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Medicaid Redetermination Topic of Plan Meeting

A primary focus of the February Medicaid Managed Care Policy and Planning Meeting was the unwind of the Medicaid continuous coverage requirement that has been in place since March 2020 due to the Families First Coronavirus Response Act. Even without the announcement that the federal Public Health Emergency (PHE) is ending on May 11th, the Consolidated Appropriations Act signed at the end of December 2022 decoupled continuous coverage provisions from the sunset of the PHE and set requirements for states to resume eligibility redeterminations. The process will entail coverage renewal as well as the transition to other coverage for beneficiaries who may no longer be eligible for Medicaid.

New York State will restart the process of Medicaid renewals on April 1, 2023, and beneficiaries will need to take the required action to maintain eligibility. The Department of Health (DOH) has developed materials to make Medicaid beneficiaries aware of this upcoming requirement and to urge them to update contact information if needed. At the meeting, DOH shared the unwind schedule and outlined the steps that plans should be taking to assist their members through the process. The presentation built on an initial discussion in the January plan meeting and follows a direct distribution to Managed Long Term Care (MLTC) plans, including Programs of All-Inclusive Care for the Elderly (PACE), of the January guidance. That distribution reminded plans to submit any new or revised member-facing materials pertaining to annual Medicaid eligibility renewals to their plan manager by Feb. 23, 2023.

The renewal process will roll out one renewal month at a time and will take up to 14 months to complete. Beneficiary renewal dates will align with the pre-established renewal month prior to the start of the continuous coverage requirement. Those members who became eligible during the PHE will recertify in the month in which they enrolled. The first beneficiaries to be impacted will be those with renewal dates in June. The New York City Human Resources Administration (HRA) will start sending notices at the end of March to beneficiaries with June renewal dates, while upstate social services districts will begin mailings in April. NY State of Health mailings will start in May. DOH expects to renew approximately 1/12th of the caseload each month.

DOH stressed that plans should help educate members regarding the redetermination process and assist their members by:

  • Checking member recertification dates on DOH-issued enrollment data;
  • Enlisting their provider networks to help spread the word;
  • Obtaining approval from DOH for updated member material (submit by Feb. 23rd);
  • Initiating member renewal reminder communication aligning with renewal mailing schedule;
  • Ensuring that care managers have access to recertification dates and have information on the unwind to discuss with members in care management;
  • Highlighting to members that the Medicaid renewal process is restarting and member action is required to maintain Medicaid coverage, including updating contact information and responding to renewal notices;
  • Updating managed care organization (MCO) web pages, portals, voice response systems, and staff and provider training modules; and
  • Utilizing the Communications Toolkit to develop content to update websites and social media channels where applicable.

DOH expressed hope that expanded Medicaid eligibility rules and potential flexibility from the Centers for Medicare and Medicaid Services (CMS) would help minimize disruption for dual-eligible individuals in mainstream products. DOH expects to convene dedicated meetings to address other unwind dynamics and invites plans to send in questions. While additional resumption of involuntary disenrollment will follow, and eventually the disenrollment of long-stay nursing home residents in partially capitated MLTC plans will shift from a batch to a plan-initiated process, that is down the road, and DOH is currently focused primarily on eligibility redeterminations. The United Hospital Fund will hold a roundtable discussion with government officials, health plan representatives, provider groups, consumer advocates, and funders on the unwind on Feb. 16th, which will feature presentations by key New York State officials. While space for in-person attendance is limited, stakeholders are invited to attend virtually via Zoom, with registration available here.

The Policy Update slides from the Policy and Planning Meeting are available here, while the slides presented by the Medicaid Inspector General on newly adopted amendments to regulations on Compliance Programs (18 NYCRR Part 521) are here.

LeadingAge NY Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841