Most CHIP directors I have known over the years are truly committed to the mission of covering children. They recognize the importance of coverage to children’s healthy development, along with the economic security and peace of mind it provides to families. So no doubt many CHIP directors are biting their nails over the fact that Congress has yet to extend CHIP funding beyond September 2017, as I would be if I still administered New Hampshire’s Healthy Kids program.

Although CHIP has enjoyed bipartisan support over the years, Congress has done little to get the ball rolling on extending funding, at a time when back to school outreach and enrollment efforts are in full swing and enrollment traditionally grows. While some lawmakers have signaled to stakeholders not to worry about CHIP, Congress needs to be aware that these programs cannot be stopped on a moment’s notice.

Yes, there is a little wiggle room in that all states will have some leftover allotment from FY 2017, of which only two-thirds is available for FY 2018 spending. And there are some contingency funds to be redistributed that may give states another month or two. But just because only a handful of states will run out of money by the end of this calendar year, doesn’t mean that states can wait until they have exhausted their carryover funds to take action. There are a significant number of decisions to be made and steps to taken.

But first, states may need clarification from CMS about a few things. These include how and when the maintenance of effort (MOE) impacts CHIP if there is no new funding as of October 1, 2017. For example, can states immediately freeze new enrollment in order to preserve their unspent allotment to provide continuing coverage for current enrollees? Are states obligated to fulfill the promise of 12-month continuous eligibility, a policy that 26 of 36 separate CHIP programs have adopted?

This is just a quick back of the envelope list of decisions to be made and actions to be taken:

• Confer with the public and Indian tribes and organizations before making program changes
• Determine if the state will temporarily freeze enrollment and whether it will maintain a waitlist in the interim
• Decide whether to end the separate CHIP program, transition it to a Medicaid expansion, or a hybrid of the two
• Make changes to Medicaid and state-based marketplaces eligibility and enrollment systems
• Inform the FFM of the change in eligibility if relying on Healthcare.gov
• Amend contracts with vendors managing systems, call centers, and enrollment services
• Notify providers and managed care companies
• Provide updated training and guidance to navigators, application counselors and other application assisters
• Submit state plan amendments to CMS on planned changes
• Provide families with sufficient notice to explore other coverage options
• Screen all current enrollees for eligibility for Medicaid or subsidized coverage in the Marketplace
• Convene and educate community-based partners about the changes
• Boost customer service to handle family and stakeholder questions and concerns
• Make changes to applications, websites, and outreach materials
• And more…..

While many states are believe that Congress will extend CHIP, there is potential for only a short-term extension, as well as concern that CHIP will get caught up in other issues. Without a clean bipartisan long-term extension, states and families will be in the same position at the end of 2017 or in a year or when some other short-term fix Congress runs out. Regardless, the lack of clear support for children’s coverage threatens our nation’s success in providing coverage for 95% of children. I hope members of Congress are thinking about what they will tell their constituents when their state take steps to shut down or freeze their CHIP program because Congress has failed to act.

Editor’s note: Read more about the future of CHIP as the program turns 20