September 27 Update

In This Week’s Update:

  • New SHVS Resources for States
  • State Updates: CT, FL, IL, MA, MI, MN, MT, NH, NJ & UT
  • Medicaid Churn Toolkit
  • Racism and the COVID-19 Vaccine
  • Minimizing Losses in Postpartum Coverage Post PHE


New SHVS Resources for States

State Health and Value Strategies published two new expert perspectives on the latest federal rules and their implications for state insurance regulators and state-based marketplace officials. The first, The No Surprises Act Proposed Rule on Air Ambulances and Enforcement: Implications for States, highlights state considerations on the latest proposed rule to implement components of the No Surprises Act (NSA). This proposed rule details the data on air ambulance services that must be reported to HHS and the Department of Transportation and discusses the departments’ proposed approach to enforcement of the NSA. Beyond the NSA provisions, the proposed rule also provides guidance on new federal requirements that individual market and short-term plan insurers disclose broker compensation to current and potential enrollees as well as to HHS.


The second expert perspective, Final Round of Rulemaking for 2022 Affordable Care Act Marketplaces: Implications for States, summarizes key provisions of the final 2022 Notice of Benefit and Payment Parameters (NBPP) and its implications for states. The 2022 NBPP focuses on building on the ACA by expanding enrollment opportunities, boosting consumer assistance and outreach and enhancing plan oversight. The rule also reverses several policies of the prior administration, including the option for states to pursue a “Direct Enrollment” marketplace and seek Section 1332 waivers under more relaxed standards for coverage access and comprehensiveness. The rule also rescinds the prior administration’s requirement that plan enrollees receive a separate bill for the cost of covering abortion services. 

State Updates 

  • Connecticut – Governor Ned Lamont announced that his administration has received federal approval to combine Medicaid health coverage with a range of housing services for Connecticut residents struggling with homelessness and chronic health issues. The Connecticut Housing Engagement and Support Services (CHESS) will pool the efforts of state agencies and nonprofit partners to bring coordinated health care and housing support to individuals with mental health, substance use, and other serious health conditions.
  • Florida – The Agency for Health Care Administration is requesting to amend its Section 1115(a) demonstration, “Managed Medical Assistance” including modifying the Low-Income Pool to include non-profit licensed behavioral health providers and extending the postpartum coverage period from 60-days to 12-months. The federal public comment period is open through October 19, 2021.
  • Illinois – CMS approved the state’s postpartum CHIP Health Services Initiative amendment, which extends postpartum coverage from 60 days to 12 months. 
  • Massachusetts – The state’s Health Policy Commission (HPC) released the 2021 Annual Health Care Cost Trends Report. The report presents new research to enhance the collective understanding of health care spending trends and cost drivers in the Commonwealth and evaluates the state’s progress in meeting several cost containment, care delivery, and payment system goals set by the Commonwealth and the HPC.
  • Michigan – CMS approved the state’s request to extend its section 1115(a) demonstration “Flint Michigan Section 1115 Demonstration” for another five years. The demonstration expands Medicaid eligibility up to 400 percent of poverty for pregnant women and children suffering from the long-term health effects of lead exposure in Flint. The waiver, which also applies to the Children’s Health Insurance Program, waives cost-sharing and premiums. An estimated 46,000 children and pregnant women have received coverage because of the expanded eligibility.
  • Minnesota – The Department of Human Services announced that approximately 100,000 Minnesotans will save up to $52 a month on their MinnesotaCare premiums through the end of 2022. The premium relief stems from the American Rescue Plan Act. Until January 2023, people with incomes under 160 percent of the federal poverty level won’t have to pay premiums for MinnesotaCare. People whose incomes fall between 160 and 200 percent of the federal poverty level will pay reduced premiums.
  • Montana – The state submitted an application to CMS to amend its section 1115 demonstration, “Montana Health and Economic Livelihood Partnership (HELP),” to remove expenditure authority for 12-month continuous eligibility from its demonstration and extension application.
  • New Hampshire – The state is seeking approval of an amendment to its 1115(a) demonstration waiver to use federal funds for Medicaid enrollees ages 21 to 64 who are receiving short-term mental health treatment in an Institution for Mental Disease. The amendment would apply to both Medicaid fee-for-service and managed care members.
  • New Jersey – The New Jersey Department of Banking and Insurance announced that consumers shopping for 2022 health coverage this fall at Get Covered New Jersey, the state’s official health insurance marketplace, will continue to benefit from financial help available from the federal American Rescue Plan and the state of New Jersey. Consumers will also have more choice, with the entry into the market of a new health insurance company, Ambetter from WellCare of New Jersey, increasing the number of carriers offering plans on the marketplace. 
  • Utah – The state submitted an application to CMS to extend its section 1115 demonstration, entitled “Primary Care Network,” which provides health care coverage for various low-income populations, for five years. The request includes a number of changes to the demonstration, such as extending the period of intensive stabilization services from the first eight weeks to the entire period of the intensive program, and combining the four populations eligible to receive coverage under Utah’s premium Partnership for Health Insurance (UPP) into one demonstration population.


