UPDATES
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EC comment submission to CMS: In January 2024, the Enrollment Coalition submitted a comment to CMS with feedback regarding the "CMS Enforcement of State Compliance With Reporting and Federal Medicaid Renewal Requirements Under Section 1902(tt) of the Social Security Act" Interim Final Rule. In this letter, the Coalition outlined its support for CMS' implementation of new authorities to ensure greater transparency during the redetermination period and further protect eligible beneficiaries from being disenrolled for procedural reasons. CMS’ new authorities are critical to preventing significant coverage losses and will aid in data collection for the future improvement of State eligibility and enrollment systems.
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The Coalition's letter may be found here.
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EC comment submission to CMS: In January 2024, the Enrollment Coalition submitted a comment to CMS with feedback regarding the HHS Notice of Benefit and Payment Parameters for 2025 Proposed Rule. In this letter, the Coalition outlined its general support to strengthen State-Based Marketplace (SBM) operations and otherwise improve individuals’ continuity of coverage. The Enrollment Coalition specifically commented on CMS’ proposals to strengthen SBM operations, create more robust Special Enrollment Periods, re-enroll individuals with catastrophic coverage plans, and provide consumer's with a notice of APTC risk due to failure to reconcile.
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The Coalition's letter may be found here.
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EC letter to NAIC and NAMD: In July 2023, the Enrollment Coalition sent a letter to the National Association of Insurance Commissioners (NAIC) and the National Association of Medicaid Directors (NAMD) that encouraged their members to adopt automatic enrollment processes for people moving from Medicaid to Marketplace plans. Specifically, the letter encouraged State Insurance Commissioners and State Medicaid Directors to (1) randomize plan selection among the zero-net-premium plans that provide the highest available actuarial value; (2) prioritize maintaining existing provider-individual relationships; and (3) prioritize the equitable distribution among QHPs for consumers that have not made an active coverage selection.
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The Coalition's letter may be found here.
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EC letter to CMS: In July 2023, the Enrollment Coalition sent a letter to CMS to suggest additional guidance on two redetermination flexibilities released by CMS, Strategy 12 and Strategy 19, that members believe have especially high potential to further prevent procedural terminations for beneficiaries. The Coalition encouraged CMS to promote the New York State facilitated enrollment model as a best practice that can be implemented by other states to leverage MCOs more effectively in the Medicaid renewal process. The Coalition also highlighted that CMS' encouragement for covered providers to contact the appropriate MCO after determining presumptive eligibility for a Medicaid beneficiary could facilitate the re-enrollment process and communications from the MCO to the beneficiary and increase the likelihood of re-enrollment.
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The Coalition's letter may be found here.
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EC comment submission to CMS: In July 2023, the Enrollment Coalition submitted a comment to CMS with feedback regarding the Ensuring Access to Medicaid Services Proposed Rule. In this letter, the Coalition outlined its general support for a number of requirements that CMS would institute for state Medicaid program websites to improve their navigability for beneficiaries. The Enrollment Coalition also specifically commented on CMS’ proposal to require state Medicaid advisory committees (MAC) to have at least 25 percent of their membership come from beneficiary advisory groups (BAG), which provide bi-directional feedback between stakeholders and the state on the administration of the Medicaid program.
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EC comment submission to CMS: In January 2023, the Enrollment Coalition submitted a comment to CMS with feedback regarding the HHS Notice of Benefit and Payment Parameters for 2024 Proposed Rule. In this letter, the Coalition outlined its general support for remove existing barriers to coverage and facilitate transitions of coverage. The Enrollment Coalition specifically commented on CMS’ proposals related to Navigator assistance, transitions of coverage, and Special Enrollment Periods. The Enrollment Coalition also responded to the request for information on autoenrollment policies by providing principles for enrollee protections, state flexibility, and fair treatment of health plans.
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The Coalition's letter may be found here.
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EC letter to FCC: In October 2022, the Enrollment Coalition sent the FCC chairwoman Jessica Rosenworcel a letter requesting a meeting to discuss the request from HHS that FCC provide clarification that certain automated calls and text messages or prerecorded voice calls relating to enrollment in state Medicaid and other governmental health coverage programs are permissible under the Telephone Consumer Protection Act (TCPA). The Enrollment Coalition urged the FCC to provide timely clarification that these activities are permissible under the TCPA in order to prevent unnecessary coverage losses.
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The letter may be found here.
