With the Patient Protection and Affordable Care Act’s (ACA’s) ninth open enrollment period (OEP) set to launch in less than a month, the ACA Marketplaces are seeing record enrollment numbers with more generous subsidies, new carrier competition, and a relatively stable rating environment. At the same time, there is uncertainty with the trajectory of the COVID-19 pandemic and medical costs trending upward as the economy recovers, albeit at an uneven pace. These trends have made for a challenging rate review process in the 47 states plus the District of Columbia (D.C.) that conduct their own ACA rate reviews of carrier-proposed rates using federal review standards. State announcements of 2022 rates have trickled out at a slower pace than in prior years, and it is likely that many states will not publish their approved rates until the beginning of open enrollment. As always, state rate results vary widely and, even within states, there often are substantial variations among carriers and across different regions in geographically diverse states. With these caveats, this expert perspective highlights some observations about the factors that are impacting rate changes this year and the kind of variations that exist among states.
Analysis of Federal Statutory and Regulatory Eligibility and Enrollment
Manatt Health Solutions
The following chart, prepared by Manatt Health Solutions, with support from the State Network, summarizes the federal statutory and regulatory eligibility and enrollment requirements for Medicaid using the Modified Adjusted Gross Income (MAGI) methodology, CHIP, Non-MAGI Medicaid, Temporary Assistance for Needy Families (TANF), Child Care Assistance Program and Supplemental Nutrition Assistance Program (SNAP). This analysis highlights points of alignment and meaningful differences across all six programs. A summary document that reflects further detailed analysis can be found here.
Many states are considering the legal, technical, and operational implications of integrating their eligibility determinations for Medicaid and CHIP under MAGI with eligibility determinations for other means tested programs such as TANF, child care, SNAP and Non-MAGI Medicaid. Despite the many shared eligibility requirements across the six programs there are a number of requirements that are distinct to one or several of the programs that create a barrier to full alignment. Ultimately, development of a multi-benefit application offers states the opportunity to evaluate, streamline and simplify eligibility and enrollment rules for its public benefit programs.