In This Week’s Update:
- New CMS Unwinding Resources
- No Surprises Act Proposed Rule
- States of Unwinding: July 7, 2023
- Facilitating Multi-Stakeholder Health Equity Collaboration
- Modernizing Early and Periodic Screening, Diagnosis and Treatment
- State updates: AK, CA, DE, FL, MD, MI, ND, NJ, OK, OR, PA, USVI & WI
Last week, CMS released new resources on their webpage for Unwinding and Returning to Regular Operations after COVID-19:
- Frequently asked questions (FAQs) related to CMS enforcement of the eligibility and renewal reporting requirements included in the Consolidated Appropriations Act, 2023 (CAA). CMS makes clear in the FAQs that it does not intend to reduce a state’s regular FMAP as long as the state makes a good-faith effort to satisfy the CAA reporting requirements and follow CMS’ guidance. The new FAQs remind states of the reporting metrics, sources, and timelines and also provide information on how to handle certain reporting challenges.
- An updated timeline chart with revised information on the month in which states initiated renewals and began processing terminations of Medicaid and CHIP coverage for individuals determined ineligible. The chart newly includes detail on the states that are prioritizing redeterminations for individuals they have identified as likely ineligible for Medicaid/CHIP.
- A slide deck with account transfer strategies. CMS encourages states with State-Based Marketplaces to consider exchanging information on procedural terminations and jointly conducting outreach—including with regard to the 90-day reconsideration period for individuals terminated from Medicaid/CHIP.
No Surprises Act Proposed Rule
Last Friday, President Biden announced the release of a proposed rule on short-term plans and new FAQs on the No Surprises Act (NSA) as well as a report on the impact of the NSA. As a reminder, State Health and Value Strategies has a resource page dedicated to the NSA. The administration also highlighted a request for information jointly issued by the Consumer Financial Protection Bureau, and the Departments of Health and Human Services and the Treasury soliciting information on the prevalence, nature, and impact of medical credit cards.
States of Unwinding: July 7, 2023
State Health and Value Strategies (SHVS) published a new post in their States of Unwinding series this week. With the exception of Oregon, all states have begun terminating enrollees no longer eligible for coverage and we are seeing unwinding of the Medicaid continuous coverage requirement operationalized across the country. Communication is a key focus across the 49 states, with states adding new features to their outreach strategies and employing prominent messengers to get the word out about renewals, like in New York. States are coordinating across agencies and partnering with stakeholders—Texas is co-hosting in-person events with food banks and West Virginia created a search tool to find community partners to support renewals. State-Based Marketplaces are ramping up their communications efforts as well and providing information and resources for employers. As more states have begun processing redeterminations they are also publishing data—Vermont launched a dashboard and Massachusetts and Pennsylvania announced the number of individuals no longer eligible for Medicaid who enrolled in coverage through the Marketplace. Lastly, Minnesota announced it is leveraging the new federal flexibilities released by CMS to minimize the loss of coverage for procedural reasons. As a reminder, SHVS has created a one-stop resource page to support states as they plan for and implement unwinding.
Facilitating Multi-Stakeholder Health Equity Collaboration
Across the U.S. healthcare system, groups of people representing varying perspectives are coming together to advance health equity by improving unjust health outcomes and addressing the structures that perpetuate them. This complex work requires collaboration in teams that include multiple types of stakeholders in public health, healthcare, social services, and community-based organizations. A report from Advancing Health Equity: Leading Care, Payment and Systems Transformation provides recommendations for multi-stakeholder teams to advance health equity. The authors, from the Center for Health Care Strategies and the University of Chicago, draw from the work of the Emergent Strategy Ideation Institute on relationship building and creativity as modes of coming together to make change.
Modernizing Early and Periodic Screening, Diagnosis and Treatment
In an opinion piece for the Milbank Quarterly, authors describe why a modern regulatory framework for the early and periodic screening, diagnosis and treatment (EPSDT) program that accounts for congressional reforms to the benefit, Medicaid’s enrollment expansion, and the transition to managed care is needed. The authors argue the EPSDT rule is out of date given Medicaid transformations to eligibility, coverage and access to care. States, enrollees and providers need a comprehensive up-to-date federal regulatory framework that includes the modernization of EPSDT coverage requirements to capture the full scope of the EPSDT benefit, modernization of outreach and case management, and reforms that clarify the process of incorporating EPSDT into detailed contracts that undergird managed care systems.
