As a condition of receiving enhanced federal funds during the
COVID-19 public health emergency (PHE), states were required to take certain
steps to ensure continuous Medicaid and CHIP coverage for most enrollees,
leading to a nearly 18% jump in Medicaid enrollment. But with the latest PHE extension
set to expire on Jan. 16, states will no longer receive such funds and will
therefore no longer be required to maintain continuous coverage, although CMS
has given them 12 months after the month in which the PHE ends to complete eligibility redeterminations. As a result,
supporting states’ reverification efforts and ensuring that eligible members
stay on the rolls or have a viable landing spot will be critical to Medicaid
managed care organizations this year, industry experts tell AIS Health.
Redetermination can cause ‘chaos and crisis’
- “The biggest challenge for Medicaid MCOs in 2022 will
be churn,” asserts Jerry Vitti, founder and CEO of Healthcare Financial,
Inc., a firm that connects low-income, elderly, and disabled populations
with Medicaid and other public benefit programs.
- “With redeterminations looming, we will see a ‘chaos
and crisis’ situation when enrollees are cut off from crucial access to
care. There are administrative factors that can trigger the disenrollment
of truly eligible enrollees, such as improperly recorded address changes
and data problems and mismatches in a state’s electronic eligibility
determination system.”
- The Association for Community Affiliated Plans (ACAP),
which counts 78 safety-net plans among its members, has been actively promoting continuous coverage for all
people covered by Medicaid after the PHE ends. The association supports a
provision in the Build Back Better Act that would establish 12-month
continuous eligibility for children covered by Medicaid and CHIP.
- Previous research suggests that more than 1.5 million people in 2018
lost Medicaid and CHIP coverage, largely as a result of states’ complex
redetermination processes.
Plans, states should invest more in SDOH
- Meanwhile, plans are likely to make significant
investments in identifying and addressing social determinants of health
(SDOH) such as food insecurity as well as tackling behavioral health and
substance use disorder, Vitti predicts, advising that states help fund
improved case management for payers.
- Given that states have additional cash from
pandemic-relief legislation, Vitti is optimistic that they will spend
those extra funds on “broadening the mission of Medicaid MCOs” in
addressing SDOH.
- Vitti says an example worth keeping an eye on is the
California Advancing and Innovating Medi-Cal (CalAIM), a multiyear
initiative that began on Jan. 1 to bring about delivery system, program
and payment reform in California’s Medicaid program.
- Another item to watch will be “how strongly CMS will
look to add any type of health equity or SDOH requirements as part of MCO
contracts,” weighs in Thomas L. Johnson, executive director of the
Population Health Alliance.
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