“Reasonable” Flexibility: Exploring Models to Help States Resolve Inconsistencies in Income for Medicaid, CHIP and Tax Credit Eligibility

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With the recent affirmation by the Supreme Court that the Affordable Care Act (ACA) passes constitutional muster, states will want to accelerate their planning efforts to implement eligibility system provisions under the law for Medicaid, CHIP and Exchanges. This webinar will offer detailed analysis of one of these provisions, the standards under which states can find “reasonable compatibility” of income information provided by applicants for Medicaid, CHIP and the exchanges that is not precisely equivalent. Income data is typically neither static nor centralized, and states must be prepared to resolve discrepancies when income data is submitted by applicants or retrieved from state, federal, or other independent sources. In the case of a discrepancy, CMS eligibility rules provide guidelines to help states proceed with an eligibility determination, including some flexibility for states to find data is “reasonably compatible.”

These rules, which will apply to APTC/CSR, Medicaid and CHIP eligibility decisions regardless of whether states implement the Medicaid expansion and to state-based and federally funded exchanges, provide states with critical flexibility to operationalize eligibility decision-making by allowing states to accept small deviations in income data from different sources. What might a “reasonable compatibility” decision-making process look like in practice? How would a reasonable compatibility analysis work with programs where the actual income amount matters, as with a CHIP premium or cost-sharing requirement or the advanceable premium tax credit and cost-sharing benefit for the exchanges?

In this webinar, Deborah Bachrach and Kinda Serafi of Manatt Health Solutions, will walk participants through straw models they have created to help states think through options for reasonable compatibility process flows for Medicaid, CHIP and APTC/CSR income eligibility determinations. Karen Gibson from Minnesota Department of Human Services will share preliminary thinking on planning for implementation of reasonable compatibility standards. In addition, Ben Walker from CMS will be on hand to provide reactions and feedback on the models. Chad E. Shearer, Deputy Director of the State Health Reform Assistance Network will introduce the webinar and Alice Weiss, Co-Director of Maximizing Enrollment, will moderate the panel. [This webinar is rescheduled from its original broadcast date of June 28.]

Participants:

  • Host: Chad E. Shearer, Deputy Director, State Health Reform Assistance Network
  • Moderator: Alice Weiss, Program Director, National Academy for State Health Policy
  • Speaker: Deborah Bachrach, Special Counsel, Manatt Health Solutions
  • Speaker: Kinda Serafi, Counsel, Manatt Health Solutions
  • Speaker: Karen Gibson, Director of the Health Care Eligibility and Access Division, Minnesota Department of Human Services
  • Speaker: Ben Walker, Health Insurance Specialist, Eligibility and Enrollment Team, Office of Health Insurance Exchanges in the Center for Consumer Information and Insurance Oversight, Centers for Medicare and Medicaid Services

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