“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Click on the download button for the slide deck used during the webinar and on the link below to hear an archived version of the discussion.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.
In April 2020, the Supreme Court ruled that the federal government must restore to health insurers approximately $12.3 billion in risk corridor payments under the Affordable Care Act (ACA). On September 30, the Center for Consumer Information and Insurance Oversight (CCIIO) proposed instructions on how to allocate these risk corridor payments under the ACA’s medical loss ratio (MLR) formula. This guidance means that policyholders will receive an estimated 2.4 percent ($298 million) of the risk corridor payout in the form of MLR rebates. This expert perspective considers ways states could potentially redirect insurers’ extra cash to benefit policyholders and the public.
Several COVID-19 vaccines could be on the market soon. State and federal officials have begun devising strategies for distributing and administering the vaccine and communicating with the public, but an equally important element will be the extent to which health care payers, including private insurers, will cover the costs for recipients. The Affordable Care Act (ACA) requires that most health insurers and employer health plans cover certain preventive services without cost-sharing, including vaccines recommended by the Advisory Committee on Immunization Practices (ACIP). However, ensuring that a COVID-19 vaccine is a free preventive service for all who need it, when they need it, is by no means guaranteed. This expert perspective discusses recent federal efforts to expand private insurance coverage of a vaccine, and provides a roadmap for states to close remaining coverage gaps that could inhibit vaccine uptake.