Wednesday, April 22, 2020

CMS answers a $600 question

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While CMS has declined to open an emergency Special Enrollment Period for all comers on, the agency is taking steps to smooth the enrollment path for the newly uninsured. Here's a roundup of some constructive moves, some of which I've noted in recent posts:
  • The $600/week extra unemployment benefit provided in the CARES Act is income that counts toward the level of subsidy eligibility in the ACA marketplace but does not count toward Medicaid and CHIP eligibility. That seems a recipe for potential enrollment confusion on a platform that enrolls people in both programs. In response to a query, however, CMS tells me, " will be updated to apply logic to ensure federal pandemic UC is counted correctly and unemployed consumers receive the accurate eligibility determination." That is, applicants should report their full UI income in the application, and will be able to discount it for the purposes of determining Medicaid eligibility. That's good news, if the "logic" holds up as intended. [Update, 4/24: just to highlight the verb tense above, CMS says that they will add this capability, which means that it's not yet operative.]

  • CMS also says that if an applicant's year-to-date income or projected full-year income exceeds the Medicaid eligibility threshold, but current monthly income is below the monthly threshold ($1468 for an individual, $3013 for a family of four), will recognize Medicaid eligibility and "transfer the consumer’s information to the state Medicaid or CHIP agency as appropriate." As I've noted in prior posts, in this situation navigators generally prefer to apply directly to state agencies for Medicaid. But whether or not it's difficult in practice to report both annual (or projected annual) and current monthly income on and get the right result if one is over and the other is under the threshold, it's possible.

  • As noted in my last post, those who apply for a Special Enrollment Period on grounds that they recently lost health coverage (usually after job loss) will not have to document the loss of coverage -- only attest to it. I am not sure whether that is true for other SEP causes, such as marriage.

  • As noted in this post, the home page on offers a pretty short, clear path toward a preview of whether an applicant is likely to be eligible for Medicaid -- that is, a couple of clicks will bring you to a screener that asks just a handful of questions including monthly family income, as opposed to the annual income requested in the main "see plans and prices" preview tool. That's important, because Medicaid eligibility is determined by current monthly income, regardless of income earned year-to-date that might put one over the annual eligibility threshold.  Unfortunately, the prompts to find out if you're Medicaid eligible on the Covid-19 information page take the user to a different tool that asks for annual income. 

  • The Covid-19 information page, prominently displayed on the home page, provides a good deal of well organized information. While the sheer quantity of information may be overwhelming to some, and highlights the unfortunate complexity of our patchwork of health coverage programs, it does cover that jagged waterfront pretty comprehensively, For example, it gets at nuances of COBRA election vs. marketplace coverage that are easy to misunderstand:
              Hell, I thought only Louise Norris understood the first point.
  • Jodi Ray, a veteran navigator and program director of Florida Covering Kids & Families, tells me that she has not encountered delays when calling into the help line, despite what must be vastly increased volume in the wake of 22 million layoffs. I helped someone update an application today and also encountered no wait time. CMS is also providing support and encouragement to navigator groups that want to conduct virtual enrollment sessions with commercial videoconferencing software. Ray said that her group has been honing this practice for two years -- necessitated, ironically, by the Trump administration's massive cuts to navigator funding (from $63 million nationally to $10 million in two years). Many navigator groups have had to resort to remote assistance, and perhaps are therefore less fazed by current conditions than they would be if adequate funding had been maintained. 

It would be far better if CMS would open an emergency SEP in, sending the simple message that anyone in the country who lacks coverage can obtain it in a pandemic, and reducing the complexity of application for those eligible (seeking a SEP adds friction, even if documents don't have to be uploaded or mailed in).  A rational administration would also invest strongly in enrollment assistance. But within the political constraints imposed by Republican extremism, the agency is taking steps to make the current architecture function. 

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