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Maximizing and simplifying
    enrollment: options for
                 Maryland
      Health Care Reform Coordinating Council
               Entry into Coverage Workgroup
                              August 31, 2010

                     Stan Dorn, Senior Fellow
                          The Urban Institute
                             Washington, DC
Overview
       The importance of proactive strategies to
        enroll the eligible uninsured
       Success stories from other state and
        federal programs
       Policy options for Maryland




2
Part I
The importance of proactive
     strategies to maximize
                  enrollment
If you build it, will they come? Not
    necessarily…
       Recent federal history
         High-risk pools
         COBRA subsidies
         HCTC
       Older federal history
         CHIP – after 5 years, only 60% of eligible children
          were enrolled
         MSP – decades after statutory enactment, less than
          33% of eligible seniors enroll
       State history
         Maine

4
Part II
Success stories from other state
          and federal programs
The Massachusetts story




        Findings from a SHARE grant funded by the
        Robert Wood Johnson Foundation


6
Key facts
       Only 2.6 percent uninsurance by 2008
       But it’s not just the mandate and the subsidies!
         Consumers seamlessly enrolled into 4 separate programs. 1
          form and 1 eligibility process applied to all programs.
         Roughly 1 in 4 newly insured qualified for Commonwealth Care
          based on eligibility records from the state’s free care pool—no
          applications needed!
         More than half of all successful applications were filled out by
          CBOs and providers, not by consumers.
            o No DSH money for serving a patient unless application process
              completed
            o The ―Virtual Gateway‖ – on-line application system open to trained
              staff of CBOs and providers


7
The Louisiana story




8
LaCHIP renewals for children
       In December 2009:
          Procedural terminations – 0.7 %
          Total terminations – 4.6%
       By contrast:
          In some states, 50 percent of children lose coverage at renewal
          40 percent of eligible, uninsured children nationally received Medicaid
           or CHIP the prior year
          Why? Coverage ends unless renewal forms are completed
       LA eligibility determined based on
            Data from state-accessible records
            Where income is stable, administrative renewal
            Proactive telephone calls
            Traditional form completion is a last resort
       In September 2009, forms were required for only 3% of LA children
        renewing coverage


9
The Medicare Part D story
    1/2006, Part D coverage of prescription drugs
     began
      Included low-income subsidies (LIS)
    By 6/16/06, 74% of eligible beneficiaries
     received LIS
      Most qualified based on data matches with state
       Medicaid programs or SSA
      People who received Medicaid last year automatically
       get LIS this year
    Now, 80% of eligible beneficiaries receive LIS

10
Lessons learned
    Affordability is key
    The less consumers must do to enroll, the
     more will enroll
      Base eligibility on data, without requiring the
       completion of traditional application forms
      When forms are required, provide intensive
       application assistance, so consumers don’t
       need to complete paperwork

11
Why is paperwork such an issue?
   Human nature.
      Percentage of eligible workers who participate in
           tax-advantaged retirement accounts
                                                                   90%



                                       33%
          10%

Independent enrollment in    Firms where new hires        Firms where new hires go
          IRA               enroll in 401(k) only after    into 401(k) UNLESS they
                               completing a form          complete an opt-out form

Sources: Etheredge, 2003; EBRI, 2005; Laibson (NBER), 2005.


12
Part III
Policy options for Maryland
Highlights of the Affordable Care
 Act (ACA): A quick review
    Medicaid to 138% of the federal poverty level (FPL)
      Modified Adjusted Gross income (MAGI)
      Rules for newly eligible adults
        o Definition: would not have qualified under state rules as of 12/1/09
        o Highly enhanced federal medical assistance percentage (FMAP) –
          100% for 3 years, declining to 90% by 2020
        o ―Benchmark benefits‖
      Standard FMAP and benefits for other adults
    Subsidies in the exchange up to 400% FPL
      OOP cost-sharing subsidies to 250% FPL
    Integrated eligibility system for Medicaid, CHIP and
     exchange – 1 application form for all subsidies
    Individual mandate for coverage

14
Consumer assistance, including
 facilitated enrollment
        Consumer assistance grants for 2010
        Patient navigators in exchange
           Federal funding through 12/31/14
           Starting in 1/15, surcharge insurers?
          Key questions:
            o How much funding for navigators? Can foundations help?
            o Who are the navigators? CBOs, legal services programs
            o What do navigators do? Fill out applications, via ―virtual gateway‖

        Outstationed EWs probably less effective
        Follow MA precedent in terms of safety net providers?
        New importance of consumer advice
          Penalties for going without coverage
15        Tax consequences for excess subsidies
Basing eligibility on income data
    Subsidies in exchange
      Based on prior-year tax data
      Chance to supplement at application
      Year-end reconciliation
    Medicaid
      Initial determination based on income at time
       application is processed - challenge
      Post-application changes? Not clear, under PPACA
      What happens if application submitted to exchange?


