ACA 101 Conference Call FAQs

ACA 101 Conference Call FAQs 1. How will MA help residents (particularly the most vulnerable) transition from the simplicity of needing a pay stub for eligibility to having to have their taxes filed? This seems like a critical change from the state's law for at least a portion of the population served by MassHealth and Commonwealth Care. Individuals that do not file taxes and we are unable to obtain a data match, that individual may be required to submit verification of income as they do today. The same type of documents used for verifications today will be acceptable in 2014, such as pay stubs, Social Security letters, last year s federal tax return, & pension award letter. For those individuals that are within the FPL range that could qualify to purchase a Qualified Health Plan (QHP), the individual will need to file taxes for the years in which they receive premium tax credits. 2. Are there new roles for example Certified Application Counselor and Health Reform Ambassadors? How would I go about applying for one of the new roles? Certified Application Counselors is a new term that we have received through federal guidance. Both MassHealth and the Health Connector have been looking very closely at the responsibilities associated with certified application counselors. We think this role is very similar to the current virtual gateway providers role and will provide more information once a final decision is made. Health reform ambassadors are individuals who can help support outreach efforts in Massachusetts communities. Ambassadors are a shared resource between the Health Connector and MassHealth. 3. As I understand the new requirements for health insurance eligibility, residents will need to have their Modified Adjusted Gross Income from the most recent tax year a much more stringent requirement than the current law. So two questions: a. If Commonwealth Care members need to transition to new insurance by the end of December, does that mean they must file 2012 taxes? Commonwealth Care (CommCare) programs will be ending as of December 31, 2013. CommCare members at or below 133% FPL will transition to MassHealth coverage. CommCare members above 133% will be eligible for qualified health plan coverage (QHP) through the Health Connector and will need to apply for coverage during the open enrollment period, October 1, 2013 to January 1, 2014. CommCare members will receive information about their changes in coverage and any next steps that will be required. 7/17/13 Page 1

For Commonwealth Care members that will need to apply for QHP coverage, the application will ask questions on filing taxes. If the individual does not file taxes/plan to file taxes, then they may not be eligible for subsidies to help pay for their QHP coverage. In order to receive Premium Tax Credit (PTC) a person must file taxes for the year that Premium Tax Credits are received. NOTE: married couples must also file a joint tax return. b. What about the population that is currently not required to file taxes? Must they still do so in order to be eligible for health insurance? Modified Adjusted Gross Income (MAGI) will be used to count income and determine household composition. If a person does not file taxes, they will be asked to submit verification of income as they do today. For MassHealth there is no change to verifying income as done today. For those individuals who do not file taxes or who we cannot get a data match for income, or who are not consider Reasonably Compatible, income verification can be submitted as it is done today. For Premium Tax Credits the individual can submit paper verifications, as done for MassHealth today. NOTE: In order to receive Premium Tax Credit a person must file taxes for the year that Premium Tax Credits are received. Married couples must also file a joint tax return. 4. What will happen to those individuals whose address are unknown and mail comes back as undeliverable and therefore are not aware of the deadlines, changes, etc? Most MassHealth members will not experience a change in coverage due to ACA. Those MassHealth members that will experience a change in coverage (such as MassHealth Essential and MassHealth Basic) will be notified that they will be transitioned to a new coverage type under ACA. For certain MassHealth and Commonwealth care members that will be eligible for QHP coverage they will be notified that they will need to apply. In addition to direct mailings, member communication plans also include an outbound call campaign, postcards and emails to ensure individuals that that will experience a change in coverage are informed of any next steps that will need to take. In terms of any new applicants, the application will ask about the applicant s address. We will be data matching to verify information. If the system is unable to verify any information through data matching, the individual may be required to submit verifications. Similar to today, certain exceptions will apply (i.e. homeless etc.) 5. What are the names of the plans that will be available for those who are not eligible for MassHealth or employer sponsor health insurance? The Health Connector is currently conducting the seal of approval process. It will be completed at the end of the summer and will be announced at the Health Connector s September board meeting. 6. "No change in coverage to individuals 65 and over". Why do the changes in the ACA only affect the under 65 population? The federal health reform law changes to subsidized coverage apply to the under 65 populations. The ACA did include provisions pertaining to Medicare Part D and reducing the donut hole, eliminating the donut hole by 2020. 7/17/13 Page 2

