CMS’ Duals Clarifications Enable State Innovation

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March 02, 2015

Improving care at a manageable cost for people who are dually-eligible for Medicare and Medicaid is the heart of the latest demonstration initiatives from the Centers for Medicare and Medicaid Services (CMS). This demonstration is titled “Enrollment and Retention Flexibilities to Better Serve Medicare-Eligible Medicaid Enrollees”. Specifically, CMS expands the demonstration to include a broad range of dually-eligible Medicare/Medicaid recipients under existing authorities, not just the fully-eligible populations comprising the current 13 state demonstrations. Through delivery system and financing changes, CMS seeks to achieve improved outcomes for beneficiaries receiving medical and long-term care services.

This recently released bulletin suggests ways for states to be creative and efficient about how they assess newly Medicare eligible members who are already in Medicaid. It stipulates that the state Medicaid agency must assess whether the individuals are eligible for any other category of Medicaid coverage before terminating or reducing the scope of their current coverage due to their eligibility for Medicare. The impact to states is that many of these beneficiaries will continue to qualify for full Medicaid benefits or be eligible for Medicare Savings Programs (MSPs). 

Simplifying MSP Redeterminations

This CMS bulletin empowers states to streamline their eligibility determination and renewal processes. It emphasizes aligning with the intent of the Affordable Care Act, to rely on existing data sources before reaching out to consumers for additional information. It offers broad flexibility in income and asset verification for newly-eligible Medicare members to ensure their continuity of coverage and reduce the burdens on both beneficiaries and state agencies.  Recommended efficiencies include:

  • Align the Redetermination Schedule: states can align the redetermination schedule for MSPs that are used for Modified Adjusted Gross Income (MAGI) eligible populations, which rely on an annual redetermination to avoid coverage lapses. For states, this minimizes administrative burdens related to closing and re-opening cases due to common fluctuations in income for MSP-eligible populations.
  • Use Available Data Sources: states can rely on existing automated data sources such as the Federal Data Hub and other state or commercial data available through electronic data searches. 
  • Eliminate Burdensome Processes:  states can eliminate in-person interviews, the tedious process of getting renewal forms signed and filling out new applications, while using prepopulated forms where additional or updated information is needed from the beneficiary.
  • Implement Automatic Renewals: the bulletin suggests using automatic renewals and another option to simplify the process, which can be implemented unless the beneficiary provides changed information.

Using these strategies, states can reduce the burden on eligible beneficiaries and increase retention rates. They’ll also conserve agency time and administrative resources, while ensuring program integrity is maintained. In Louisiana, the implementation of administrative efficiencies resulted in annual savings of more than $1 million.

Whether a state opts for self-attestation or reliance on automated eligibility verification, bringing together data from multiple federal, state, and commercial sources in a single location will make significant change possible in programs. This allows Medicaid agencies to have a greater level of confidence that those receiving benefits are entitled to them and that the Medicaid program is acting as the payer of last resort.  Achieving the potential administrative savings and improved beneficiary engagement will require states to work with a proven partner to transform this policy opportunity into cost-effective action, but the CMS bulletin opens the door to state innovation.

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