16
Possible approach to Medicaid
    If prior-year tax data show Medicaid eligibility, consumer
     automatically receives Medicaid
      If after a certain point in the calendar year, could supplement with
        more recent data (new hires, quarterly earnings)
    If prior-year tax data show ineligible for Medicaid, receive
     an opportunity to apply for Medicaid using traditional
     procedures, including pay stubs, etc. Like Express Lane
     Eligibility.
      In the meantime, subsidies in the exchange
    Incidental advantages
      Lower administrative costs for eligibility determination. 50% FMAP.
      Less risk of erroneous eligibility determinations, federal sanctions.
    Depends on CMS allowing this approach – likely, not
     certain
17
Limit application forms to
 questions relevant to eligibility
    Need to distinguish the newly eligible from others
      Claim enhanced FMAP
      Provide benchmark benefits
    Requires information irrelevant to eligibility
      Parents
        o Assets
        o Deprivation
      Childless adults and empty nesters
        o Disability
        o Pregnancy
    Solutions
      To claim FMAP, use sampling (assuming CMS approval)
      Provide standard Medicaid benefits as ―Secretary-approved‖
        benchmark coverage, Social Security Act Section 1937(b)(1)(D)

18
Asking for help without
 completing a traditional form
    Eligibility is determined based on data when an
     individual applies ―by requesting a determination of
     eligibility and authorizing disclosure of … information
     [described in Social Security Act Sections 1137, 453(i),
     and 1942(a)] … to applicable State health coverage
     subsidy programs for purposes of determining and
     establishing eligibility.‖ PPACA Section
     1413(c)(2)(B)(ii)(II)
    Precedents
      EITC amount
      CA income tax
      Medicare Parts B and D – automatic, without request


19
Process
    Consumer requests determination of
     eligibility based on disclosure of data
    State and exchange gather data.
      SSA Section 1137 – IEVS, SAVE
      453(i) – National Directory of New Hires
      1902(a) – public benefit programs, new hires
        data, state tax records, Medicaid TPL data
        showing private coverage, vital statistics records
        in any state
    Data establish:
      Medicaid eligibility
      Eligibility for subsidies in exchange, with right of
        consumer to seek Medicaid determination based
        on more recent information
20
Basing eligibility on receipt of
 other benefits
    Express Lane Eligibility (ELE) remains an
     option for children
    Can seek 1115 waiver for adults
    Logical if other program’s eligibility is below
     138% FPL. For example:
      SNAP (130% gross income)
      TANF ($565/month, less deductions)
    Depends on CMS approval – likely, not
     certain

21
Integrated eligibility determination
    Basic model
      Exchange, Medicaid, and CHIP compile a data warehouse for
        each applicant, determine eligibility ―behind the scenes‖
    Medicaid needs better eligibility IT
      Will CMS develop modules?
      Will CMS provide sufficient Medicaid funding?
      Can administrative funding for the exchange help with Medicaid?
    Exchange can contract with Medicaid to determine
     eligibility for subsidies in exchange
      Massachusetts model
      Must meet HHS ―requirements ensuring reduced administrative
        costs, eligibility errors, and disruptions in coverage‖
    Single, statewide office when data establishes eligibility
      Link to local social service offices when households may qualify
        for other benefits
22
But can low-income adults afford coverage in the
 exchange? Will they enroll? Will they seek care?

    Subsidy levels lower than almost any state
     program serving low-income adults
    Example: single adult at 160% FPL, $1,444 in
     monthly pre-tax income. Under PPACA:
      $64 in monthly premiums
      Copays could include
        o $20 per office visit
        o $10, $25 and $40 per prescription
      Contrast: most CHIP programs impose no charges or
       minimal charges at this income level. Same is true of
       longstanding state programs for adults at this level.


