Frequently Asked Questions are used to provide additional information and/or statutory guidance not found in State Medicaid Director Letters, State Health Official Letters, or CMCS Informational Bulletins. The different sets of FAQs as originally released can be accessed below.
Frequently Asked Questions
Yes. CMS will continue to consider section 1115 demonstration extension requests. However, the State's proposal must include a plan to address changes in its demonstration that would need to take place to ensure readiness for 2014. Please also note that extension requests are subject to the recently issued transparency final rule (http://www.gpo.gov/fdsys/pkg/FR- 2012-02-27/html/2012-4354.htm )and corresponding State Health Officials letter (http://www.medicaid.gov/Federal-Policy-Guidance/Downloads/SHO-12-001.pdf (PDF 0 bytes)), which outlines the new public notice comment and process requirements.
Supplemental Links:
Date: May 21, 2012
Topics:
Affordable Care Act
Subtopics:
Section 1115 Demonstrations
FAQ ID: 93031
Since 2006, State Medicaid programs have had the option to provide certain groups of Medicaid enrollees with an alternative benefit package known as "benchmark" or "benchmark-equivalent" coverage, based on one of three commercial insurance products or a fourth, "Secretary-approved" coverage option. Beginning on January 1, 2014, all Medicaid benchmark and benchmark-equivalent plans must include at least the ten statutory categories of Essential Health Benefits. Under the Affordable Care Act, the medical assistance provided to the expansion population of adults who become newly eligible for Medicaid as of January 1, 2014, must be provided consistent with section 1937 benchmark authority.
For Medicaid alternative benefit plans, three of the benchmark plans described in section 1937 (the State's largest non-Medicaid HMO, the State's employee health plan, and the FEHBP BCBS plan) may be designated by the Secretary as EHB benchmark reference plans, as described in the EHB Bulletin (link below). A State Medicaid Agency could select any of these section 1937 benchmark plans as its EHB benchmark reference plan for Medicaid. There would be no default EHB benchmark reference plan for purposes of Medicaid; each State Medicaid Agency would be required to identify an EHB benchmark reference plan for purposes of Medicaid as part of its 2014-related Medicaid State Plan changes.
If the EHB benchmark reference plan selected for Medicaid were to lack coverage within one or more of the ten statutorily-required categories of benefits, the section 1937 alternative benefit plan would need to be supplemented to ensure that it provides coverage in each of the ten statutory benefit categories. This would be in addition to any other requirements for Section 1937 plan, including Mental Health Parity and Addition Equity Act compliance.
For more information about the Essential Health Benefits, please see CCIIO's bulletin from December 2011 (available at http://cciio.cms.gov/resources/files/Files2/12162011/essential_health_benefits_bulletin.pdf ) and the CMCS informational bulletin from February 2012 (available at http://www.medicaid.gov/Federal-Policy-Guidance/downloads/CIB-02-17-12.pdf.
Date: May 21, 2012
Topics:
Affordable Care Act
Subtopics:
Benefits and Delivery Systems
FAQ ID: 93036
Yes. A State is not required to select the same EHB benchmark reference plan for Medicaid section 1937 plans that it selects for the individual and small group market, and it could have more than one EHB benchmark reference plan for Medicaid (for example, if the State were to develop more than one benefit plan under section 1937).
Supplemental Links:
Date: May 21, 2012
Topics:
Affordable Care Act
Subtopics:
Benefits and Delivery Systems
FAQ ID: 93041
Yes. A State could propose its traditional Medicaid benefit package as a section 1937 alternate benefit plan under the Secretary-approved option available under section 1937 of the Social Security Act. The State would have to ensure that the ten statutory categories of EHB are covered, either through that benefit plan or as a supplement to that plan.
