In a letter to the Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure on a Notice of Proposed Rulemaking outlining benefit and payment parameters for qualified health plans offered on health insurance exchanges, MACPAC offered comments on opportunities to improve access to and enrollment in Medicaid and the State Children’s Health Insurance Program (CHIP).
A recent MACPAC analysis of Medicaid and CHIP beneficiaries who lost coverage in 2018 found that only 3 percent of these beneficiaries enrolled in exchange coverage within a year, and when they did, most beneficiaries experienced a gap in coverage. MACPAC also found that adults with gaps in coverage are more likely to have a substantial increase in potentially avoidable hospital use after re-enrolling in Medicaid. This suggests that individuals with gaps between Medicaid and exchange coverage could also experience adverse health effects.
The proposed rule includes several provisions intended to smooth coverage transitions, which the Commission supports. However, the Commission pointed out that these changes alone are not sufficient to ensure seamless coverage transitions. The upcoming unwinding of the Medicaid continuous coverage requirements provides an opportunity to learn more about effective strategies for helping beneficiaries move from Medicaid to exchange coverage without gaps. The Commission supports efforts to provide more time for individuals losing Medicaid or CHIP to enroll in exchange coverage.
The Commission encouraged CMS to consider other steps that it can take to reduce gaps and is concerned that beneficiaries submitting Medicaid or CHIP renewal forms must also submit new exchange applications. Given the magnitude of the challenges that Medicaid and CHIP beneficiaries face in moving seamlessly to exchange coverage, more should be done to align eligibility and enrollment policies with the statutory requirements for streamlined coverage. As a first step to addressing these challenges, CMS should evaluate coverage transitions and make data publicly available to enable further analyses.
During the unwinding of the Medicaid continuous coverage requirements, it will be particularly important to evaluate how these transitions are working and make data publicly available on a timely basis. The recently passed Consolidated Appropriations Act, 2023 (P.L. 117-73) adds new requirements for states to report information on transfers between Medicaid and exchange coverage beginning April 1, 2023. “As a result, it is important that CMS work closely with states to share data about coverage transitions to help inform these important monitoring efforts,” the letter concludes.
