LeadingAge submitted a comment letter on November 7 in response to a proposed rule from the Centers for Medicare and Medicaid Services (CMS) that aims to streamline the processes through which eligible individuals enroll and retain eligibility in Medicaid.

The proposed rule includes a wide range of changes intended to simplify eligibility, enrollment, and renewal processes for applicants and enrollees and to reduce administrative burden on State agencies administering Medicaid, as well as the Children’s Health Insurance Program, and the Basic Health Program.

CMS has learned through experiences working with States and other stakeholders that certain existing policies result in unnecessary administrative burden and create barriers to enrollment and retention of coverage for eligible individuals.

Among other goals, CMS intends for the proposed rule to remove some of those barriers and facilitate enrollment of new applicants, particularly those dually eligible for Medicare and Medicaid; align enrollment and renewal requirements for individuals in Medicaid; address timeliness requirements for redeterminations of eligibility in Medicaid; and modernize recordkeeping requirements to ensure proper documentation of eligibility and enrollment.

It is important to note that these regulations govern and apply specifically to States and the work they do with program applicants and enrollees. The ways in which enrollment and eligibility processes work, however, affects not only individuals enrolled in Medicaid but also providers who offer services and supports to those beneficiaries, and for that reason LeadingAge wrote to share our perspective on selected aspects of CMS’ proposal.

Our comments focused on three issues:

• We voiced support for a proposal to promote enrollment in Medicare Savings Programs. These programs provide income support to eligible individuals by assisting with payment of Medicare premiums and/or coinsurance, yet data shows participation in these programs is relatively low among eligible low-income Medicare beneficiaries. CMS proposes to codify in rule existing statutory requirements to make sure States are aware of and clear about steps they should be taking.
• Under current rules States have the option to project certain predictable medical institution expenses (such as the monthly cost of nursing home care) when determining the income eligibility of an individual who will be required to meet a spenddown. CMS is now proposing to give States the option to project recurring expenses for individuals residing in the community, as well – such as services identified in the person’s plan of care or prescription drug costs. We noted our support for this proposal, which would create alignment between policies for individuals living in institutional and non-institutional settings, simplify administrative processes, and support continuity of care by helping certain beneficiaries to avoid cycling in and out of Medicaid eligibility.
• Finally, we noted that States and their local partners in some cases struggle to meet required timelines for processing Medicaid applications, and we encouraged CMS to track and publicly report on the performance of States, so that stakeholders can work together to address systemic delays if and where they are occurring.

CMS will proceed to review the public comments it received and will issue a final rule in the coming months. LeadingAge will share an analysis of the final rule with members shortly after it is released.