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EC comment submission to CMS: In October 2022, the Enrollment Coalition submitted a comment to CMS with feedback regarding the Medicaid, CHIP, and Basic Health Program Eligibility and Enrollment proposed rule. The Coalition emphasized the following points; (1) the importance of using multiple modalities for communication including text messaging, (2) utilizing third party data to evaluate eligibility and facilitate renewals, and (3) the need to leverage MCOs to help assist beneficiaries in redeterminations and renewals.
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EC comment submission to FCC: In May 2022, the Enrollment Coalition submitted a comment to the Federal Communications Commission (FCC) in support of HHS’ request to clarify that the Telephone Consumer Protection Act (TCPA) would not apply to certain eligibility and enrollment communications. The Coalition believes that increasing communication options is a vital tool for improving access to health coverage for which individuals are already eligible.
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EC response to RFI re: access to coverage: In April 2022, the Enrollment Coalition responded to CMS’ request for information (RFI) about access to coverage and care under Medicaid and the Children’s Health Insurance Program. The Coalition’s RFI response suggested improvements to eligibility determination systems for state-operated exchanges, improving outreach to enrollees by using clearer language, removing barriers to enable texting or other preferred forms of communication, metrics to monitor for enrollment success, and methods to improve administrative efficiency. Read the full letter here.
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EC Comment re: NBPP Proposed Rule: In January 2022, The Enrollment Coalition provided comments to CMS on the HHS Notice of Benefit and Payment Parameters for 2023 Proposed Rule. The Coalition’s response commented on the shared goals of streamlining the enrollment process, removing existing barriers, and improving the consumer enrollment experience. The Coalition supported CMS’s proposal to use additional data sources, including the National Directory of New Hires, to inform eligibility determinations and ease administrative burdens. The Enrollment Coalition also voiced support for the role of agents and brokers in getting people enrolled in coverage, and shared appreciation for CMS’s efforts to help consumers make informed decisions on their coverage options. Read the full letter here.
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EC develops three examples of EC journeys: In September 2021, the Enrollment Coalition developed three example enrollment journeys depicting the enrollment process for individuals signing up for Medicaid or Marketplace plans. These enrollment journeys show how the enrollment process can be complicated and points at which it could be difficult for an individual to compete the process to enroll in health coverage.
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EC letter to CMS requesting agency provide updated guidance: In August 2021, the Enrollment Coalition sent a letter to CMS requesting the agency provide State Health Officials (Medicaid Directors) updated guidance on planning for the resumption of normal State Medicaid, CHIP, and BHP operations upon the conclusion of the COVID-19 public health emergency. The letter specifically requests updated guidance on planning for and resuming regular eligibility and enrollment operations, expectations or opportunities for assisting individuals who no longer qualify for Medicaid/CHIP to enroll in insurance in the private market, promoting efficiency and integrity in ensuring the right source of coverage at the right time for individuals, and enrollment strategies or flexibilities states adopted during the PHE that may be permanently adopted following the expiration of the PHE, including resources to assist with planning and implementation. Read the full letter here.
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EC submits comments to OMBs RFI: In July 2021, the Enrollment Coalition submitted comments in response to OMB’s Request for Information: “Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government.” The Enrollment Coalition’s response focused on reducing barriers and burdens to enrolling in existing health insurance programs in order to promote health equity and reduce racial disparities. Read the full comments from the Enrollment Coalition here.
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EC letter to Secretary Becerra: In June 2021, the Enrollment Coalition sent a letter to Secretary Becerra to request HHS re-issue a previous exception to the cost allocation requirements set forth in the OMB Circular A-87, to allow Federally-funded Health and Human Services programs to benefit from investments in the design and development of State eligibility-determination systems for State-operated Exchanges, Medicaid, and CHIP. Read the full letter here.
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EC letters to Congress: In March 2021, the Enrollment Coalition sent letters to Members of Congress to introduce the coalition, its work, and offer to be a resource as Congress works on relevant policies. Read the full letter here.
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EC letter to Biden-Harris Team: In January 2021, the Enrollment Coalition sent a letter to the Biden-Harris Team with recommended near-term actions to support health coverage enrollment for eligible individuals. The letter included six recommendations:
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Issue an Executive Order on Health Care Enrollment.
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Establish a Special Enrollment Period.
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Utilize Exchange User Fees to Support Navigators and Other Enrollment Activities.
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Support Targeted Enrollment Campaigns in Communities of Color.
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Establish “Bridges” to Help People Who Lose Their Jobs Find Alternative Sources of Coverage.
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Address Timing of Grace Period and Outstanding Premiums.
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Read the full letter here.