Medicaid will help pay medical expenses for improperly terminated beneficiaries
Medicaid will help pay medical expenses for improperly terminated beneficiaries
States that make retroactive payments for health services received by individuals and families who were improperly terminated from Medicaid can receive federal help with the payments.
Medicaid director Timothy Westmoreland says federal financial participation (FFP) money will be available for state payments even to people for out-of-pocket payments for services that would have been covered by Medicaid had the individual not been terminated.
A long way to go
FFP, in direct payments, will be based on the full payment amount, Mr. Westmoreland says. FFP in payments to participating Medicaid providers will be at the Medicaid rate.
Announcement of the federal aid for retroactive payments was included in an April 7 letter from Mr. Westmoreland to state Medicaid directors outlining requirements states must follow to identify individuals and families who were improperly terminated, to reinstate them to Medicaid, and then re-determine Medicaid eligibility.
While states have made great progress in recent years in increasing access to health care coverage for low-income working families, there’s still a long way to go, Mr. Westmoreland says.
"At the same time that states have made expansion of coverage a priority, instances in which eligible children and parents have lost out on coverage have come to light," he says.
In particular, the detachment of Medicaid from cash assistance has made it possible for states to offer low-income families health care coverage regardless of whether the family is receiving welfare, but it has created challenges as well as opportunities for states, Mr. Westmoreland explains.
"We are concerned that some families who left the Temporary Assistance for Needy Families [TANF] program and who remain eligible for Medicaid or Transitional Medical Assistance [TMA] benefits may have lost coverage. In addition, it appears that some children who became ineligible for Supplemental Security Income [SSI] benefits due to a change in the SSI disability rules may not have been continued on Medicaid despite congressionally mandated requirements," the letter says.
Mr. Westmoreland says states have a continuing obligation to provide Medicaid to everyone who has not been properly determined ineligible for Medicaid. That includes people whose Medicaid coverage was terminated through computer error or without a proper re-determination of eligibility.
Mr. Westmoreland says states should follow these procedures:
1. Determine whether individuals and families lost Medicaid coverage when their TANF case was closed, or when their TMA coverage period ended without a proper notice or without a proper Medicaid determination, including an ex parte review.
States must see particularly if their computer system improperly terminated Medicaid coverage when TANF benefits were terminated and should consider whether families whose TANF termination was due to earnings were evaluated with respect to ongoing Medicaid eligibility, including TMA.
2. Identify and reinstate children who became ineligible for SSI due to the 1996 change in the SSI disability rules and then were terminated from Medicaid either without adequate consideration of their eligibility under Section 4913 of the Balanced Budge Act of 1997 or without a proper re-determination, including an ex parte review.
States are to compare the Social Security Administration list of children whose Medicaid eligibility was protected by Section 4913 and determine which, if any, of the children are not currently receiving Medicaid or are receiving Medicaid but are not identified as a Section 4913 child.
3. Consider identifying and enrolling eligible individuals applying for Medicaid and TANF who may have been denied Medicaid improperly because eligibility determinations continued to be linked.
4. Develop a timetable for reinstating coverage and conducting follow-up eligibility reviews as appropriate if the statewide examination of enrollment policies and practices indicates there have been improper terminations since the TANF plan went into effect.
Coverage should be reinstated as quickly as possible. States that find that problems in policy or practice caused individuals to lose Medicaid improperly may reinstate coverage without making a specific finding that an individual termination was improper.
FFP is available for up to 120 days of coverage after reinstatement, pending a redetermination of ongoing eligibility, regardless of the re-determination outcome.
5. Make active outreach efforts to identify and contact individuals and families who have not been in contact with the Medicaid agency in some time.
Possible steps include checking food stamp records for current addresses, alerting caseworkers to refer individuals who are in touch with the agency for other reasons, sending notices to families receiving child care services, and broadcasting public service announcements.
6. Re-determine eligibility after reinstatement to assess whether the individual or family still is eligible for Medicaid.
Individuals and families whose most recent Medicaid eligibility determination or re-determination occurred less than 12 months before reinstatement may be continued on Medicaid until 12 months from the date of the last eligibility review, without any new re-determination of eligibility.
[Contact Mr. Westmoreland at (410) 786-3870.]
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