The Connecting to Coverage Coalition (CCC) applauds the Centers for Medicare & Medicaid Services (CMS) for implementing key measures aimed at maintaining enrollment for individuals eligible for Medicaid and the Children’s Health Insurance Program (CHIP), as well as assisting those who are no longer eligible with securing alternative health coverage options through the federal or state-based Marketplace, Medicare, or employer-provided coverage. We recognize this has been a multi-year planning and implementation process, with much of the heavy lifting occurring at the state level, with “all hands-on deck” support from a myriad of partners. While much work remains to support individuals through the redetermination process, the member organizations of the CCC are pleased to see these important steps and look forward to partnering with CMS and states to further assist individuals and families.
In particular, the CCC greatly appreciates the clarification of existing policies and flexibilities that allow Medicaid managed care organizations (MCO) to play a key role in helping individuals through the redetermination process. Importantly, MCOs will be able to support states with the eligibility process by contacting enrollees, filling out forms, recording a telephonic or electronic signature, and submitting completed applications. The newly announced final rule also builds on the unwinding experience and improves how states identify address changes and helps ensure states have the correct contact information for enrollees. This includes allowing states to partner with contracted managed care plans as reliable data sources, as well as utilizing the National Change of Address (NCOA) database. By taking these steps to improve the enrollment and renewal process for enrollees, CMS is acknowledging the collective input from CCC members who advocate for uninterrupted access to care during this unprecedented time in the Medicaid program.
The CCC also wants to recognize the historic improvements in the use of ex parte to determine eligibility at renewal. With support from CMS, states have streamlined and improved the accuracy of the eligibility process, and we urge CMS to continue supporting states to increase utilization of this important process going forward. Additionally, the CCC is pleased to see these additional policies by CMS:
- An extension of the temporary special enrollment period (SEP) for the Health Insurance Marketplace until November 30, 2024 — a vital step to ensure that individuals transitioning out of Medicaid or CHIP can remain connected to coverage;
- New resources geared toward helping families navigate their state’s fair hearing process;
- Efforts to align non-MAGI and MAGI eligibility processes, including extending protections such as the use of prepopulated renewal forms and reconsideration periods to the non-MAGI populations; and
- Smoothing the transition of children between Medicaid and CHIP.
While these steps are encouraging, much work remains ahead to ensure that Medicaid-eligible individuals do not lose coverage, and to connect people who are no longer eligible for Medicaid to other health coverage options. We encourage CMS to continue exploring all available tools at the federal government’s disposal to help keep people connected to coverage, including extending flexibilities that maximize ex parte renewals and expanding upon data collection efforts. The CCC and its members continue to support federal and state officials in ensuring a smooth transition from the continuous coverage requirement and making long term improvements to Medicaid renewals and transitions.