Looking Ahead: A Timeline of State Policy & Operational Considerations if Federal CHIP Funding Ends for States

Without Congressional action, federal funding for the Children’s Health Insurance Program (CHIP) is due to end in September 2017. The National Academy for State Health Policy (NASHP) created this infographic to highlight the main policy and operational issues that would need to be considered and addressed in states with separate CHIP programs if future federal funding for CHIP remains uncertain in the coming months.

States with separate CHIP programs can limit enrollment if federal funds are not available, and this timeline reflects the key issues for 42 states with these types of CHIP programs. However, Medicaid expansion CHIP programs are required through the Affordable Care Act’s (ACA) maintenance of effort (MOE) provision to maintain eligibility levels for children through 2019, even if federal CHIP funding ends; they would receive the regular Medicaid match rate for children enrolled in these programs.*

Infographic: A Timeline for States
Printable version of Timeline.
Blog: Planning Now: State Policy and Operational Considerations if Federal CHIP Funding Ends

Supported by the David and Lucile Packard Foundation. 

A Timeline for state health policy and operational considerations if CHIP funding ends.

Color key below chart.

2016

Month

January

February

March

April

May

June

July

August

September

October

November

December

Budgetary Cycle

Budgeting for FY2017 and FY2018, depending on state budget cycles (Making assumptions re: federal funding for programs)

 

 

 

 

 

States with Biennial budgets may need to begin an amendment process to address major budgetary changes

Implementing State Budget Contingency Plans

Begin internal planning for systems changes and care transitions

 

 

 

Begin finalizing FY2017 budgets

 

 

 

 

 

 

 

 

 

 

 

 

 

Statutory Change Cycle

 

 

 

 

 

 

 

Develop transition plans to ensure continuity of care

 

Begin internal planning for systems changes and care transitions

Develop transition plans to ensure continuity of care

 

 

Draft & Pass State Legislation

Enrollment Policy and Practices

 

 

 

Consider other coverage options available

 

 

 

 

Begin internal planning for systems changes and care transitions

 

 

 

Minimize Disruption of Care

 

 

 

State by State review of EHB vs. CHIP (identify services children may lose in transition)

 

 

 

Develop transition plans to ensure continuity of care

 

Develop transition plans to ensure continuity of care

Begin internal planning for systems changes and care transitions

 

 

 

Contractual Obligations

 

 

 

 

 

 

 

 

Begin internal planning for systems changes and care transitions

 

 

 

Systems Changes

 

 

 

 

 

 

 

 

Begin internal planning for systems changes and care transitions

 

 

 

Exchange Plan Cycle

 

 

 

QHPs set rates for 2017

 

 

 

 

Begin internal planning for systems changes and care transitions

Consider a pediatric benefit in exchanges

 

 

2017

Month

January

February

March

April

May

June

July

August

September

October

November

December

Budgetary Cycle

Begin finalizing FY2018 budgets

 

 

 

 

 

 

 

 

 

 

 

Review agency staffing needs

Start of Many State Fiscal Years

Budgeting for FY2018 and FY2019, depending on state budget cycles (Making assumptions re: federal funding for programs)

 

 

 

 

 

 

 

 

 

Current Authorization for Federal CHIP Funding Ends

Statutory Change Cycle

Ideal time for Federal Government decision on CHIP funding

(Latest possible date for any state law changes)

State law should include a transition plan

 

Assess current state policies, regulations and laws and make changes to regulations (4-5 mo.)

 

 

 

State Laws take effect unless stated otherwise

State Transition plan can begin

 

 

Current Authorization for Federal CHIP Funding Ends

 

 

 

Enrollment Policy and Practices

 

Develop comprehensive communications plan

Work with CMS on the clarification of maintenance of effort (MOE) and address continuous eligibility

 

Develop and submit appropriate information to CMS: SPA, waiver, financial plan (dependent upon CMS timeline – could take 9 months or longer)

Draft Notices to Families

 

Freeze CHIP Enrollment (6 months from end of allocation)

Send notices to families

(3 mo. from end of program/ allotment)

 

Current Authorization for Federal CHIP Funding Ends

Transition Enrollees (will depend on when allotment ends)

 

 

 

Minimize Disruption of Care

 

Develop comprehensive communications plan

 

