If they weren t already, most states anticipate they will be in the testing phase for their systems at some point this month. Some indicated they are on track to meet their state s readiness expectations for October 1 st. Hub Connectivity States reported progress along the entire spectrum for interactions with the federal hub. Some states are working on a connection to the hub while others are in the final phases of testing. Identity Proofing -This is an area where some states have made a big jump in implementation. Some states reported moving from the designing phase to the testing phase of identity proofing concepts, while others are continuing to design these pieces of their systems. Page 2 of 5

3 Income Conversion More states have reported receiving approval from CMS on their submitted state plan amendments (SPAs) for MAGI income conversion. While some states are still working to submit their proposals, most reported submission of their SPAs and some states responded that they have received approval. Streamlined Application States continue to develop their streamlined applications, and some have received clarification from CMS on changes that will require federal approval. While the majority of states have made modifications to their streamlined applications, they have not submitted to CMS for approval. Presumptive Eligibility (PE) States are reporting that they are still in the design phase. They are focused on assessing model practices that may be appropriate to apply in their state, talking with stakeholders, and conducting internal conversations on how to operationalize their PE programs. Expansion States FMAP Claiming Methodology Many of the expansion states reported that they are planning to submit their methodologies to CMS in while some others noted that they have already done so. Page 3 of 5

4 Alternative Benefit Plan (ABP) Status States are in the midst of internal analysis and conversations with CMS to inform the design of benefit packages for the new expansion population. States described their status as preparing for SPA submission, while simultaneously determining needed contract adjustments and conducting rate setting analyses. Overarching Themes and Trends Communications and Interactions with Public States are engaged in strategies to develop materials and implement initiatives to raise awareness of the coming changes within their health care system. Since each state Medicaid program is designed differently, these efforts must be tailored in a variety of ways. Medicaid agencies are augmenting call center capacity, and re-training eligibility staff to send a consistent message to the public about the Medicaid program. In addition to working to retrain their own eligibility staff and any communications activities they undertake, Medicaid agencies also are working to ensure they are linked up with the other outreach initiatives and navigators programs initiated through the new marketplaces entities, whether these are state-based or federally facilitated, as well as similar work that is undertaken by non-governmental entities. Alternative Benefit Plan Submission Currently, expansion states are designing their alternative benefit plans (ABP) for the newly eligible population. This process is challenging because many of the moving parts of implementation for the expansion hinge on the approval of the ABP; for example modifications to or new contracts with health plan organizations, state agency training, and communications with providers and consumers. States continue to work through the benefit package analysis and consult with CMS officials prior to SPA submission. As states continue these conversations, some are targeting submission of SPAs for later in September and others later this fall. In turn, this may impact the timing of any CMS approval needed for state contracts with managed care entities. Mitigation Planning Mitigation planning refers to the processes a state is developing to ensure that eligibility is determined regardless of the state s progress on implementation of new policy and program changes required by Affordable Care Act. Some states report that certain Page 4 of 5

5 components are not expected to be fully functional for October 1 st, and they are working to develop alternative or transitional processes that support their specific state needs. The ability for states to align their current programs with the new standard federal requirements has created large variation in states systems functionality. As states develop their respective mitigation strategies, they are working to find solutions to the discrepancies between existing state programs and new federal requirements. It is important to note that all states began implementation from different places based on the status and design of their current Medicaid programs. Some states had online applications, real-time verification processes and/or had expanded coverage to more populations before the passage of the ACA. With these and many other variations in mind, states are working with CMS to tailor their systems to meet the needs of day 1 while planning to refine and streamline operations over time. Two areas mentioned by states as current focal points in the implementation process are discussed below: Eligibility System Preparedness Medicaid agencies have extensive experience managing changes within their eligibility systems. With the October 1 st launch date approaching, states will use these techniques to implement work-arounds that they have developed in collaboration with CMS to ensure consumers receive timely, accurate information and eligibility determinations. Along with technical solutions, states are in constant communication with sister agencies, vendors and CMS to formulate the best possible route for running E&E systems during the initial open enrollment period. Account Transfers A notable piece of the implementation process in Federally-Facilitated Marketplace (FFM) states is the progress toward functional communication between the state Medicaid agency and the insurance marketplace. At the time of this report, state implementation status varies widely, and some Medicaid programs could experience challenges in their ability to transfer accounts with the FFM. The disconnects between the two entities are being worked through on a state-by-state basis; states are in conversations with CMS and their sister agencies to create state-specific solutions for timely account transfer. Page 5 of 5

Frequently Asked Questions on Exchanges, Market Reforms and Medicaid

Frequently Asked Questions on Exchanges, Market Reforms and Medicaid DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services 7500 Security Boulevard, Mail Stop C2-21-15 Baltimore, Maryland 21244-1850 Date: December 10, 2012 Subject: Frequently Asked