By Martha Heberlein
Citing the ongoing delay in transferring Medicaid/CHIP applicants from the Federally Facilitated Marketplace (FFM) to states, CMS has given states the option to enroll new Medicaid applicants based on the “flat files,” as opposed to full applicant accounts, in the hopes of getting new applicants connected to coverage by January 1.
To understand how this mitigation strategy will work, let’s take a step back to look at what was envisioned under the ACA. To facilitate coordination across programs and prevent individuals from having to provide information multiple times, Medicaid/CHIP agencies and Marketplaces were expected to electronically transfer an account with all of the individual’s information and not request any data that the individual has already provided.
However, given the technical glitches that are plaguing healthcare.gov, these transfers (both to and from the FFM) have been delayed. In their place, CMS has been sending states “flat files” containing basic information on applicants assessed or determined eligible for Medicaid/CHIP. The idea was that these files would help states plan their workload needs once the ability to transfer full electronic accounts came online.
Under this mitigation strategy announced last week, CMS now plans on expanding the data included in the file so that it contains enough information, such as SSNs and dates of birth, to enroll the individual. (It’s important to note that these data are a subset of what will be available in the account transfer and have been verified by the FFM.) States can take up this approach through a time-limited (up to 90 days, with the possibility of an extension) waiver. And once the full account transfer is available, states will no longer have this option and should be processing new enrollments in the expected manner.
In states allowing the FFM to make a determination, the process is pretty much the same as if they were receiving the full account – the Medicaid/CHIP agency will enroll individuals based upon the data that are available in the flat file and they will remain eligible until their next regularly scheduled renewal. Similarly, if the account transfers were available, these states would accept the FFM’s determination and enroll the individual without re-verifying any eligibility criteria.
In assessment states, the individual can only be enrolled for a temporary period (no more than 90 days) and a full review of the account file, once it is transferred, could then be completed. Assessment states also can’t enroll individuals for whom there is an inconsistency between the attested and the electronic data and will have to process these applicants in the “regular” manner.
[Note that this strategy also can’t be used (in either assessment or determination states) for applicants who have asked for a full Medicaid determination or who have been referred for non-MAGI based eligibility.]
It’s obvious that while the kinks are being ironed out of the system, CMS is looking to help states enroll eligible people into Medicaid/CHIP. It will be interesting to see if states take them up on the offer of a workaround. There are very good reasons to do so – not only would it ease the administrative burden on the state, it would also help connect people to coverage as soon as possible.
