The silver lining in the wake of Medicaid coverage terminations | Arkansas Blog

Tuesday, August 11, 2015

The silver lining in the wake of Medicaid coverage terminations

Posted By on Tue, Aug 11, 2015 at 8:15 AM

This blog has obviously been critical of the decision-making process that led to 47,000 Medicaid beneficiaries – many or most of whom are in fact Medicaid eligible – facing termination of their health insurance coverage.

But it’s also important to get the word out to Medicaid beneficiaries: a cancellation letter is not the end of the story.

Beneficiaries can send in their information at any time during the process: DHS is now allowing 10 days of additional processing time beyond the 10-day deadline, so beneficiaries may have more time before actually receiving a cancellation letter than the income-verification letters state. Meanwhile, once the cancellation letter is sent, it will take at least 10 days before the coverage actually ends – and it won’t end until the first of the following month. DHS officials say that if they receive the relevant documentation at any step of the way, the responses will be promptly processed and coverage will not be terminated (many may then require further followup from DHS caseworkers). Obviously, some beneficiaries may have some mistrust when it comes to DHS promptly dealing with their responses, but they should nevertheless send in their documentation as soon as possible in order to maintain, or reinstate, coverage.

If their coverage has already been terminated for failure to respond, beneficiaries have 90 days (guaranteed by federal law) to send in the relevant income verification and, if eligible, have coverage reinstated without having to re-apply. Again, DHS officials have said that if they receive the relevant documentation during that 90-day window, the responses will be promptly processed. To be clear: this 90-day window is not an appeal, a much more complicated process that would typically only make sense if a beneficiary was actually found ineligible and wants to contest the finding (the governor misspoke and called it an "appeal" last week and some DHS communications to beneficiaries have mentioned appeals but not the 90-day window). This is simply more time to provide the information and, in theory, be quickly re-enrolled back into the program.  

"The good news is, with this program there is plenty of opportunity to come back," said DHS Director John Selig.  

Unfortunately, the income verification letters and cancellation notices have not been clear about any of this (for example, the cancellation letters that some beneficiaries have shared with the Times mention nothing about the 90-day window...I've asked DHS whether they've revised or updated that). Hopefully insurance companies, brokers, and community organizations can help pick the slack on outreach, communicating with beneficiaries about their options amidst the chaos and confusion of this renewal process. 

What information do beneficiaries need to submit? See here for examples of proof of income — employed beneficiaries need to provide multiple pay stubs from the previous month, a letter from an employer, or other proof; self-employed beneficiaries need to provide a tax return; unemployed beneficiaries need to provide a signed letter explaining they they have no income. DHS officials suggested that beneficiaries who have received terminations or cancellation notices go to the county office in person to provide income verification information or mail it in to the location listed on the notice.

I think there's reason to be hopeful that most of the eligible beneficiaries facing coverage terminations will get re-enrolled, if not before the termination goes through, at least within the 90-day window that follows termination. DHS officials have stated that beneficiaries who manage this will have retroactive coverage. (This involves more hassle and red tape, but beneficiaries can also re-apply even after the 90-day window — however, in this scenario, they wouldn't get retroactive coverage.) Again, a lot of this will come down to other stakeholders doing the outreach work that really should have started months ago — it's even possible all of the controversy and attention will help to get the word out. 

To be clear, none of this changes the fact that this mess has been disruptive to the lives of low-income Arkansans and that interruptions in coverage can cause problems in access to care with dire consequences. But there is still the chance — despite unforced policy errors in the implementation of the renewal process and a stubborn refusal to change course — that this will turn out to be something closer to a glitch than a disaster. 

I do have a question for the governor. State officials keep pointing to all of the above and arguing that the de facto window is actually significantly longer than 10 days. And fair enough. But if we're giving people more this point, why not just directly give people sufficient time to respond to begin with, rather than clinging to a policy bound to result in waves of cancellations for eligible beneficiaries?  

Why not give DHS caseworkers and stakeholders time to do proper outreach and get responses? Wouldn't it make more sense to avoid the chaos and confusion of plan cancellations, breaks in coverage, etc.? Why add the additional bureaucratic hoops or rushed cancellations? Why stick with a system doomed to end up with people getting lost in the shuffle? What good has the 10-day deadline accomplished? 


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