The agency issued an informational bulletin last month reminding states of federal renewal requirements and available flexibilities to ensure continued coverage for individuals eligible for HCBS through Medicaid. This bulletin continues CMS’ efforts to minimize coverage gaps, particularly during and after the public health emergency unwinding process, and to ensure eligible individuals retain or are re-enrolled in Medicaid.

For home care providers, a renewed government effort to clean up HCBS protocols – like in the Medicaid Access Rule – helps keep patients on census and enables better care geared toward value.

Following the end of the COVID-19 public health emergency in 2023, states restarted regular eligibility renewals for those enrolled in Medicaid and Children’s Health Insurance Program (CHIP) coverage, a process often called “Medicaid unwinding.” This included renewals for individuals who needed assistance with daily living activities.

As states restarted renewals, many individuals faced challenges renewing their coverage because of administrative barriers. States experienced unprecedented renewals, resulting in backlogs in some areas, according to CMS. Many states also experienced system and compliance issues, which the agency directed them to address.

Throughout unwinding, CMS has strongly urged states to adopt federal strategies that make it easier for eligible individuals to renew Medicaid. On Aug. 19, CMS issued guidance outlining strategies states can adopt to help eligible individuals receiving HCBS retain their coverage.

These strategies are designed to simplify eligibility and enrollment processes, maximize the use of available and accurate information, and reduce the burden on individuals and state Medicaid agencies, allowing eligible individuals receiving HCBS to maintain their coverage, independence and engagement in community life.

In accordance with the guidelines, states are required to regularly review Medicaid eligibility, in line with federal regulations, to ensure continued access to HCBS for those who are still eligible. Some of the current flexibilities that help maintain coverage and access to HCBS include collaborating with local agencies to improve “no wrong door” systems for assisting individuals in maintaining Medicaid enrollment. States can also choose to exclude some or all countable income or resources when renewing coverage for individuals receiving HCBS for a specific period of time.

No wrong door means consumers can enter any service with the expectation that if it is not appropriate for them, they will receive assistance in accessing the most relevant services.

“During the COVID-19 pandemic, the Families First Coronavirus Response Act mandated that states maintain continuous enrollment in Medicaid for people,” Home Assist Health President and CEO Sara Wilson told Home Health Care News. “However, this continuous eligibility requirement ended with the public health emergency, leading to various challenges for states transitioning out of it. These challenges included staffing shortages, training needs, outdated operating systems and communication issues. As a result, procedural errors occurred, leading to wrongful termination of participants and creating gaps in care. These gaps can pose increased financial and health risks for the individuals affected.”

Phoenix-based Home Assist Health is a nonprofit home care provider.

“HCBS enables individuals to age and recover in the comfort of their homes,” Wilson said. “Continuity in these programs is crucial in upholding this right, guaranteeing access to care, and safeguarding the health and well-being of participants.”

During the renewal process, eligibility must first be confirmed using the state’s asset verification system without requiring additional information from the individual (ex parte). Ex parte renewals are one of the most vital tools for states to keep eligible people covered and prevent terminations due to red tape, as demonstrated by CMS data last year.

“Ensuring people have access to comprehensive, high-quality health coverage is a top priority for the Biden-Harris Administration,” a CMS spokesperson told HHCN. “That is why we have urged states to take up every tool CMS made available to help eligible people renew coverage and to protect them from becoming disenrolled due to red tape as states conducted Medicaid and CHIP renewals following the end of the Medicaid continuous enrollment condition in 2023, a process often called ‘Medicaid unwinding.’

As the unwinding process demonstrated, states’ choices have real consequences for eligible people’ ability to maintain coverage during Medicaid and CHIP renewals. While states must follow federal Medicaid and CHIP requirements, they have broad flexibility within these requirements when administering their programs. States can take steps to help eligible people, including people who receive HCBS, stay covered. These steps include improving ex parte rates, taking up CMS’ strategies that make renewals easier to navigate (including strategies outlined in our recent guidance), and addressing other barriers to coverage.”

CMS issued guidance to help states adopt strategies to improve ex parte rates. With these efforts, Medicaid and CHIP ex parte rates doubled nationwide from about 25% in April 2023 to 50% of renewals due in May 2024.

The agency also recently finalized a rule that builds on critical lessons learned during Medicaid unwinding by streamlining and simplifying how people enroll in and renew Medicaid and CHIP from now on. These improvements will reportedly help millions of eligible people with HCBS enroll in and maintain Medicaid coverage moving forward.

For example, for those eligible for Medicaid based on disability, the rule prohibits states from requiring in-person interviews, requires states to provide a reasonable period for applicants to return information and documentation, and requires states to accept renewals in multiple ways, such as online, by phone, mail or in person.

Regarding compliance with renewal requirements, the guidance issued on Sept. 20 details steps that all states must take to ensure their compliance with federal renewal requirements for Medicaid and CHIP and avoid further action by CMS.

States must assess their compliance with federal requirements, submit the results to CMS, and submit a plan to resolve any issues. Building on insights from the unwinding period, this action will help ensure state compliance with key federal renewal requirements, safeguarding individuals’ ability to renew their health coverage and strengthening the integrity of the Medicaid program, according to CMS.

“HCBS is crucial for long-term care services, allowing participants to choose home-based care while promoting individual choice and control,” Wilson said. “Home care providers should work with their state Medicaid authorities to support this transition process for members.”

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