Supplemental Links:
Date: May 21, 2012
Topics:
Affordable Care Act
Subtopics:
Benefits and Delivery Systems
FAQ ID: 93046
The managed care regulations apply to all benefits delivered through a managed care delivery system, regardless of the authority under which the benefits are provided or enrollment is required. Thus, any State which uses a managed care organization to deliver benefits under the authority of section 1937 of the Act must comply with the managed care regulations at 42 CFR 438.
Supplemental Links:
Date: May 21, 2012
Topics:
Affordable Care Act
Subtopics:
Benefits and Delivery Systems
FAQ ID: 93051
Yes. 1915 (c) waivers are optional programs that most States currently operate and can continue to operate. States interested in making changes to their 1915(c) waivers should contact their CMS Regional Office with specific questions.
Supplemental Links:
Date: May 21, 2012
Topics:
Affordable Care Act
Subtopics:
Benefits and Delivery Systems
FAQ ID: 93056
Yes. CHIP enhanced FMAP will continue to be available for children whose income is greater than the Medicaid applicable income level (defined in section 457.301 and based on the 1997 Medicaid income standard for children), regardless of whether those children are enrolled in Medicaid or CHIP. This includes children who previously qualified for CHIP in a separate program and children whose family incomes are up to 133 percent of the Federal poverty level, and therefore will be newly eligible for Medicaid in 2014.
Supplemental Links:
Date: May 21, 2012
Topics:
Affordable Care Act
Subtopics:
Children's Coverage
FAQ ID: 93061
Yes. Section 2101(f) of the Affordable Care Act provides that States maintain coverage under a separate CHIP program for children who lose Medicaid eligibility due to the elimination of income disregards as a result of the conversion to MAGI. We anticipate that this provision will directly impact a relatively small number of children, and are committed to helping States implement this provision in a manner that is not unduly burdensome or costly and still protects the continuity of coverage for these children as required by statute.
For States with only Medicaid Expansion CHIPs, one approach is to create a separate CHIP that is substantively identical to the existing program, thereby creating the greatest continuity of coverage for the child, the least confusion for the family, and the most efficient operation for the state. For States with existing separate CHIPs, a State plan amendment assuring that these children will be covered through that program for as long as they qualify should be sufficient.
Supplemental Links:
Date: May 21, 2012
Topics:
Affordable Care Act
Subtopics:
Children's Coverage
FAQ ID: 93066
The process for making a MAGI-based eligibility determination is largely the same for all insurance affordability programs. The Affordable Care Act requires a single, streamlined application, accompanied by a similar set of business rules and verification processes, and an adjudication work flow that is largely identical between Exchanges, Medicaid and CHIP programs.
It is expected that State agencies that receive Federal funds from CMS to establish State-based Exchanges and provide for Medicaid and CHIP expansions coordinate efforts to produce a shared eligibility service or system that relies on a shared IT infrastructure and as such, cost allocate this service.
A shared eligibility service is not the same as one system. We define an eligibility service as a set of IT functions that produce an eligibility determination based upon MAGI. The service incorporates an application, a set of verifications (for citizenship, income, residency, etc.) and business rules that together determine how much financial assistance a consumer should receive to acquire affordable health insurance.
While policies codified in final regulations allow legal authority for eligibility determinations to remain with state Medicaid agencies (for Medicaid) and Exchanges (for premium tax credits and cost-sharing reductions), the underlying business rules and processes are nearly identical, and should, to the maximum extent practical, rely upon a shared IT service(s) and infrastructure.
Supplemental Links:
Date: May 21, 2012
Topics:
Affordable Care Act
Subtopics:
Coordination with the Federally Facilitated Marketplace
FAQ ID: 93071
The agreement between Medicaid/CHIP agencies and Exchanges regarding coordination must be available to the Secretary upon request and will be subject to applicable disclosure laws, such as the Freedom of Information Act.
Supplemental Links:
Date: May 21, 2012
Topics:
Affordable Care Act
Subtopics:
Coordination with the Federally Facilitated Marketplace
FAQ ID: 93076