There has been a lot of activity from the Department of Health and Human Services (HHS) over the past few weeks, including a new proposed rule from the Centers for Medicare and Medicaid Services (CMS) on Medicaid eligibility and new guidance from the Center for Consumer Information and Insurance Oversight (CCIIO) on state partnership exchanges.
On January 14, CMS released a new Medicaid eligibility proposed rule and fact sheet that deals with several important aspects of how applicants will be enrolled in coverage beginning later this year, and what types of coverage they will receive. Specific areas covered include:
- Coordination of notices and appeals between Medicaid, CHIP, and the exchange.
- Certification of application counselors.
- The Medicaid benefits package for the newly eligible adult population.
- Changes to cost-sharing in Medicaid, including allowing states to increase cost-sharing for non-preferred drugs and non-emergency use of the emergency department and possible reduction of the maximum allowable cost-sharing for inpatient hospitals stays for those below 100 percent of the federal poverty level.
- State options for determining Medicaid eligibility during the initial exchange open enrollment period at the end of 2013.
- Allowing states to continue to impose waiting periods of up to 90 days for CHIP coverage.
Comments are due on February 13, 2013.
In addition, on Thursday, January 3, CCIIO released new guidance on state partnership exchanges that provides further information on the role of a state and the role of the federal government in both a plan management and a consumer assistance partnership exchange. Topics covered in the guidance include:
Plan Management Partnership Exchanges
- The scope of state responsibilities, including recommending plans for qualified health plan (QHP) certification, recertification, and decertification to HHS.
- The scope of HHS responsibilities, including receiving, approving (as appropriate), implementing, and overseeing state QHP certification and recertification recommendations.
- Information regarding requirements for a state-specific memorandum of understanding (MOU) with HHS, which will include a description of how each state approved for a plan management partnership will review health plans for exchange certification.
- A recommended timeline for state plan management partnership activities, including a requirement that partner states complete their part of the QHP certification process and provide required plan data and certification recommendations to HHS by July 31, 2013.
Consumer Assistance Partnership Exchanges
- The scope of state responsibilities, including managing navigators, and developing, implementing and managing an in-person assistance (IPA) program.
- The scope of HHS responsibilities, including funding and awarding grants to navigator entities, establishing conflict of interest, cultural and linguistic competency, and training standards for navigators, providing training for navigators and in-person assisters, and operating a single State Partnership Exchange call center and website.
- State use of 1311 (exchange establishment) funding for navigator and in-person assistance programs and state options to permit agents and brokers to enroll consumers in qualified health plans through the exchange, develop additional training for navigators and in-person assisters, and conduct exchange outreach and education activities.
- Information on the development of outreach and education plans. States must submit an outline of plans for these activities to HHS by March 29, 2013.