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From Health Law Daily, June 20, 2013

Update on single application for Medicaid, exchange coverage, subsidies

By Michelle L. Oxman, JD, LLM

CMS has released guidance and additional tools to help states coordinate their application processes for Medicaid and the Children’s Health Insurance Program (CHIP) with the health insurance exchanges (CMS Memorandum, June 18, 2013). State Medicaid and CHIP agencies must prepare to interface with the exchanges, also called marketplaces, when enrollment begins October 1, 2013.

One-stop enrollment. Under the Patient Protection and Affordable Care Act (PPACA) (P.L. 111-148), individuals seeking coverage must be able to submit one application to the health insurance exchange to be considered for Medicaid, CHIP, enrollment in qualified health plans, premium subsidies, and cost sharing reduction. The exchanges operated by the federal government will use the paper and online form released earlier this year. State Medicaid and CHIP agencies and health insurance marketplaces operated by states may use the federal form or develop their own alternative applications. Any alternative state form must meet CMS requirements.

Requirements for state forms. State Medicaid and CHIP agencies and state-operated marketplaces are expected to collaborate to develop the joint application, which must meet the requirements of the Medicaid, CHIP, and health insurance exchange regulations. All alternative applications must be submitted to CMS, but certain modifications do not require approval: (1) deletion of questions that are not relevant to the state’s eligibility requirements for or administration of Medicaid or CHIP; (2) references or links to any alternative electronic data base that the state uses to verify eligibility; (3) addition of state-required notices of privacy rights; (4) changes to the placement and order of questions that maintain the “dynamic nature” of the federal application; (5) removal of requests for data that the state will verify after determining eligibility; (6) information relevant to additional state programs or eligibility categories, such as family planning benefits.

States must obtain CMS approval of changes to the: (1) income tax-related questions; (2) requests for explanations of discrepancies between the application and the information gained from electronic databases; and (3) timing of electronic verification of portions of the data. Any additions related to eligibility determinations not involving the Modified Annual Gross Income (MAGI) standard must be reviewed and approved by CMS. The organization of the application should not require applicants to submit data that is not needed for the eligibility determination the applicant requests. For example, when the applicant does not wish to be considered for Medicaid, no data related only to Medicaid eligibility should be required.

Approval process. Detailed instructions for requesting approval are provided. In addition, a toolbox is available on the CMS website. CMS will grant conditional approval under an expedited process for 2014. States must obtain final approval during 2014.

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