State updates: AK, CA, DE, FL, MD, MI, ND, NJ, OK, OR, PA, USVI & WI
- Alaska – CMS has granted Alaska additional time (18 months) to initiate renewals due to state-specific challenges and the need to prevent inappropriate losses of coverage.
- The California Department of Health Care Services awarded $30.5 million to 63 groups to support youth mental health through community and evidence-based practices, supporting parents, grandparents, and other family caregivers. The grant awards are part of Governor Gavin Newsom’s $4.7 billion Master Plan for Kids’ Mental Health.
- As part of Governor Gavin Newsom’s $1 billion Master Plan for tackling the fentanyl and opioid crisis, California awarded $5.7 million for opioid and stimulant use education and outreach in Two-Spirit/LGBTQ+ communities. The grants will be used to increase awareness and education about opioids and stimulants, decrease stigma related to substance-use and treatment, and integrate and strengthen treatment referral pathways for opioid use disorder and stimulant use disorder.
- Delaware – The Division of Public Health issued its biennial report, Impact of Diabetes in Delaware, 2023, which provides information on diabetes prevalence, programming, costs and progress. While the overall five-year age-adjusted mortality rate for diabetes has continued to decline, there are concerns about disparities by race. Non-Hispanic Black adults have a five-year age-adjusted mortality rate for diabetes (34.5 deaths per 100,000 population), which is twice that of non-Hispanic White adults (17.2 deaths per 100,000 population).
- Florida – Governor Ron DeSantis signed House Bill 121, which increases the income eligibility limit for subsidized CHIP coverage from 200% to 300% of the federal poverty level.
- Maryland – The U.S. Department of Health and Human Services and the Department of Treasury approved Maryland’s 1332 waiver extension request to continue implementing the Maryland State Reinsurance Program for another five years. The waiver extension allows Maryland to continue to pursue innovative strategies for providing residents with access to high-quality, affordable, health insurance while retaining the basic protections of the ACA.
- Michigan – The Michigan Department of Insurance and Financial Services released the 2024 requested rate changes from carriers in the individual and small group market. The proposed changes are currently under review.
- New Jersey – Department of Banking and Insurance Acting Commissioner Justin Zimmerman issued a bulletin providing guidance to insurance carriers concerning health coverage for transgender individuals to ensure all New Jersey residents have equal access to health coverage and healthcare. The bulletin provides guidance regarding the prohibitions against unfair discrimination in the issuance and administration of health benefit plans in the state.
- North Dakota – North Dakota Health and Human Services invites parents of children with autism spectrum disorder, providers and other interested stakeholders to provide public comments on the proposed renewal of the Medicaid autism spectrum disorder waiver. Proposed changes to the waiver, which provides services to eligible children and supports parents in their efforts to maximize their child’s development, include the addition of 195 slots and an increase in the qualifying age of children from age 15 through age 17. Other amendments include an enhanced reimbursement rate to provide case management in rural areas and provider rate increases.
- Oklahoma – The Oklahoma Health Care Authority (OHCA) submitted a waiver to CMS to transition from a fee-for-service system to the new comprehensive health delivery system, SoonerSelect. OHCA expects to launch the dental plans with the two qualified dental contracted entities, DentaQuest and LIBERTY Dental, in February 2024. The medical and children’s specialty plans for SoonerSelect are expected to launch in April 2024.
- Oregon – The Oregon Health Authority has launched a comprehensive new review that will analyze residential mental health and substance-use treatment capacity throughout the state, identify gaps and guide investments, including the allocation of approximately $164 million appointed to expand treatment in the 2023 legislative session.
- Pennsylvania – The Pennsylvania Department of Human Services announced a change in Medicaid that will allow certain enrolled medical providers to provide care outside a clinical setting to Medicaid enrollees who are experiencing homelessness—a practice known as street medicine. Street medicine uses physical and behavioral health services to address the unique needs and circumstances of people experiencing unsheltered homelessness that are delivered directly to them in their own lived environment.
- U.S. Virgin Islands – The U.S. Virgin Islands received CMS approval to extend postpartum coverage for a full year after pregnancy for individuals enrolled in Medicaid. As a reminder, SHVS published an issue brief on the American Rescue Plan Act (ARP) option to extend postpartum coverage.
- Wisconsin – The Wisconsin Department of Health Services (DHS) announced four organizations have received funding to help providers better serve communities that continue to experience barriers to accessing behavioral healthcare. Each organization has received one-time grants as part of an ongoing effort by DHS to improve health equity and access.