7. What is the difference between Navigators and Certified Application Counselors? A Navigator program is a requirement for all state based exchanges. Massachusetts is working to create its own navigator program. We are currently in the middle of a grant procurement process. More information will be coming in the next couple of months. Certified Application Counselors is a new term that we have received through federal guidance we have received through federal guidance. Both MassHealth and the Health Connector have been looking very closely at the responsibilities associated with certified application counselors. We think this role is very similar to the current virtual gateway provider role and will communicate information to folks once a final decision is made. 8. Still unclear on Health Safety Net (HSN) changes? The HSN will continue to operate and serve low-income patients throughout the implementation of the ACA. As specific policies are finalized, we will continue to bring this information to providers and other stakeholders. 9. I am an employer with employees in multiple states. We do not provide credible coverage for all MA employees and we currently pay the Fair Share Penalty. If we offer coverage that meets Federal MEC to all eligible employees, will we still have to pay the Fair Share Penalty because we do not meet MCC? Yes, they could be. Massachusetts residents must be covered by insurance that meets Massachusetts Minimum Creditable Coverage (MCC) in order to fulfill the individual mandate and avoid a penalty. If the person has non-mcc compliant coverage, he/she could be liable for a penalty, unless he/she is exempt for reasons of affordability or hardship. (An official determination of affordability and any applicable penalty occurs at the time a person files his/her state income taxes.) a. Also, if we do not offer coverage to our employees at all, will we have to pay the Federal penalty and the Fair Share Penalty for all of our MA employees? Will we be double penalized? I'm the Benefits Administrator working in Atlanta, GA. Yes, they could be. However, there is legislation to repeal the MA Fair Share rules, but it has not been ruled on. So as it stands right now, a Massachusetts resident working in the Massachusetts office of an out-of-state/international company that provides insurance that meets federal ACA requirements, but not MCC requirements, will be subject to the Massachusetts Fair Share rules. An out-of-state/international employer, however, will be able to seek certification of its insurance plan(s) as MCC compliant, even though the insurance plan might not meet all the specific MCC regulations. For instance, plans that offer coverage that roughly approximates the benefits of MCC could apply for certification. An employee covered by a health insurance plan certified by the Health Connector would meet his/her individual mandate requirement. 10. What does family composition mean? Under ACA, Modified Adjusted Gross Income (MAGI) methodology will be used for income counting and determining household composition. MAGI follows tax household rules to determine household composition. 7/17/13 Page 3

For tax subsidies, the tax household rules always apply. For MassHealth, tax household rules are used, but some exceptions apply based on family relationships and who lives together. 11. What goes into determining MAGI? Generally, MAGI is a methodology that uses federal income tax rules and concepts to count income and determine household composition and family size. Federal income tax rules and concepts of adjusted gross income (with some modifications) are used, but it is not simply a number off a tax return. Please reference An Overview of MAGI presentation posted on the MTF website for more comprehensive details. 12. Does real time determination mean that the person is approved and active as soon as they pay or is there still a wait until the first of the month? In every instance possible, a real time eligibility determination will be made. If an individual qualifies for a QHP, individuals will be able to shop among plans. In order to enroll, the premium must be paid for coverage effective the 1 st of the following month. 13. What if a person stopped working yesterday, will the Federal Data Hub show that? No. However, an individual, as they do today, should report current circumstances to ensure an accurate eligibility determination is made. 14. Individuals who are undocumented are they cross matched with the Federal Data Hub? The federal data hub will be using a variety of information to match against self-attested information reported by the applicant. This includes, but is not limited to, Department of Homeland Security and Social Security Administration. If a match does not come back, an applicant would need to send in acceptable documentation to verify their immigration status. 15. Where does certification occur for application counselors? To be determined 16. Is Maximus going to continue to be MH Customer Service? Yes 17. What employer information will need to be provided for the Federal Hub match to work? This will be addressed in more comprehensive training on the new single streamlined application and HIX system, which will be rolled out in the very near future. 18. Where do questions for identity proofing come from? How is residency going to be matched? The identifying proofing questions are a federal requirement of the new system. They are for security purposes to ensure the individual entering the information on the application or making an update to 7/17/13 Page 4

