Renewals in Medicaid and CHIP: Implementation of Streamlined ACA Policies and the Potential Role of Managed Care Plans
Renewal Processes for Medicaid and CHIP under the ACA
Ex parte renewals.1 The state should check all data sources to determine if eligibility can be renewed based on available data without contacting the family. Because the decision is based on reliable data sources, a signed renewal form is not needed. The state must send a notice to the beneficiary informing him or her of continued eligibility and providing the opportunity to correct any inaccurate information, but, if nothing has changed, the individual is not required to sign or return the notice.2 The concept of ex parte renewal is a longstanding federal Medicaid policy, but it had previously been inconsistently applied by states, since many states had limited systems capability to check against data sources and renew eligibility without the enrollee providing information. The broader systems upgrades facilitated by the ACA, coupled with access to electronic verification data, enhanced states’ ability to implement an effective ex parte process.
Pre-populated forms. If an ex parte renewal cannot be achieved, states must provide the enrollee a pre-populated renewal form that includes information available to the agency and requests additional information needed to renew eligibility.3 These pre-populated forms must be provided at least 30 days in advance of the renewal date and must be accepted through multiple modes, including online, by phone, mail and in person.4 Individuals must sign and return the pre-populated renewal form to complete the renewal, and states must provide several signature options, including telephonic signatures, electronic signatures and handwritten signatures that can be transmitted electronically.5 States also are required to provide notices to individuals following completion of the renewal.6
90-day reconsideration period. If an individual does not complete the renewal, states must provide at least a 90-day reconsideration period after the date coverage ends.7 During this period, families have the opportunity to provide the necessary information to continue coverage without being required to complete a new application. Under regulations, retroactive Medicaid coverage is available back to the date coverage ended, although some states have received waivers of retroactive coverage.
Coverage transitions. Prior to terminating Medicaid coverage, the state must consider eligibility through all eligibility pathways (both MAGI and non-MAGI) and assess or determine eligibility for other coverage options including CHIP and Marketplace coverage.8 If the state assesses the individual as potentially eligible for Marketplace coverage, it must electronically transfer that individual’s account to the Marketplace for a complete determination of eligibility.9
Renewals for Non-MAGI groups. There are some differences in renewal rules for elderly and disabled populations whose Medicaid eligibility is determined based on non-MAGI rules.10 Eligibility is renewed at least every 12 months, and ex parte renewal is required if sufficient information is available. States may, but are not required, to use a pre-populated renewal form for these groups. In general, states have delayed systems upgrades for non-MAGI groups, with most planning toward incorporating them into new or upgraded systems in 2016.11