CMS posted an FAQ that says issuers that reduce or eliminate agent and broker commissions for enrollments through special enrollment periods (SEPs) are violating the guaranteed issue provisions of the ACA and doing so would constitute a discriminatory marketing practice.
The state’s Office of Superintendent of Insurance recently notified its carriers that a broker compensation structure that pays differing commissions for open and special enrollments violates state nondiscrimination provisions and constitutes an unfair or deceptive practice under the state’s unfair trade practices statute.
New state reporting templates and guidance released by the Centers for Medicare & Medicaid Services (CMS) on March 22, 2022, build upon a State Health Official letter released on March 3. The resources specify both the data and the metrics that states will be required to submit to monitor enrollment and renewal efforts as they resume routine Medicaid and CHIP operations following the end of the COVID-19 PHE. This expert perspective summarizes the new reporting requirements and presents a set of considerations for states as they begin implementing new unwinding policies, procedures, and reporting.
The Centers for Medicare & Medicaid Services (CMS) released additional templates and resources to support state reporting around enrollment and renewal efforts when the federal public health emergency (PHE) concludes. The resources include 1) a “Renewal Distribution Report” form in which states will be required to summarize their renewal plans, with a focus on mitigating inappropriate coverage loss during the unwinding period and 2) an “Unwinding Eligibility and Enrollment Data Reporting” Excel workbook and specifications document, which aims to support states in reporting on certain metrics around timely application processing, renewal initiation and completion, reason for termination, and fair hearings. CMS also previewed that states will eventually report on these metrics on a monthly basis.
When the Families First Coronavirus Response Act Medicaid “continuous coverage” requirement is discontinued states will restart eligibility redeterminations, and millions of Medicaid enrollees will be at risk of losing their coverage. A lack of publicly available data on Medicaid enrollment, renewal, and disenrollment makes it difficult to understand exactly who is losing Medicaid coverage and for what reasons. Publishing timely data in an easy-to-digest, visually appealing way would help improve the transparency, accountability, and equity of the Medicaid program. This expert perspective lays out a set of priority measures that states can incorporate over time into a data dashboard to track Medicaid enrollment following the end of the continuous coverage requirement. For a detailed discussion of the current status of Medicaid enrollment and retention data collection and best practices when developing a data dashboard to display this type of information, SHVS has published a companion issue brief.
The Families First Coronavirus Response Act (FFCRA) Medicaid “continuous coverage” requirement has allowed people to retain Medicaid coverage and get needed care during the COVID-19 pandemic. When continuous enrollment is discontinued, states will restart eligibility redeterminations, and millions of Medicaid enrollees will be at risk of losing their coverage. The current lack of publicly available and timely Medicaid enrollment, renewal, and disenrollment data will make it difficult to understand exactly who is losing coverage and for what reasons. One effective way to monitor this type of information is through the use of Medicaid enrollment and retention dashboards. This issue brief examines the current status of data collection to assess Medicaid enrollment and retention, summarizes potential forthcoming reporting requirements, and describes some of the best practices states should consider when developing a data dashboard to display this type of information. The issue brief lays out a phased set of priority measures and provides a model enrollment and retention dashboard template.
On November 24, CMS released a “punch list” of strategies states and the US territories can adopt to maintain coverage of eligible individuals as they return to normal operations after the end of the public health emergency. The strategies are organized around seven topics areas: (1) strengthening renewal processes; (2) updating mailing addresses; (3) improving consumer outreach, communication, and assistance; (4) promoting seamless coverage transitions; (5) improving coverage retention; (6) addressing strains on the eligibility and enrollment workforce; and (7) enhancing oversight of eligibility and enrollment operations. In this resource, CMS also flagged strategies they expect to have the biggest impact on mitigating coverage losses.
Updated Guidance Related to Planning for the Resumption of Normal State Medicaid, CHIP, and BHP Operations Upon Conclusion of the COVID-19 Public Health Emergency
Guidance on planning for the Resumption of Normal State Medicaid, CHIP, and BHP Operations Upon Conclusion of the COVID-19 Public Health Emergency