Within the COVID-19 public health emergency (PHE), Congress enacted the Families First Coronavirus Act (FFCRA), which required states to keep members in Medicaid continuously enrolled through the end of each month until the PHE was removed. On December 29, 2022, Congress set into law an end to the continuous enrollment provision on March 31, 2023. States will have 12 months to initiate redeterminations of Medicaid eligibility for all Medicaid enrollees.
This will impact roughly 12 million dually eligible members and may result in millions of highly complex Medicare Advantage (MA) members losing their Medicaid coverage and Dual Eligibility Special Needs Plans (D-SNP) eligibility, which will ultimately delay needed access, treatment and care. The most common reason Medicaid eligibility will be lost is due to administrative reasons, not due to the beneficiary failing to continue meeting state Medicaid eligibility requirements.
Most Medicare Advantage plans have some degree of limited process and education in place regarding D-SNP members’ Medicaid eligibility redeterminations. But most plans do not have enough staff or robust enough staffing and support in place to ensure this Medicaid reality does not pervade their Medicare Advantage plans. Without strong member engagement and support, this will have a large impact on D-SNP plans and non-SNP plans with large numbers of Dual Eligible members.
A Checklist for Providing D-SNP Coverage After March 31
Plans who proactively invest in highly-focused member engagement and support specifically focused on this high-impact issue will insulate their most precious corporate asset – their members – and preserve their Star Ratings at the same time.
The following is a checklist for Medicare Advantage plans to ensure continuity of coverage for dual-eligible members through the Medicaid Redetermination process:
D-SNPs can continue to provide care for members that lose coverage but are expected to meet Medicaid eligibility criteria within six months. D-SNPs are expected to provide members with written notice within 10 days of learning of the loss of Medicaid eligibility. The D-SNP plan will not be held financially responsible for covering what the state was supposed to cover from the Medicaid funds.
During this period, you should:
Validate the existence and criteria for your policy regarding the grace period upon loss of Medicaid eligibility prior disenrolling member for your D-SNP.
Ensure staff is trained on the policy and procedures in place to support members through the redetermination process.
Ensure systems are set up to not trigger auto-disenrollment upon loss of Medicaid eligibility. Instead, seek approval to pend disenrollment during the grace period and develop 2023 policies and procedures.
Ensure policy is applied uniformly to all members that are similarly situated.
Create and accelerate detailed timeline for execution of writing policies, training staff, communicating (internally, with members, with providers, and with vendors too), and adjusting any system configurations as needed.
Work with your state Medicaid department to coordinate notification of members receiving renewal notices and ex-parte processes that will impact your members.
Be proactive and begin informing all D-SNP members of the redetermination process and what they need to do to remain eligible for Medicaid and enrolled in their Medicare Advantage D-SNP. Remind them how much you care that they do not have to change plans or lose access to care and treatment.
Offer members assistance with completing the forms or identify and refer members to any state-run assistance programs.
Use multiple channels to inform members of this important process with their state Medicaid agency and use every tool at your disposal and all recent Federal Communications Commission flexibilities, including mail, email, text and telephone outreach.
Train all member-facing staff including customer service, care management, sales, agents, brokers, concierge and vendors to ask about this issue when members call in. Validate whether they received communication from the state, their Medicaid plan or your MA plan, or if they may have read or heard about redetermination in the news. Confirm they understand what it means, what they should do and when they should do it to ensure their healthcare coverage remains in place.
Train staff to assist members in gathering the best available evidence needed for redetermination.
Train staff to assist members in understanding all options and completing the redetermination.
Train staff regarding special enrollment periods and how to assist members who will be losing eligibility with enrollment to another plan if possible.
Create a centralized repository for all related materials, including copies of State and plan letters, news articles, policies and procedures, and call scripts.
Create a one-page cheat sheet that can be used with internal and external partners, highlighting the key issues and messages.
Work with providers to help with updating member contact information and making sure renewal forms are sent to the correct address.
Work with providers and vendors to help aid with notifying members during appointments and engagements.
Our Expert Advisory Services team has extensive experience performing and supporting Medicaid eligibility redeterminations within Medicaid and Medicare Advantage plans. If you need help with these important activities, email us at email@example.com more information.