“Reasonable” Flexibility: Exploring Models to Help States Resolve Inconsistencies in Income for Medicaid, CHIP and Tax Credit Eligibility Webinar
Manatt Health Solutions - Deborah Bachrach and Kinda Serafi
This webinar offered detailed analysis of the standards under which states can find “reasonable compatibility” of income information provided by applicants for Medicaid, CHIP and the exchanges that is not precisely equivalent. Income data is typically neither static nor centralized, and states must be prepared to resolve discrepancies when income data is submitted by applicants or retrieved from state, federal, or other independent sources. In the case of a discrepancy, CMS eligibility rules provide guidelines to help states proceed with an eligibility determination, including some flexibility for states to find data is “reasonably compatible.” These rules, which will apply to advance premium tax credit (APTC) and cost-sharing requirement (CSR), provide states with critical flexibility to operationalize eligibility decision-making by allowing states to accept small deviations in income data from different sources.
On this July 16, 2012 webinar, Deborah Bachrach and Kinda Serafi of Manatt Health Solutions, walked participants through straw models they have created to help states think through options for reasonable compatibility process flows for Medicaid, CHIP and APTC/CSR income eligibility determinations. Karen Gibson from Minnesota Department of Human Services shared preliminary thinking on planning for implementation of reasonable compatibility standards. In addition, Anne Marie Costello from CMCS and Ben Walker from CCIIO provided reactions and feedback on the models. The webinar was introduced by Chad E. Shearer, Deputy Director of the State Health Reform Assistance Network. Alice Weiss, Co-Director of Maximizing Enrollment, moderated the panel.
Click on the download button for the slide deck used during the webinar and on the link below to hear an archived version of the discussion. An appendix (referred to, but not presented during the webinar) is included at the end of the slideshow to provide illustrative examples and outline Federal requirements.
In February, Galen Benshoof underscored the importance of agents and brokers in ensuring robust enrollment and exchange sustainability. Recognizing this, the State Network funded programs in Illinois and Minnesota, led by Wakely Consulting Group (Wakely), to enhance in-person agent and broker engagement while expanding their capability to assist anyone who walks through their doors, even if they are eligible for Medicaid or other state coverage programs. These Lead Broker Agency programs were a success, and the states are planning to continue or expand the programs next year!
A new issue brief, prepared by Kathie Mazza at Wakely, describes the concept of these pilots and outlines how other states interested in partnering with insurance brokers can implement similar initiatives for future open enrollment periods.
Student health plans have long been a source of coverage for college students who do not have other options available. In 2012, the U.S. Department of Health and Human Services redefined student health plans under the Affordable Care Act (ACA), requiring that they be treated like individual health insurance. This means that students buying these plans through their college or university now have the same protections available to them as if they bought a plan in the individual market. It also means that states and the federal government have a new role in oversight of these plans.
The State Network team mourns the recent passing of our dear friend and colleague, Andy Hyman. Andy was the father of the State Network, seeing the value in connecting states with the expertise they need to achieve the vision of coverage that drove him every day.