Safety Net Streamlining Proposal Signals AAFP Advocacy Win
Rule Would Shrink Post-PHE Coverage Gaps
Dec. 19, 2022, 1:53 p.m. News Staff — A proposed rule from CMS meant to boost Medicaid, CHIP and Basic Health Program enrollment and equity includes numerous potential wins for family medicine practices and vulnerable patient populations, the Academy told the agency.
Streamlining processes in those programs, said the AAFP’s letter, will lower enrollment churn in favor of continuous health care coverage — “which in turn reduces administrative burdens on physicians and their practices and helps physicians maintain continuity and trust in their relationships with their patients.”
The Academy was responding to a proposed rule titled “Streamlining the Medicaid, Children’s Health Insurance Program, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Processes,” published Sept. 7 in the Federal Register.
The letter recognized most of the rule’s proposed changes to Medicaid, CHIP and BHP application, eligibility determination, enrollment and renewal processes as moves likely to improve equitable access to primary care and behavioral health care as well as program integrity. In line with related advocacy this year centered on safeguarding patient care beyond the COVID-19 public health emergency, the Academy expressed broad support for the rule, alongside comprehensive recommendations on how to optimize its benefits.
Medicaid Enrollment
The Academy voiced strong approval for an element of the rule that would ease Medicaid access for some Medicare patients.
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“Many Medicare beneficiaries are also eligible for several Medicaid benefits but aren’t accessing them,” the letter said. “These individuals, known as dual eligibles, are low income and have a high prevalence of chronic conditions and disabilities, substantial care needs and disproportionately high Medicaid and Medicare expenditures. Dual eligibles often do not have another source of health insurance beyond Medicare, and without Medicaid support they may be unable to access services that are not covered by Medicare, such as long-term services and supports.
“The AAFP supports federal policies that streamline and standardize access to Medicaid benefits for dual eligibles across states, assist beneficiaries with enrolling in benefits they are eligible for and remove cost barriers.”
If enacted, the rule would require states to use existing data to help facilitate Medicaid and Medicare Savings Program enrollment. The letter recognized this as an improvement also likely to reduce cost barriers for eligible individuals and repeated the AAFP’s call for CMS to assist states with incorporating data from non-health programs into eligibility determination processes.
“Data flow between state agencies and with federal benefits programs should be maximized so that individuals are at least automatically referred to or have their applications initiated to benefit from other available programs for which they may be eligible without excessive administrative burden on both agency staff and beneficiaries,” the Academy said.
To prevent Medicaid beneficiaries from losing coverage, along with vital care continuity, as states redetermine their eligibility after the PHE ends, the Academy urged CMS to allow patients 60 days (rather than the rule’s proposed 30 days) to seek re-enrollment.
Expressing strong support for the proposed rule’s mandate that states conduct a series of data checks and outreach attempts to locate beneficiaries and verify their addresses to determine eligibility, redetermination or renewal, the letter reminded CMS that it should compel states to use multiple forms of communication when attempting to reach individuals.
The agency also should “consider requiring state redetermination plans to be continually updated and made publicly available,” the letter added.
Transitions
“The AAFP supports CMS’ proposal to require seamless transition of eligibility determinations between Medicaid, CHIP and BHP agencies, along with the issuance of a combined notice to individuals who may be in this situation,” the letter said.
Beyond that, “CMS should take steps to help applicants understand what transitions mean for them,” the Academy wrote. “This could include CMS developing and releasing informational materials for state Medicaid and CHIP agencies to send to enrollees, along with the combined notice referenced in this proposed rule, with detailed information on any change in the beneficiary’s benefits, premium level, cost sharing and related information. CMS may consider using navigators to work with enrollees who need to undergo renewal to submit the appropriate information for the renewal form and/or understand the transition to Medicaid from CHIP and vice versa.”
CHIP
Noting that children covered by CHIP have better access to primary, preventive, specialist and other care compared with uninsured children, the letter said the Academy would applaud any effort to streamline the program’s enrollment, determination and redetermination policies. Specific to this proposed rule, the AAFP voiced support for its elimination of premium lock-outs, waiting periods and annual and lifetime limits on benefits for CHIP enrollees. These improvements, the letter said, are in line with the AAFP’s Health Care for All policy framework.