CMS

Medicaid

I wrote about this last summer, but as the Omicron variant wave of COVID-19 seems to be winding down (with an emphasis on seems) and the federal Public Health Emergency (PHE) declaration currently set to expire in 60 days (April 16, 2022), today felt like a good time to repost something about the situation:

What goes up usually goes back down eventually, and that's likely to be the case with Medicaid enrollment as soon as the public health crisis formally ends...whenever that may be.

Well, yesterday Ryan Levi and Dan Gorenstein of of the Tradeoffs healthcare policy podcast posted a new episode which attempts to dig into just when that might be, how many people could be kicked off of the program once that time comes and how to mitigate the fallout (I should note that they actually reference my own estimate in the program notes):

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This is great news, and there's also a small but important wording choice which should be noted:

CMS Commits Over $49 Million to Reduce Uninsured Rate Among Children and Boost Medicaid Enrollment Among Parents, Pregnant People

The Centers for Medicare & Medicaid Services (CMS) committed a record $49.4 million to fund organizations that can connect more eligible children, parents, and pregnant individuals to health care coverage through Medicaid and the Children’s Health Insurance Program (CHIP). Awardees—including state/local governments, tribal organizations, federal health safety net organizations, non-profits, schools, and others—will receive up to $1.5 million each for a three-year period to reduce the number of uninsured children by advancing Medicaid/CHIP enrollment and retention.

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In the midst of all the data & stats from this morning's CMS report touting the most successful ACA Open Enrollment Period ever, I almost forgot another important related report which the Biden Administration is promoting as well:

This week, HHS’s office of the Assistant Secretary for Planning and Evaluation (ASPE) is also releasing a report analyzing new survey data that showed the uninsured rate fell in 2021 after the American Rescue Plan and outreach efforts took effect. According to the report, the uninsured rate for U.S. population was 8.9% for the third quarter of 2021 (July – September 2021), down from 10.3% for the last quarter of 2020 – corresponding to roughly 4.6 million more people with coverage over that time period. Coverage gains occurred among both children and working age adults, with the largest coverage gains for those with incomes under 200% of the poverty level (roughly $27,000 for a single adult or $56,000 for a family of four).

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Statement by CMS Administrator Chiquita Brooks-LaSure On the U.S. Supreme Court’s Decision on Vaccine Requirements

“The Centers for Medicare & Medicaid Services (CMS) is extremely pleased the Supreme Court recognized CMS’ authority to set a consistent COVID-19 vaccination standard for workers in facilities that participate in Medicare and Medicaid. CMS’ vaccine rule will cover 10.4 million health care workers at 76,000 medical facilities. Giving patients assurance on the safety of their care is a critical responsibility of CMS and a key to combatting the pandemic.

“Vaccines are proven to reduce the risk of severe disease. The prevalence of the virus and its ever-evolving variants in health care settings continues to increase the risk of staff contracting and transmitting COVID-19, putting their patients, families, and our broader communities at risk. And health care staff being unable to work because of illness or exposure to COVID-19 further strains the health care system and limits patient access to safe and essential care.

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The Affordable Care Act includes a long list of codified instructions about what's required under the law. However, like any major piece of legislation, many of the specific details are left up to the agency responsible for implementing the law.

While the PPACA is itself a lengthy document, it would have to be several times longer yet in order to cover every conceivable detail involved in operating the ACA exchanges, Medicaid expansion and so forth. The major provisions of the ACA fall under the Department of Health & Human Services (HHS), and within that, the Centers for Medicare & Medicaid (CMS)

Every year, CMS issues a long, wonky document called the Notice of Benefit & Payment Parameters (NBPP) for the Affordable Care Act. This is basically a list of proposed tweaks to some of the specifics of how the ACA is actually implemented.

For example, here's what the actual PPACA legislative text itself said about the annual Open Enrollment Period (OEP):

(6) Enrollment periods.--The Secretary shall require an Exchange to provide for--

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As I explained back in 2018, the Trump Administration seriously gutted the ACA's Navigator program:

The Trump administration is considering cutting funding for ObamaCare outreach groups that help people enroll in coverage, sources say.

An initial proposal by the administration would have cut the funding for the groups, known as "navigators," from $36 million last year to $10 million this year. Sources say that proposal now could be walked back, and it is possible funding could remain the same as last year, but it is unclear where the final number will end up.

...Officials announced it would cut funding from $63 million down to $36 million in August 2017, a move that was decried by Democrats.

Thankfully, last summer, the Biden-Harris Administration announced that they were reversing this by massively re-expanding the program including a significant budget increase:

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So, in addition to their standard Weekly Snapshot Report, CMS issued a more comprehensive mid-OEP (Open Enrollment Period) press release this morning which not only finally breaks out the HealthCare.Gov enrollment data by state, but also includes partial 2022 OEP data for the 18 state-based ACA marketplaces (SBM). Each press release has some unique information, while some of it is duplicated, so this post sort of merges the two together, along with some additional analysis by myself.

First "National Snapshot" press release:

The Centers for Medicare & Medicaid Services (CMS) reports that nearly 4.6 million Americans have signed up for 2022 individual market health insurance coverage through the Marketplaces since the start of the 2022 Marketplace Open Enrollment Period (OEP) on November 1. This includes 3.9 million plan selections in the 33 states using the HealthCare.gov for the 2022 plan year, through December 4, 2021 (Week 5), and 625,000 plan selections in the 17 states and the District of Columbia with State-based Marketplaces (SBMs) that are using their own eligibility and enrollment platforms, through November 27, 2021 (Week 4). Total nationwide plan selections include 923,000 consumers (20% of total) who are new to the Marketplaces for 2022, and 3.6 million consumers (80% of total) who have active 2021 coverage and returned to their respective Marketplaces to renew or select a new plan for 2022.

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CMS had already announced this previously but now it's official:

CMS Extends Open Enrollment Period and Launches Initiatives to Expand Health Coverage Access Nationwide

The Biden-Harris Administration, through the Centers for Medicare & Medicaid Services (CMS), is taking a number of steps that will make it easier for the American people to sign up for quality, affordable health coverage and reduce health disparities in communities across the country. Beginning this year, consumers will have an extra 30 days to review and choose health plans through Open Enrollment, which will run from November 1, 2021 through January 15, 2022, on HealthCare.gov.

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via CMS:

The Biden-Harris Administration is expanding the number of Navigator organizations to help people enroll in coverage through the Marketplace, Medicaid, or the Children’s Health Insurance Program (CHIP) in 30 states with a Federally-Facilitated Marketplace. Through $80 million in grant awards for the 2022 plan year, 60 Navigator awardee organizations will be able to train and certify more than 1,500 Navigators to help uninsured consumers find affordable and comprehensive health coverage.

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via Amy Lotven of Inside Health Policy:

CMS tells Inside Health Policy that it will be releasing a final report on its COVID-19 Special Enrollment Period in September and points out that consumers who submitted their applications by the Aug. 15 SEP deadline still have 30 days to select a plan. Additionally, staffers are contacting the “very small group” of consumers who reached out to the Marketplace Call Center just before the deadline but were unable to get through to a representative so that those individuals have a chance to enroll, the agency confirms.

The final report was obvious, since the 2021 "No Excuses Needed" SEP still ran through August 15th in most states (and is still ongoing in a few), but I figured they'd come out with it in late August, not September.

I admit that I didn't know (or had forgotten?) about those who submitted their apps prior to 8/15 still having a full month to select a plan. Granted, if they wait until mid-September their coverage won't start until October, giving them just 3 months to use up a full 12-month deductible, but still.

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