By Joe Touschner and Tricia Brooks
The single provision of the Children’s Health Insurance Program Reauthorization Act (CHIPRA) that has generated the most questions to CCF staff has got to be the performance bonus (we love questions so keep them coming!). While funded through CHIPRA, the bonuses are awarded to states that reach the lowest-income kids by exceeding specific enrollment targets for children enrolled in Medicaid and by meeting at least five of eight program features to improve access and efficiency. As with any competition, participants have many specific questions about how they will be judged. Some of those questions were addressed by CMS in its December 2009 guidance However, some questions remained and, as the agency prepares to award bonuses for 2010, it has released another set of frequently asked questions and answers on this complex provision.
First off, states have a revised deadline for applying for bonus payments. States must submit information on how they meet the 5 of 8 features by October 15 and have until November 1 to provide data to show the required enrollment gains. The guidance clarifies that even the states that received bonuses last year or that have informally discussed their eligibility with CMS must submit formal applications to be considered for 2010 bonuses.
With the exception of premium assistance, a state must have implemented the program features in both Medicaid and CHIP. Most states meet at least two measures since the eight program features include doing away with face-to-face interviews and eliminating or simplifying verification of an asset test, steps that almost all states have taken.
The new Q & A provides more specifics on how CMS is interpreting the statutory requirement that the program features be implemented throughout the entire fiscal year. Any necessary state legislation to implement a feature would have had to be effective by October 1, 2010, although not all program features require legislation. Additionally, the program feature must be operational in a state from April 1, 2010 through September 30, 2010. To receive credit for the same measure in future years, the strategy must be in operation for the full year. The new guidance also emphasizes that a program feature must all be in place in all eligibility groups for which being a child is a requirement of eligibility including 1115 demonstrations or waivers but not groups not linked to age (e.g. disability).
The guidance goes into greater detail about how states can meet specific measures and helps states determine if their current practices are consistent with the performance bonuses requirements. States where there remains some question about whether its practices qualify for a particular program feature should apply. It’s like winning the lottery, if you don’t play, you can’t win…..if you don’t apply, you won’t get a bonus! The process can be informative and help states make changes that will secure future bonuses.
In these cash-strapped times, most states continue to see significant increases in their Medicaid enrollment and are likely meeting the performance bonus enrollment targets. Looking at how to streamline processes in a way that stretches limited staff resources, increases administrative efficiency, makes it easy for families to enroll and retain coverage for their kids AND earns a performance bonus is a win-win for everyone.
This new guidance may not put us out of the business of answering questions on the performance bonus, but it’s a useful new resource for those working to bring home a bonus payment for their states.