On Monday, November 7, 2022 ADvancing States submitted comments on the CMS proposed rule, “Streamlining the Medicaid, Children's Health Insurance Program, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Process” (CMS-2421-P). In our comments, we provide feedback on several issues, including:
- General comments about the public health emergency (PHE) unwinding and other pressures on state eligibility and enrollment systems leading to the need for ample implementation time;
- Supporting the CMS changes to streamline the conditional Part A enrollment process for individuals with a premium and hope that it makes the program more accessible to participants and note that this type of policy complexity is one of the reasons that the State Health Insurance Assistance Programs (SHIPs) and Aging and Disability Resource Centers (ADRCs) are so crucial for participants;
- Requesting confirmation that the proposed 12 month eligibility certification periods only apply to financial and not functional eligibility;
- Encouraging CMS to develop a model preprint for states that wish to implement income and asset disregards to align Medicare Savings Plan (MSP) and Low Income Subsidy (LIS) eligibility;
- Stressing that audit protocol must ensure that states are not penalized for required self-attestations if they later turn out to be incorrect; and
- Supporting the change to allow projected HCBS expenses for establishing and maintaining Medicare Savings Plan eligibility to provide more flexibility and address one of the lingering institutional biases in medically needy eligibility policy and request that CMS clarify other state options to expand the prospective HCBS deductions to individuals with private-pay receipts or who have received support from a qualified entity (such as an ADRC) to develop a service plan.
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