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.
Work and Community Engagement Requirements in Medicaid: State Implementation Requirements and Considerations
Patricia Boozang, Allison Orris, Mindy Lipson, and Deborah Bachrach, Manatt Health
In January 2018, the Centers for Medicare & Medicaid Services (CMS) released a State Medicaid Director Letter providing guidance to states as to the circumstances under which CMS would approve 1115 demonstration waivers making work/community engagement (CE) requirements a condition of Medicaid eligibility. Since then, CMS has approved state work/CE waivers in Arkansas, Indiana, Kentucky, and New Hampshire, and additional states have submitted or are poised to submit similar waivers. Manatt Health has produced a series of charts that outline the legal, policy, financial and operational tasks and issues that states will face in adding a work/CE condition to their Medicaid program.
If you are interested in only one of the charts, they are also available as individual resources:
State Health and Value Strategies also recently hosted a webinar, Explaining the Stewart v. Azar Decision and Implications for States, that provided an overview of the Stewart v. Azar decision and its potential implications for states with approved, pending or planned Medicaid waivers that include work/community engagement requirements.