While I was enjoying some holiday down time with the family, CMS was busy churning things out over the past few weeks. On December 30th, CMS approved Michigan’s Section 1115 Medicaid waiver to help open the doors to Medicaid coverage for an estimated 300,000-500,000 Michiganders. The Medicaid expansion,will be implemented on April 1st.
The Michigan plan addresses many of the same issues that have been swirling around in the recently approved Iowa Medicaid waiver and in the proposed Pennsylvania plan – incentivizing healthy behaviors and restructuring Medicaid cost-sharing to some extent. Unlike Arkansas and Iowa, the Healthy Michigan plan does not put new beneficiaries into the exchange. And the MI plan does not include any benefit waivers (Iowa you will remember includes a limited one-year waiver of the non-emergency transportation benefit.)
So what is new about Michigan’s approach? The state will establish accounts for the newly eligible beneficiaries that will include some novel forms of cost-sharing — described below. And beneficiaries that comply with some of the as yet largely unspecified healthy behaviors can see a reduction in these charges.
The state has 90 days to submit additional details to federal CMS on how these accounts will work along with more information on what kinds of healthy behaviors will be rewarded. (Note: This is part of a slightly troubling trend with details being worked out later that we have mentioned before – there are some handles for stakeholders to get involved in these discussions in both the Iowa and Michigan waiver terms and conditions but this issue bears watching.)
Here is what we know so far — beneficiaries over the poverty line between 100-133% of FPL will have to pay 2% of their income in premiums into the new accounts though they cannot be denied enrollment for nonpayment. For those under the poverty line in Michigan, individual accounts will be established that reflect a person’s usage of services over the prior six-month period, and beneficiaries will pay the appropriate copay amounts. The copays will not be paid to providers at the time of service but placed into these new accounts on a regular basis. The way this works exactly is still to be determined – but the overall expected payment cannot exceed maximums allowed in Medicaid cost-sharing rules as no waiver was given in this area. And providers cannot turn people away for failure to pay.
So, yet again, this all seems more complicated than a straight up Medicaid expansion, though there are certainly far fewer moving parts in Michigan’s plan than in the Iowa and Arkansas waivers. And “Healthy Michigan” is making an effort to test new approaches that may be beneficial – so we will keep an eye on how the waiver proceeds and a strong evaluation is needed.
Also on the CMS activity front over the holidays, my colleague Elisabeth Burak already blogged about the CHIPRA performance bonuses were released earlier this week, CMS also released some new FAQs which cover a range of topics including FMAP for the newly eligible, eligibility rules for youth aging out of foster care, guidance on CHIP matching rates, CHIP allotments, “stairstep kids” and future eligibility expansions for kids and families. You can see the FAQs here — 12/27 FAQ’s from CMS.
One interesting note from the FAQ’s re Medicaid expansion is that states that do a straight expansion with a state plan amendment can be paid retroactively within a quarter, but those that undertake a waiver approach like Michigan, Iowa and Arkansas, cannot. We will share other tidbits from these FAQs in future blogs no doubt.
They were busy at CMS over the holidays!