their case, is the actual person they say they are. This is a new security feature and has nothing to do with identification verification requirements pertaining to an eligibility determination. For state residency, an applicant will be asked if they live in Massachusetts and have the intention to reside in the Commonwealth. This is self-attested information. In terms of address information, that will be checked to ensure it is a valid/real address (not a P.O. Box or corporate business address for example) and that the individual is associated with the address. Depending on the match information, the applicant may be required to send in proof of address (the same types of verifications accepted by MassHealth today will continue under ACA) 19. If ERV is auto verified through the Federal Hub, will an ERV still be sent out to the clients? If we are able to verify the necessary information through data matching at annual renewal, we will aim to have the individual just verify the data matching information and not complete a whole ERV. 20. What is the definition of lawfully present? "Lawfully present" are immigrants or noncitizens who have been inspected and admitted into the United States and not overstayed the period for which they were admitted, or have current permission from the U.S. Citizenship and Immigrant Services (CIS) to stay or live in the U.S. 21. What is the time line for consumer contacts about the changes? (When will mailings be expected out etc.?) Information will likely be going out in late summer/early fall. As member transition communication plans are finalized, they will be shared through MTF. 22. Is the Breast & Cervical cancer program back? And how is it going to be run? We were told over a year ago to stop sending clients to the agency that did applications for this program because it had lost funding so was no longer able to cover those individuals. The program was never stopped and is currently being handled at the central office in Quincy. MassHealth has requested federal authority to cover individuals with incomes between 133% and 250% FPL. This is currently pending with CMS. 23. Is there any idea if there will be different names for the MassHealth plans or will it just be called MassHealth? Under ACA, some MassHealth coverage types will be eliminated. These include MassHealth Basic, MassHealth Essential and Insurance Partnership. A new MassHealth coverage type, that will provide coverage to some of the individuals under the Medicaid expansion, will be available and will be called MassHealth CarePlus. An active procurement is underway, the health plans that will provide coverage under MassHealth CarePlus are not yet determined. 24. What are the qualifying events for special enrollment? Qualifying events include birth, marriage, loss of insurance, etc. 25. What tiers in the metallic system will people who qualify for subsidies going to be able to select from? Silver Tier 7/17/13 Page 5

26. I would like to know how and how often the CommCare clients will be notified of the pending transition coming. Member transition communication plans are being finalized and will be shared through MTF. Plans include multi forms of communication channels direct mail, phone calls, emails, postcards etc. 27. Will HSN be available to people who are eligible for QHP but outside of open enrollment? Will they get a reminder & help to enroll when enrollment is open? To be determined 28. Will partial HSN be available as secondary for people in QHP with income 300-400% FPL (federal PTC but no state subsidy)? To be determined 29. Slide 33: where do the elderly & disabled not in LTC fit into the model? What is meant by a "screen?" Is it something other than an application? For individuals applying for MassHealth coverage, the same rules that exist today will exist under ACA. For example, asset test etc. will remain in place. The subsidized changes included under the federal health reform law pertain to the population under 65 only. 30. As the open enrollment period ends 3/31/2014 for policies effective 1/1/2014: For someone that does not enroll until 3/31/2014, what will I see for eligibility if I go onto MMIS 1/1/2014? If an individual/family shops between 10/1/13-12/20/13 they will have an effective date of 1/1/14. If an individual shops during 1/1/14-3/31/14 they could have an effective date for February April 2014. 31. Are they certain about the roll-out date for HIX/IES application and transition? Any updates on roll-out and functionality of the new HIX/IES system will be communicated through MTF. 32. Is it realistic to get real-time response to applications done on line? Yes, that is the goal. Not every case will result in a real time eligibility determination for example if certain missing critical data is not included the system will not be able to make a full determination. However, the goal is to make real time eligibility determinations for as many applications as possible. 33. Have they ever straightened out the redetermination mess i.e. people sending the forms and it getting lost and the Insurance carrier drops the patient? Certain implementations have enhanced the redetermination process, i.e. administrative reviews, express lane renewals and the e-fax scanning process. Just like through the new HIX/IES system, the Commonwealth will leverage data matching for the initial application and we plan to leverage data matching for the renewal. This should significantly streamline the process for the individuals. Future plans will include a pre-populated ERV form based on the data matching. We will continue to provide updates on timing of rollouts of the new HIX/IES system functionality. 7/17/13 Page 6

