CMS Releases Guidance on Ensuring a Smooth Transition for ‘Stairstep’ Kids

By Wesley Prater

As I discussed in a previous blog, Section 2001(a)(5)(B) of the Affordable Care Act aligns the minimum eligibility level for children across all age groups. Thus, some states will need to transition children from coverage in their separate CHIP programs to coverage in Medicaid on January 1, 2014. The provision is intended to align with existing minimum eligibility for younger children, so that children in a family will generally qualify for the same program, regardless of their age. This will remove the “stairstep” eligibility rules that have existed for years in a number of states.

CMS recently released guidance to further assist states and discuss best practices to implement a smooth transition for families and minimize the administrative burden for states. The guidances offers detailed best practices recommended for:

• Automatic administrative transfer and reported changes in circumstances
• Development of materials regarding the transition
• Notices (including timing and origination of notices)
• Stakeholder engagement
• Data sharing capabilities between Medicaid and CHIP
• Continuity of care strategies
• Monitoring the transition

The guidance did indicate that if states can show that transitioning the stairstep kids to Medicaid by January 1, 2014 will create an undue hardship on families and/or a significant administrative burden, CMS would consider alternative approaches for the transition. This alternative plan would need to be submitted as soon as possible and approved by CMS. Additionally, notices to families explaining the alternative plan to the family would also need to be approved in advance. CMS must receive this request from states by November 1, 2013.

CMS stated that they would consider the following examples of alternative approaches:

• A phase-in transition based on meaningful criteria
• Giving families the option to remain in CHIP until a child’s next scheduled renewal
• Implementing the transition to coincide with other significant reforms in the state

CCF has been following this provision closely and we released a report with the Kaiser Commission on Medicaid and the Uninsured on how this affects children and families as well as states. To date, this is the most thorough guidance that has been released regarding the transition. This guidance can be a valuable resource for advocates and states to ensure a smooth transition for children and families.

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