On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (the ARP), a wide-ranging package of health care and economic measures responding to the coronavirus pandemic. The ARP includes a broad expansion of the Affordable Care Act’s (ACA) main health insurance subsidy, the premium tax credit (PTC), the first major expansion of the health care reform law since its passage. This piece highlights the policymaking considerations that states must account for in light of the PTC expansion and uncertainty about future federal action. A key theme that emerges is that states will benefit from approaches that give them the flexibility to adjust policies year by year as the federal landscape develops.
“Reasonable” Flexibility: Exploring Models to Help States Resolve Inconsistencies in Income for Medicaid, CHIP and Tax Credit Eligibility Webinar
Manatt Health Solutions – Deborah Bachrach and Kinda Serafi
This webinar offered detailed analysis of the standards under which states can find “reasonable compatibility” of income information provided by applicants for Medicaid, CHIP and the exchanges that is not precisely equivalent. Income data is typically neither static nor centralized, and states must be prepared to resolve discrepancies when income data is submitted by applicants or retrieved from state, federal, or other independent sources. In the case of a discrepancy, CMS eligibility rules provide guidelines to help states proceed with an eligibility determination, including some flexibility for states to find data is “reasonably compatible.” These rules, which will apply to advance premium tax credit (APTC) and cost-sharing requirement (CSR), provide states with critical flexibility to operationalize eligibility decision-making by allowing states to accept small deviations in income data from different sources.
On this July 16, 2012 webinar, Deborah Bachrach and Kinda Serafi of Manatt Health Solutions, walked participants through straw models they have created to help states think through options for reasonable compatibility process flows for Medicaid, CHIP and APTC/CSR income eligibility determinations. Karen Gibson from Minnesota Department of Human Services shared preliminary thinking on planning for implementation of reasonable compatibility standards. In addition, Anne Marie Costello from CMCS and Ben Walker from CCIIO provided reactions and feedback on the models. The webinar was introduced by Chad E. Shearer, Deputy Director of the State Health Reform Assistance Network. Alice Weiss, Co-Director of Maximizing Enrollment, moderated the panel.
Click on the download button for the slide deck used during the webinar and on the link below to hear an archived version of the discussion. An appendix (referred to, but not presented during the webinar) is included at the end of the slideshow to provide illustrative examples and outline Federal requirements.