By Martha Heberlein
An option provided by CMS to states to delay renewals so that they wouldn’t be running eligibility the old and new way, has a second purpose as states face processing back logs and fixing systems glitches.
Taking a step back – the ACA requires that existing beneficiaries be protected against losing coverage due to the move to MAGI-based eligibility before March 31, 2014 or at their annual renewal, whichever comes later. But to ensure this grandfather status, states would need to apply both the new MAGI rules and the pre-ACA rules, and to avoid this duplication of effort, CMS offered states the option to extend renewal dates.
This opportunity to delay renewals is especially useful for states that need additional time to ensure their systems are capable of processing MAGI-based renewals in the manner expected under the ACA – and we’ve seen some early trouble spots in states that have started processing renewals.
Of the 36 states that received approval to postpone renewals in the first quarter of 2014, one-third expects to complete the process by June 2014, while two-thirds are delaying over a longer timeframe, with some concluding the process in 2015. These end dates have shifted over time, in part, because states have received approval to extend further out as they reassess their system readiness and capacity to process the increased volume of cases.
A few notes of caution for advocates monitoring the renewal process in their states –
To help allay workflow concerns, CMS has given some states permission to “reset” the caseload back to its regularly-scheduled renewal month following the delay. For example, if a state delayed January renewals until April, they could set those enrollees to have another full renewal (as previously scheduled) in January – just 9 months later and a deviation from the requirement to renew eligibility once every 12 months and no more frequently than that. Not all states that have delayed renewals are taking this approach, so it’s important to follow up with your state to see how they’re processing renewals and when the first renewal will take place.
Another important note to watch in your state is how they’re handling reported changes in circumstances. Just because they have delayed scheduled renewals, it does not mean that they decided to stop processing changes in circumstances that impact eligibility. If a change is reported prior to renewal, the grandfathering protection would still apply and the state would have to run eligibility through both MAGI and pre-MAGI methods. If the consumer is ineligible under both, they would no longer retain coverage as the protection is only for those losing coverage as a direct result of the move to MAGI. However, we have heard that a number of states (at last count – 15) have been approved to delay acting on reported changes in income eligibility to avoid a dual eligibility review.
Even with these concerns, the option to delay renewals may be something states (and advocates) should consider. This first round of MAGI-based renewals requires more information from consumers, as well as more help and follow-up from assisters and program staff, to ensure that those who are still eligible retain their coverage. Delaying renewals until the system and the staff are ready to respond may ease the burden across the board.