Medicaid Churn Toolkit

With support from the Robert Wood Johnson Foundation, Benefits Data Trust (BDT) developed a “Medicaid Churn Toolkit” to guide Medicaid agencies and their partners in the design and implementation of efforts to reduce churn as they plan for the resumption of normal eligibility and enrollment actions (including renewals, redeterminations, and post-enrollment verifications) and beyond. Federal response to the COVID-19 pandemic has temporarily eliminated Medicaid churn since under the Families First Coronavirus Response Act (FFCRA) states are prevented from disenrolling Medicaid beneficiaries. The protection the FFCRA affords, however, disappears once the federal public health emergency declaration ends, putting a significant number of Medicaid beneficiaries at risk for disenrollment and resulting in the resumption of churn within the Medicaid population. Investments in efforts that reduce Medicaid churn can result in more efficient Medicaid agencies and administrative cost savings, reducing staff workload and allowing staff and resources to be dedicated to other priorities. Interested individuals can tune into a webinar hosted by BDT on the toolkit on September 30.  SHVS is also planning programming to support states as they navigate the unwinding of the PHE and seek to mitigate coverage losses, so stay tuned. And in case you missed it, last week we published an expert perspective exploring the potential health equity implications of ending Medicaid continuous coverage following the end of the PHE.


Want People to Take the COVID-19 Vaccine? Confront Racism in Health Care

Even as the Delta variant rages through the U.S., many Americans have not received a COVID-19 vaccine. The reasons are complex, but for Black and Latino(a) communities, a long history of poor access to health care has been a tall barrier. On the first episode of the new season of the Commonwealth Fund’s The Dose podcast, host Shanoor Seervai talks to Rhea Boyd, a pediatrician and public health advocate, about what it takes to dismantle the historic racism that has long prevented people of color from getting the health care they need. Black and Latino(a) health care professionals like Dr. Boyd are answering questions about the COVID-19 vaccine online and in person. If we make it a national priority, she says, we can ensure Black and Latino(a)  people get credible information about the vaccines and easy access to them.


Opportunities for States to Minimize Postpartum Coverage Loss When the Public Health Emergency Ends

With support from the Robert Wood Johnson Foundation, a new Health Affairs blog post describes how Medicaid plays a critical role in insuring pregnant people. Pregnancy-related Medicaid eligibility stops just 60 days after the end of pregnancy, which resulted in more than 20 percent of those with Medicaid-covered prenatal care becoming uninsured postpartum in 2015–18. However, the postpartum coverage landscape temporarily changed in 2020 when the Families First Coronavirus Response Act (FFCRA) began to provide states with enhanced federal matching funds if their Medicaid programs do not reduce eligibility standards and maintain continuous enrollment for most people enrolled during the public health emergency. The blog post describes how Medicaid’s role for postpartum coverage changed during the pandemic under the continuous enrollment requirement and highlights recent research findings identifying actions Medicaid agencies and state legislatures can take now to facilitate continuous coverage for postpartum people once the public health emergency ends.