23
Basic health program (BHP)
    Covered individuals
      Income at or below 200% FPL
      Ineligible for Medicaid or CHIP because of
         o Income; or
         o Legalization of immigration status during the past 5 years.
    State
      Contracts with health plans to provide coverage at least as
       generous as in the exchange
      Receives 95% of what the federal government would have spent
       in subsidies
    State could use BHP to provide Medicaid look-alike
     coverage
      Federal dollars typically much higher than Medicaid pmpm
      Could use excess to raise reimbursement, improve access
        o Equity and targeting issues

24
Conclusion
    No matter what, ACA is likely to
     dramatically increase coverage and
     access to care
    The amount of that increase will depend,
     in significant part, on state policy
     decisions
    Maryland can be a national leader

25

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Enrollment md hcrcc_8.31.10

  • 1. Maximizing and simplifying enrollment: options for Maryland Health Care Reform Coordinating Council Entry into Coverage Workgroup August 31, 2010 Stan Dorn, Senior Fellow The Urban Institute Washington, DC
  • 2. Overview  The importance of proactive strategies to enroll the eligible uninsured  Success stories from other state and federal programs  Policy options for Maryland 2
  • 3. Part I The importance of proactive strategies to maximize enrollment
  • 4. If you build it, will they come? Not necessarily…  Recent federal history  High-risk pools  COBRA subsidies  HCTC  Older federal history  CHIP – after 5 years, only 60% of eligible children were enrolled  MSP – decades after statutory enactment, less than 33% of eligible seniors enroll  State history  Maine 4
  • 5. Part II Success stories from other state and federal programs
  • 6. The Massachusetts story Findings from a SHARE grant funded by the Robert Wood Johnson Foundation 6
  • 7. Key facts  Only 2.6 percent uninsurance by 2008  But it’s not just the mandate and the subsidies!  Consumers seamlessly enrolled into 4 separate programs. 1 form and 1 eligibility process applied to all programs.  Roughly 1 in 4 newly insured qualified for Commonwealth Care based on eligibility records from the state’s free care pool—no applications needed!  More than half of all successful applications were filled out by CBOs and providers, not by consumers. o No DSH money for serving a patient unless application process completed o The ―Virtual Gateway‖ – on-line application system open to trained staff of CBOs and providers 7
  • 9. LaCHIP renewals for children  In December 2009:  Procedural terminations – 0.7 %  Total terminations – 4.6%  By contrast:  In some states, 50 percent of children lose coverage at renewal  40 percent of eligible, uninsured children nationally received Medicaid or CHIP the prior year  Why? Coverage ends unless renewal forms are completed  LA eligibility determined based on  Data from state-accessible records  Where income is stable, administrative renewal  Proactive telephone calls  Traditional form completion is a last resort  In September 2009, forms were required for only 3% of LA children renewing coverage 9
  • 10. The Medicare Part D story  1/2006, Part D coverage of prescription drugs began  Included low-income subsidies (LIS)  By 6/16/06, 74% of eligible beneficiaries received LIS  Most qualified based on data matches with state Medicaid programs or SSA  People who received Medicaid last year automatically get LIS this year  Now, 80% of eligible beneficiaries receive LIS 10
  • 11. Lessons learned  Affordability is key  The less consumers must do to enroll, the more will enroll  Base eligibility on data, without requiring the completion of traditional application forms  When forms are required, provide intensive application assistance, so consumers don’t need to complete paperwork 11
  • 12. Why is paperwork such an issue? Human nature. Percentage of eligible workers who participate in tax-advantaged retirement accounts 90% 33% 10% Independent enrollment in Firms where new hires Firms where new hires go IRA enroll in 401(k) only after into 401(k) UNLESS they completing a form complete an opt-out form Sources: Etheredge, 2003; EBRI, 2005; Laibson (NBER), 2005. 12
  • 13. Part III Policy options for Maryland
  • 14. Highlights of the Affordable Care Act (ACA): A quick review  Medicaid to 138% of the federal poverty level (FPL)  Modified Adjusted Gross income (MAGI)  Rules for newly eligible adults o Definition: would not have qualified under state rules as of 12/1/09 o Highly enhanced federal medical assistance percentage (FMAP) – 100% for 3 years, declining to 90% by 2020 o ―Benchmark benefits‖  Standard FMAP and benefits for other adults  Subsidies in the exchange up to 400% FPL  OOP cost-sharing subsidies to 250% FPL  Integrated eligibility system for Medicaid, CHIP and exchange – 1 application form for all subsidies  Individual mandate for coverage 14
  • 15. Consumer assistance, including facilitated enrollment  Consumer assistance grants for 2010  Patient navigators in exchange  Federal funding through 12/31/14  Starting in 1/15, surcharge insurers?  Key questions: o How much funding for navigators? Can foundations help? o Who are the navigators? CBOs, legal services programs o What do navigators do? Fill out applications, via ―virtual gateway‖  Outstationed EWs probably less effective  Follow MA precedent in terms of safety net providers?  New importance of consumer advice  Penalties for going without coverage 15  Tax consequences for excess subsidies