34. Will people that are eligible for tax credits to help them pay for their premiums and cost-sharing for a QHP be able to enroll to get tax credits anytime or are they now also subject to the open enrollment rules? For example, people can apply for Commonwealth Care right now at any time during the year. Will this change in the post ACA world? People applying for the first time or having a qualifying event will not be subject to open enrollment. 35. Will people be eligible for tax credits AND will it help pay for cost sharing up to 300% FPL or 250% FPL? There were different answers provided during the call. Federal cost sharing reductions are up to 250% FPL; State cost sharing reductions are up to 300% FPL. 36. In the new system, checks will be performed for citizenship and immigration status through the department of homeland security. Does this mean that undocumented individuals will be reported to INS? In the past, we had written assurance that this would not happen. Will we get such an assurance with this new system? There will be no reporting to INS. A data match does not constitute a report. 37. I do not understand the information about the affordability schedule. Is the middle column what someone in a particular category will pay for insurance? Or is this the penalty they will pay for not having insurance? This still feels vague to me. While it's good to know these are the changes coming, I need specifics on what will the programs be. What will be the coverage? What will the process for MAGI look like and how will an individual actually apply it? What processes will be in place when? Will those over the 400% still have to purchase insurance at the private rate? Will these affordable plans be state sponsored or private insurance companies? What flexibility is built into the programs, i.e. becoming eligible out of the enrollment dates? Traditionally, I believe, open enrollment has been used to change plans or coverage for employer based insurance, not enter for the first time, unless one does not respond to the original confirmation. Thank you for your interest and questions. Please reference our topic specific presentations on MAGI and federal and state subsidies. All topic specific presentations are located on the MTF website. Please continue to stay connected to MTF, as many of these updates will be shared in the very near future. 38. If someone is currently over-income for Commonwealth Care and must buy Commonwealth Choice from July 1 - August 15, will they be able to apply for QHP subsidies in October for January 1, or do they have to wait until after January 1? If they shop and purchase a CommChoice plan during Open Enrollment they will have a shortened plan year, ending at the end of March 2014. In addition, they will have the opportunity to end their plan sooner and shop during the Federal OE October 1, 2013 March 31, 2014 for a plan starting as early as January 1, 2014. 39. How are individuals going to prove that he or she cannot afford the specific insurance premium? As we have today, it will be based on the affordability schedule. 40. Currently an individual is not eligible for CommCare when an employer offers health insurance and contributes 33% of the cost for an individual or 20% towards a family plan. An example, referencing the Affordability Schedule for Individuals on Page 16 of the presentation: A person making 230%FPL 7/17/13 Page 7

reads that the maximum monthly premium (s) he can afford to pay is $78.00 per month. So, if the employees cost is $200.00 per month, through his employer who pays for 33%, - is the employee eligible for an ACA plan or must (s)he take the employer offered plan. Might the 33% Individual and 20% Family employer mandate be changing, so the question is moot? Or is there some new % contribution rule that employers must follow? There is a new Expected Contribution calculation, which is the percent that each individual is expected to pay towards their health insurance premium. If an individual s contribution for ESI is more than 9.5% of their household income then it would be deemed unaffordable and they would be able to shop for a QHP. Also, an employer sponsored plan needs to meet minimum value which would mean the plan has an actuarial value of 60%. If it doesn t an individual would be able to shop for a QHP. 41. Is it necessary for financial counselors at transplant centers to notify their patients who have Commonwealth Care or Medical Security Plan that their insurance will need to change before 1/1/2014? Member transition communication plans will be shared via MTF once finalized. Members that will experience a change in coverage will be notified and will be provided information of any next steps they may be required to take. 7/17/13 Page 8