State Outlines Plans for Medicaid Beneficiary Recertification; HHS Discusses PHE Unwind
After almost three years of Medicaid continuous coverage requirements, the December 2022 Consolidated Appropriations Act requires states to restart Medicaid eligibility redeterminations beginning April 1, 2023. States have 14 months to complete the process. New York State faces a major challenge in ensuring that the 9 million individuals in public health insurance programs do not lose their access to health insurance coverage during the process. That challenge was the topic of a roundtable discussion convened by the United Hospital Fund (UHF) on Feb. 16th that featured State Medicaid Director Amir Bassiri and other key Department of Health (DOH) leaders, who outlined the State’s plans to meet it.
Since the start of 2020, the number of people enrolled in public health programs in New York State has grown by 2 million. Over 9 million people, nearly half of the state’s population, are enrolled in Medicaid, Child Health Plus, and the Essential Plan. Although based on assumptions that have shifted slightly, modeling by DOH and the Urban Institute projects that the redeterminations will result in a decrease in Medicaid enrollment of about 1.2 million, with about 1 million people needing to return to employer-based health care. The State is working with the Centers for Medicare and Medicaid Services (CMS) to maximize automatic administrative redeterminations, which will significantly shrink the number of people who have to go through the full redetermination process.
The recertification process will roll out over 14 months, with those with recertification dates in June being the first batch of beneficiaries who will need to recertify. The New York City Human Resources Administration (HRA) will start mailing letters in March, with upstate districts starting mailings in April. For those enrolled through NY State of Health, mailings will begin in May. The State’s intent is to recertify approximately 1/12 of the beneficiaries each month so that all have been recertified by June 2024.
DOH has been engaging stakeholders and has given several meeting briefings and provided guidelines to Medicaid managed care plans, although there seems to have been limited information from DOH targeted directly at providers so far. As DOH negotiates with CMS and works through a variety of systems issues to help ensure a smooth transition, a primary public-facing effort is one of communicating to individuals enrolled in Medicaid that this initiative is underway and that beneficiaries should have their current contact information on file. DOH is taking the lead in preparing communication materials and is engaging other government agency partners and stakeholders in the effort to help educate people that this is coming. Providers, especially staff who deal with eligibility issues, should be aware of redetermination timelines and help clients and families understand that they may have to take action to maintain their eligibility. A communications toolkit is available here.
This effort coincides somewhat with the May 11th end of the federal public health emergency (PHE), with the federal Department of Health and Human Services (HHS) holding a recent stakeholder meeting on the implications of the end of the PHE. Along with a formal notification to governors, HHS provided a fact sheet available here indicating what may and may not change when the PHE ends. Key points include the following:
- Access to free vaccination, testing, and treatment will not be immediately affected by the end of the PHE, but CMS will have a process to move these into the commercial market in late summer/early fall.
- Access to vaccines, tests, and treatments will continue to be covered for both Medicare and Medicaid beneficiaries through September 2024. Medicare and Medicaid will cover medically necessary polymerase chain reaction (PCR) and antigen tests for Medicare and Medicaid beneficiaries, ordered by a physician or approved clinician. The current free over-the-counter tests will end with the PHE.
- The Food and Drug Administration's (FDA) emergency use authorization (EUA) is not going to be affected by the end of the PHE. Authorization over various products will remain, and the FDA will have the authority for new EUAs when criteria for issuance are met.
- Long term care facility reporting of resident and staff infections will continue, given that it is a regulatory provision.
- At the Centers for Disease Control and Prevention (CDC), there will be changes to reporting of lab results and immunization data. HHS's authority to require lab reporting of negative tests will end with the PHE. Additionally, at the state level, vaccine administration data will no longer be required. The CDC is working on voluntary data use agreements for both.
- The Consolidated Appropriations Act extends many telehealth waivers until Dec. 31, 2024. CMS shared that some Medicaid telehealth flexibilities can continue after the PHE ends, and CMS encourages states to use telehealth moving forward.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841