Psst, governor: consultant hired by Health Reform Task Force suggests giving Medicaid beneficiaries more time to respond to renewals | Arkansas Blog

Wednesday, August 19, 2015

Psst, governor: consultant hired by Health Reform Task Force suggests giving Medicaid beneficiaries more time to respond to renewals

Posted By on Wed, Aug 19, 2015 at 1:02 PM

click to enlarge HUTCHINSON: Won't listen to state's own consultant.
  • HUTCHINSON: Won't listen to state's own consultant.
Gov. Asa Hutchinson said yesterday that everything was hunky-dory with the 10-day response deadline for Medicaid beneficiaries going through the state’s troubled eligibility verification and renewal process. The policy has helped contribute to a disastrous mess: tens of thousands of eligible Medicaid beneficiaries kicked off their coverage during a chaotic and confusing process, and a bureaucratic nightmare that state agencies are still trying to cope with. However, Hutchinson argued, the policy should continue because it was “the status quo.”

The state’s own consultant, however, disagrees. The Stephen Group (TSG), the private consulting firm hired by the Legislative Health Reform Task Force, made the same case in their recent report that we’ve been making for weeks (okay, they were a little more polite about it). The 10-day response policy was questionable to begin with, TSG concluded, and certainly at this point, it makes sense to revisit the policy.

First off, TSG makes note of a problem we’ve also brought up. Federal regs require 30 days for renewal – since this income verification is what Arkansas is doing in lieu of the required renewal process, questions arise about whether the state is compliance with federal rules.

In any case, TSG notes, it’s clear that the state could choose to give beneficiaries more time to respond: 

Some of the relevant federal rules and guidelines have had enough ambiguity to stimulate a review.

Arkansas DHS state officials, as well as TSG, have asked CMS for clarification of the federal regulation regarding time required to be given to beneficiaries when they need to revalidate their income qualifications. Whatever the regulation review comes up with, it is already clear by reviewing the processes other states are using and initial exchange with CMS officials that Arkansas almost certainly has the option to extend the verification notice time periods.

What about the merits of the policy? TSG notes the particular circumstances Arkansas is dealing with right now and questions whether a longer response time would make more sense.

Longer Response Time: Given that Arkansas is now resolving a backlog built up over a year, and considering that the state must support many of these renewal cases with individual case worker and call center support, and considering that a significant portion of the new Medicaid clients are new to these processes and procedures there seems to be a reasonable argument for significantly extending the renewal response time – at least until the backlog is resolved.

TSG also looks at slowing down the pace of the income-verification letters as the kinks get worked out:

Slower Pace of Renewal Backlog Recovery: A second alternative would be to slow the pace of renewals so that there would be more adequate DHS resources to deal with individual case issues as they arise. This however would likely be a less successful standalone solution than simply providing more response time to the beneficiaries as proposed above. A combination of these two adjustments would probably completely alleviate the current problems for legitimate beneficiaries and the DHS overload. We have already informally confirmed with CMS that changes along these lines should not jeopardize the federal waiver under which this renewal delay is operating, although that should be explicitly confirmed if the state chooses to make a change to their process.

Another idea TSG brings up is processing renewals and income verifications via the renewal process for SNAP (food stamp) beneficiaries. DHS did this when people first signed up for the private option: if they had already verified income for SNAP beneficiaries, they could use that same information to determine private option eligibility. It seems like a no-brainer to do that again during this renewal process. In fact, one could even imagine a scenario in which beneficiaries in both programs simply go through one single renewal-and-eligibility-verification process for SNAP and the private option, rather than dealing with the hassle and bureaucratic complications of doing it twice. I asked DHS a while back why they weren’t using SNAP eligibility during this renewal process for the private option; I never got a response. Here’s TSG:

Ex Parte Based Eligibility: SNAP eligibility can be used to meet Medicaid eligibility requirements. Although SNAP eligibility and renewal processes are different, the differences in aggregate result in an eligibility 58 scrub that is generally more stringent than current Medicaid requirements, so using SNAP information does not degrade the quality of eligibility review, since both require similar documentation.

Finally, TSG questions (as others have) whether the state really needs to flag and verify people whose income has gone down (for example, low-income parents who shift Medicaid categories after their income goes down or beneficiaries whose wage data shows no income at all). Here’s TSG:

Decreased Income: Even though it might require federal agreement, it would also be reasonable to not disqualify beneficiaries whose reported income has gone down. In those cases the evidence at hand indicates that the beneficiary would still likely qualify for Medicaid. The policy change should include a review process to bring the income being used for services determination into line with current reality, but without the intermediate step of disqualifying the beneficiary for all services because the beneficiary didn’t document their decreased income.

Most likely, any service level adjustment should not be made until the new, lower income is verified, but it is questionable to disqualify someone because their income has decreased without notification to DHS. Over time, this policy change would probably save administrative effort and money for those who will almost surely continue to remain eligible.

The state is paying TSG at least one million dollars. They have some good ideas! Maybe the governor should listen. 

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