Identify children receiving long-term treatments

Identify children receiving long-term treatments

Engage provider and health plans on payment issues in advance of losing funds

Implement communications plans with health providers, plans, and stakeholders

 

 

Current Authorization for Federal CHIP Funding Ends

 

 

Contractual Obligations

 

Develop comprehensive communications plan

Evaluate all system contracts (e.g. MMIS, etc.) to identify possible changes needed

 

Address Call Center Contracts (likely increased demand as notices sent and to set end date for service)

Modify existing or future managed care or third party administrator contracts

Modify existing or future managed care or third party administrator contracts

Modify existing or future managed care or third party administrator contracts

 

 

Current Authorization for Federal CHIP Funding Ends

Final IBNR** and Payment Appeals

Final IBNR and Payment Appeals

Systems Changes

 

Develop comprehensive communications plan

Review and identify needed changes for systems

Review and alter RFPs, contracts for system upgrades

 

Implement MMIS, eligibility system changes

 

 

 

 

 

Current Authorization for Federal CHIP Funding Ends

Develop manual workaround during the transition period

  

Consider interagency agreements and data sharing obligations necessary to transition children to other coverage sources

 

 

 

Exchange Plan Cycle

Engage QHPs with Medicaid/CHIP early to inform rate setting and to plan a pediatric benefit

Review existing and establish new transitions rules/policies for Medicaid and exchanges

 

 

 

 

 

 

 

 

 

 

QHPs set rates for 2018

Coordinate with marketplace leadership to transition enrollees

Take initial steps to implement a pediatric benefit to be offered by QHPs for 2018

Current Authorization for Federal CHIP Funding Ends

Open Enrollment for Exchanges

 

2018

Month

January

February

March

April

May

June

July

August

September

October

November

December

Budgetary Cycle

 

 

 

 

 

 

 

 

 

 

 

 

Statutory Change Cycle

 

 

 

 

 

 

 

 

 

 

 

 

Enrollment Policy and Practices

Transition Enrollees (will depend on when allotment ends)

Transition Enrollees (will depend on when allotment ends)

 

 

 

 

 

 

 

 

 

 

Minimize Disruption of Care

 

 

 

 

 

 

 

 

 

 

 

 

Contractual Obligations

Final IBNR** and Payment Appeals

Final IBNR and Payment Appeals

Final IBNR and Payment Appeals

Final IBNR and Payment Appeals

Final IBNR and Payment Appeals

 

 

 

 

 

 

 

Systems Changes

 

 

 

 

 

 

 

 

 

 

 

 

Exchange Plan Cycle

Open Enrollment for Exchanges

 

 

 

 

 

 

 

 

 

 

 

2019

Month

January

February

March

April

May

June

July

August

September

October

November

December

Budgetary Cycle

 

 

 

 

 

 

 

 

 

End of Federal Maintenance of Effort (MOE) Requirement for children

 

 

Statutory Change Cycle

 

 

 

 

 

 

 

 

 

End of Federal Maintenance of Effort (MOE) Requirement for children

 

 

Enrollment Policy and Practices

 

 

 

 

 

 

 

 

 

End of Federal Maintenance of Effort (MOE) Requirement for children

 

 

Minimize Disruption of Care

 

 

 

 

 

 

 

 

 

End of Federal Maintenance of Effort (MOE) Requirement for children

 

 

Contractual Obligations

 

 

 

 

 

 

 

 

 

End of Federal Maintenance of Effort (MOE) Requirement for children

 

 

Systems Changes

 

 

 

 

 

 

 

 

 

End of Federal Maintenance of Effort (MOE) Requirement for children

 

 

Exchange Plan Cycle

 

 

 

 

 

 

 

 

 

End of Federal Maintenance of Effort (MOE) Requirement for children

 

 

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* This timeline was developed based on guidance and input from state CHIP officials, and outlines key budgetary, statutory, and programmatic issues and changes that states would need to consider and/or implement. This timeline assumes that states will have funds available to spend from their federal CHIP allotment through at least the first quarter of federal fiscal year 2018. States have different budget cycles and while this timeline notes critical decision points for states, the time in which changes will need to be made, especially those with biennial budgets, may differ. Also, states will need to work closely with CMS to make many of the policy changes needed if the future of federal funding remains uncertain, so the timing of federal guidance will affect states’ ability to make some critical changes.

**Incurred but not reported