Implementing Eligibility Changes under the Affordable ... - Shadac

Implementing Eligibility Changes under the Affordable Care Act: Issues Facing State Medicaid and CHIP ProgramsSTATUS OF ISSUESThrough its regulations, subregulatory guidance,formal presentations, and direct technical assistance,CMS has addressed many of these implementationissues (as well as other implementation issues raisedby states). For example, CMS provided detailedanswers to states' specific questions about householdcomposition, income methodologies, and budgetperiods in the final rule and during a March 29, 2012"Medicaid Eligibility and Enrollment Final Rule"public webinar on "MAGI Methods and HouseholdScenarios." CMS has also provided support to statesfor overhauling or replacing their eligibility systems bymaking available enhanced federal funding,establishing conditions and standards for receipt ofthat funding, issuing guidance on cost allocation, andexpediting the review and approval of planning andimplementation advanced planning documents.Some issues identified by states at our workshop areunresolved, although progress has been made inbringing them to resolution. CMS is currentlyworking with contractors and selected states to testproposed methodologies for converting incomestandards into MAGI-based standards and foridentifying and claiming the newly eligible -- it expectsto issue final regulations on these issues later in 2012.CMS is also working closely with multiple partners todevelop paper and electronic versions of the standardapplication. CMS spelled out its principles for theapplication during an April 19, 2012, public webinaron "Application, Verification, and Renewals," but isstill finalizing the set of questions to be included ineach version. Regarding the federal shared serviceshub, CMS is continuing to consult with its federalpartners and states on its development, but questionsabout data sources, common identifiers, costallocation, and functionality, among others, remain.Questions also remain about language in the March 23rule allowing Medicaid agencies to delegate eligibilitydeterminations to an exchange (even when privatecontractors operate it) - states would like clarificationabout the meaning of the "merit system personnelprotection principles" exchange entities must employ.CONCLUSIONIf implemented successfully, the Affordable CareAct's Medicaid eligibility provisions could modernizeand streamline the process by which low-incomeuninsured and underinsured individuals and familiesenroll in Medicaid, CHIP, and other affordableinsurance coverage options. Implementation requiressubstantial policy development, information systemsupdates, and, potentially, organizational changes. It isespecially difficult at the state level due to the need tofollow federal guidance and resource constraints.Since the ACA's March 2010 enactment, CMS, otherfederal agencies, state governments, and many otherstakeholders have engaged in a flurry ofimplementation activities, which have resulted in finalguidance and financial and technical support forstates; however, many of the implementation issuesstate Medicaid and CHIP eligibility directors haveidentified remain unresolved. Regular two-waycommunication between CMS and states, includingdetailed discussion of outstanding issues like thatfacilitated in a SHARE workshop, will facilitate timelyimplementation.This brief follows a November 2011 presentationat the Association for Public Policy Analysis andManagement (APPAM) Fall Conference regardingstate perspectives on implementing expandingMedicaid eligibility under the ACA, which isavailable athttp://www.shadac.org/publications/MedicaidEligibilityMAGI_state. It is a companion to the brieftitled “Income Eligibilityfor Assistance under the Affordable Care Act:Estimates for Nonelderly Adults" and to the brieftitled “Translating Modified Adjusted GrossIncome (MAGI) to Current Monthly Income,”which can be found atwww.shadac.org/share/grant/Eligibility-MAGI.SHARE STATE HEALTH ACCESS REFORM EVALUATION WWW.SHADAC.ORG/SHARE 5