  • 16. Basing eligibility on income data  Subsidies in exchange  Based on prior-year tax data  Chance to supplement at application  Year-end reconciliation  Medicaid  Initial determination based on income at time application is processed - challenge  Post-application changes? Not clear, under PPACA  What happens if application submitted to exchange? 16
  • 17. Possible approach to Medicaid  If prior-year tax data show Medicaid eligibility, consumer automatically receives Medicaid  If after a certain point in the calendar year, could supplement with more recent data (new hires, quarterly earnings)  If prior-year tax data show ineligible for Medicaid, receive an opportunity to apply for Medicaid using traditional procedures, including pay stubs, etc. Like Express Lane Eligibility.  In the meantime, subsidies in the exchange  Incidental advantages  Lower administrative costs for eligibility determination. 50% FMAP.  Less risk of erroneous eligibility determinations, federal sanctions.  Depends on CMS allowing this approach – likely, not certain 17
  • 18. Limit application forms to questions relevant to eligibility  Need to distinguish the newly eligible from others  Claim enhanced FMAP  Provide benchmark benefits  Requires information irrelevant to eligibility  Parents o Assets o Deprivation  Childless adults and empty nesters o Disability o Pregnancy  Solutions  To claim FMAP, use sampling (assuming CMS approval)  Provide standard Medicaid benefits as ―Secretary-approved‖ benchmark coverage, Social Security Act Section 1937(b)(1)(D) 18
  • 19. Asking for help without completing a traditional form  Eligibility is determined based on data when an individual applies ―by requesting a determination of eligibility and authorizing disclosure of … information [described in Social Security Act Sections 1137, 453(i), and 1942(a)] … to applicable State health coverage subsidy programs for purposes of determining and establishing eligibility.‖ PPACA Section 1413(c)(2)(B)(ii)(II)  Precedents  EITC amount  CA income tax  Medicare Parts B and D – automatic, without request 19
  • 20. Process  Consumer requests determination of eligibility based on disclosure of data  State and exchange gather data.  SSA Section 1137 – IEVS, SAVE  453(i) – National Directory of New Hires  1902(a) – public benefit programs, new hires data, state tax records, Medicaid TPL data showing private coverage, vital statistics records in any state  Data establish:  Medicaid eligibility  Eligibility for subsidies in exchange, with right of consumer to seek Medicaid determination based on more recent information 20
  • 21. Basing eligibility on receipt of other benefits  Express Lane Eligibility (ELE) remains an option for children  Can seek 1115 waiver for adults  Logical if other program’s eligibility is below 138% FPL. For example:  SNAP (130% gross income)  TANF ($565/month, less deductions)  Depends on CMS approval – likely, not certain 21
  • 22. Integrated eligibility determination  Basic model  Exchange, Medicaid, and CHIP compile a data warehouse for each applicant, determine eligibility ―behind the scenes‖  Medicaid needs better eligibility IT  Will CMS develop modules?  Will CMS provide sufficient Medicaid funding?  Can administrative funding for the exchange help with Medicaid?  Exchange can contract with Medicaid to determine eligibility for subsidies in exchange  Massachusetts model  Must meet HHS ―requirements ensuring reduced administrative costs, eligibility errors, and disruptions in coverage‖  Single, statewide office when data establishes eligibility  Link to local social service offices when households may qualify for other benefits 22
  • 23. But can low-income adults afford coverage in the exchange? Will they enroll? Will they seek care?  Subsidy levels lower than almost any state program serving low-income adults  Example: single adult at 160% FPL, $1,444 in monthly pre-tax income. Under PPACA:  $64 in monthly premiums  Copays could include o $20 per office visit o $10, $25 and $40 per prescription  Contrast: most CHIP programs impose no charges or minimal charges at this income level. Same is true of longstanding state programs for adults at this level. 23
  • 24. Basic health program (BHP)  Covered individuals  Income at or below 200% FPL  Ineligible for Medicaid or CHIP because of o Income; or o Legalization of immigration status during the past 5 years.  State  Contracts with health plans to provide coverage at least as generous as in the exchange  Receives 95% of what the federal government would have spent in subsidies  State could use BHP to provide Medicaid look-alike coverage  Federal dollars typically much higher than Medicaid pmpm  Could use excess to raise reimbursement, improve access o Equity and targeting issues 24
  • 25. Conclusion  No matter what, ACA is likely to dramatically increase coverage and access to care  The amount of that increase will depend, in significant part, on state policy decisions  Maryland can be a national leader 25