Medicaid Redeterminations​

• Helping those eligible to maintain some form of coverage as Medicaid redeterminations resume is a priority for the Enrollment Coalition. The CMS has adopted a number of policies and flexibilities supported by the Coalition, including:

  • permitting managed care plans to aid enrollees in completion and submission of Medicaid renewal forms.

  • allowing the state Medicaid agency to determine presumptive eligibility, and

  • allowing additional entities to be able to determine presumptive eligibility for certain vulnerable populations.

• According to the Medicaid and CHIP Payment and Access Commission (MACPAC), only about 3 percent of all adult and child beneficiaries who were disenrolled from Medicaid and CHIP enrolled in Exchange coverage within a year after disenrolling. Most individuals who moved from Medicaid to the Marketplace had a gap in coverage and these gaps were longer for racial and ethnic minorities. The Coalition supports policies to ease transitions of coverage to help people enroll in the coverage for which they are eligible.

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Autoenrollment

• Millions of Americans are eligible for subsidized health insurance but are not enrolled in coverage. People of color are disproportionately likely to fall into the enrollment gap, as are working-class families. The Enrollment Coalition believes that it must be a top policy priority to ensure that those who are eligible are enrolled and retained in coverage. Autoenrollment policies can bridge the persistent enrollment gap and promote equity and health for those needing care. The Coalition has developed a framework for an autoenrollment policy that supports the enrollment of eligible individuals and families, protects patient choice, and preserves program integrity. The Coalition’s framework for an autoenrollment policy can be found: here

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Telephone Consumer Protection Act

• We strongly believe that protecting consumers is critically important. Policymakers should consider how to protect consumers while modernizing policy to accommodate consumer preferences and needs for information in the digital era. After proactive advocacy from HHS, the Enrollment Coalition, and other stakeholders, the FCC issued a declaratory ruling on how phone calls and text messages can be used to raise awareness of the eligibility and enrollment requirements for Medicaid beneficiaries. The Enrollment Coalition supports the FCC’s declaratory ruling and encourages Congress and the Biden Administration to continue considering how best to continue protecting consumers from unwanted robocalls and scams, while ensuring important communications are not inadvertently prevented. By conducting this important work, Congress and the Administration will ensure equitable outcomes for beneficiaries regardless of their limitations in access to communication mediums.

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Health Equity

• Section 4302 of the Affordable Care Act added Section 3101 to the Public Health Service Act (PHSA) requiring “any federally conducted or supported health care or public health program” to collect and report data, to the extent practicable, on race, ethnicity, sex, primary language, and disability status. Section 3101 also instructs the Secretary of Health and Human Services to “analyze data collected under paragraph (a) to detect and monitor trends in health disparities.” However, this section also included subsection (h) which prevents the implementation of this provision unless Congress specifically appropriates funding for these activities. To date, Congress has not provided funding specifically for carrying out this provision and this provision has not been fully implemented. The Enrollment Coalition is seeking a legislative change to strike subsection (h) of Section 3101 of the PHSA to allow HHS to collect and analyze important data related to health disparities within health coverage programs.

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Exception to OMB Circular A-87

• We believe states and consumers would benefit from a time-limited exception to OMB’s cost allocation requirements, which would allow states to leverage investments in eligibility and enrollment systems across multiple programs. In 2011, HHS and USDA issued an exception (to OMB Circular A-87) to encourage states to leverage the technology investments for streamlined enrollment in the ACA to modernize eligibility and enrollment for other safety-net benefits. Reviving this time-limited tool would be an important step enabling the creation of data connections between state agencies, especially as they are preparing for Medicaid redeterminations after the end of the PHE. States could use a cost exception to:     

  • connect health programs to external sources of data that can verify eligibility without requiring individuals and families to complete repetitive paperwork;  

  • leverage federal technology investments that will be made to improve access to unemployment to also improve access to health and social services; and 

  • simultaneously enroll eligible individuals into health coverage as well as other programs for which they are eligible by improving data matching, establishing more robust referral mechanisms, streamlining business processes, and notifying program participants of their potential eligibility for other benefits.

• By promoting more integration of IT systems across health and social services programs through the A-87 exception, HHS can encourage states to reimagine how to deliver government services for the 21st century.