ACHP Offers 5 Recommendations For CHIP, Medicaid During PHE Unwinding

November 10, 2022 - The Alliance of Community Health Plans (ACHP) had five recommendations for CMS regarding how to streamline processes in Medicaid, Children’s Health Insurance Program (CHIP), and the Basic Health Program.

“The Alliance of Community Health Plans (ACHP) supports the Centers for Medicare and Medicaid Services’ (CMS) efforts to promote efficiency, streamline eligibility, reduce administrative burden and advance equity across the Medicaid, Children’s Health Insurance Program (CHIP) and Basic Health Program. We appreciate the opportunity to provide comments that align with the Agency’s efforts to create a seamless care journey for patients through enhanced access to coverage and more efficient eligibility processes,” began the letter from Ceci Connolly, president and chief executive officer of ACHP.

First, the organization offered its recommendations on how to improve outreach with consumers.

The Telephone Consumer Protection Act (TCPA) has significantly restricted the payer industry’s ability to connect with consumers, ACHP argued. The Act restricts communication to physical mail and phone communication. If state Medicaid agencies have the primary lines of contact with beneficiaries—instead of the health plans with which they are more familiar—this could cause confusion.

While conversations between CMS and the Federal Communications Commission on this issue are ongoing, ACHP suggested that CMS also contact Medicaid agencies to ensure that Medicaid programs and Medicaid managed care plans are properly seeking consent from beneficiaries to be contacted by automated texts and calls.

Second, ACHP recommended certain steps to improve transitions to coverage.

CMS should lean on Medicaid managed care plans to support beneficiaries during coverage renewal, redetermination, and transitions to marketplace coverage. Cost-allocation agreements between Medicaid programs and the Affordable Care Act exchanges could be used to fuse application and customer assistance.

Third, the payer organization explained its approach to aligning enrollment and renewals.

ACHP affirmed the need for a single, streamlined application for Modified Adjusted Gross Income (MAGI) and non-MAGI beneficiaries. The application should be renewed once annually to create a more stable and equitable system. Additionally, ACHP supported eliminating in-person MAGI interviews.

However, CMS should evaluate the impact of having transitioning from continuous eligibility to year-long eligibility.

Fourth, the payer organization had recommendations about getting rid of barriers to entry in Medicaid and CHIP.

There are a variety of barriers that restrict beneficiaries’ ability to receive Medicaid and CHIP coverage, including eligibility criteria that varies by state. CMS should move forward with its proposal to remove lockout-periods.

When a CHIP enrollee fails to pay a premium, the result is a lock-out period. ACHP argued that this practice, and the practice of allowing periods of uninsurance when a child is transitioning from group health insurance to CHIP, should be eradicated.

Finally, ACHP supported leveraging third-party data to improve the renewal and eligibility processes.

ACHP affirmed CMS guidance that encouraged states to use managed care plans’ data to supplement their own Medicaid data on beneficiaries. The payer organization suggested taking this approach one step further by incorporating third-party data to help inform Medicaid agencies about things like address changes, state income taxes, and supplemental nutrition assistance program (SNAP) utilization.

“How states, health plans and other stakeholders handle the unwinding will have a profound impact on beneficiaries, their families and the health of the nation,” Connolly concluded.

“Large rates of uninsurance among an already vulnerable demographic will result in deferred care or higher utilization of emergency services, both of which impede timely medical intervention and result in higher medical costs. We have a critical window of opportunity to coordinate and fortify processes to ensure consumers do not lose confidence in the system due to disruptions in care and coverage and become hesitant to seek care due to potentially unexpected costs.”

State Medicaid programs, Medicaid managed care plans, and healthcare leaders generally have expressed concerns about the fate of beneficiary coverage during the public health emergency unwinding. The unwinding is also expected to impact Medicaid spending. Medicaid programs are attempting to prepare beneficiaries for changes.

As of the date of this publication, experts have predicted that the public health emergency will end in 2023.