Medicaid Proposal Seeks to Smooth Enrollment, Improve Retention

State Medicaid programs would face new federal requirements aimed at making it easier to enroll in the program and harder to be kicked off due to red tape and re-enrollment hassles under a Biden administration proposal released Wednesday.

The proposed rule (RIN 0938-AU00) would streamline eligibility and enrollment processes for all Medicaid and Children’s Health Insurance Program (CHIP) populations and create new enrollment pathways to increase enrollment and improve retention of eligible individuals.

The proposal from the Centers for Medicare & Medicaid Services comes amid fears that up to 15 million Medicaid beneficiaries could lose coverage when the Covid public health emergency comes to an end.

That’s because the end of the public health emergency will also bring the end of Medicaid eligibility protections states were required to implement in in return for enhanced federal matching funds under the Families First Coronavirus Response Act.

“Medicaid and CHIP provide essential health care to millions of families across the country, and we are making it easier to enroll children and others in health insurance and to maintain coverage,” Health and Human Services Secretary Xavier Becerra said in a statement. “With these steps, we’re delivering on our promise to make high-quality health care more accessible and affordable for all Americans.”

The public health emergency is currently in place through Oct. 13. Becerra is likely to extend it for another 90 days.

Removing Barriers

The proposed rule would remove barriers and facilitate enrollment of new applicants, particularly those dually eligible for Medicare and Medicaid, according to the text in the Federal Register.

It includes “commonsense” reforms such as limiting renewals to once every 12 months; allowing applicants 30 days to respond to information requests; requiring prepopulated renewal forms; and establishing clear, consistent renewal processes across states, according to the HHS statement.

The proposal would also align enrollment and renewal requirements for most individuals in Medicaid, establish beneficiary protections related to returned mail, create requirements aimed at speeding eligibility redeterminations in Medicaid and CHIP, and make transitions between programs easier.

Other provisions would eliminate access barriers for children enrolled in CHIP by prohibiting premium lockout periods, waiting periods, and benefit limitations. They also would update recordkeeping requirements to ensure proper documentation of eligibility and enrollment.

Under the Families First Coronavirus Response Act, states can’t disenroll people during the public health emergency through routine coverage-renewal processes or because their financial circumstances have changed.

The health department also is looking for input from the states concerning reasonable implementation timelines for the proposal in light of the enormous task facing the states of resuming routine eligibility and re-enrollment processes once the public health emergency ends, the proposed rule said.

The proposed rule comes about about seven months after the CMS asked Medicaid stakeholders to suggest improvements in enrollment and eligibility-redetermination processes and in program requirements related to access to care.

President Joe Biden also issued an executive order in April on Medicaid and the Affordable Care Act directing the HHS and other agencies to identify ways to “make it easier for all consumers to enroll in and retain coverage, understand their coverage options, and select appropriate coverage.”