In September, the Centers for Medicare and Medicaid Services (CMS) proposed a rule to simplify the processes for eligible individuals to enroll and retain eligibility in Medicaid, the Children’s Health Insurance Program (CHIP), and the Basic Health Program. In light of an expected end to the COVID-19 Medicaid continuous coverage requirement in the coming months, these changes will help ensure that the Medicaid enrollment and renewal processes are efficient and inclusive, and could help reduce coverage losses. This proposed rule would require states take steps to reduce disenrollment for procedural reasons, including: 

  1. Taking additional steps to contact applicants and beneficiaries when mail is returned to the state agency as undeliverable.
  2. Removing barriers to coverage renewal, including prohibiting in-person interviews and conducting renewal only once per year;
  3. Streamlining citizenship verification by using additional government data sources to confirm applicant status;
  4. Making transitions between programs easier; eliminating access barriers for children enrolled in CHIP by prohibiting premium lock-out periods, waiting periods, and benefit limitations; and 
  5. Modernizing recordkeeping requirements to ensure proper documentation of eligibility and enrollment.

On November 7, we submitted a comment on behalf of the Tennessee Justice Center (TJC) – a non-profit law firm that helps its clients navigate Medicaid eligibility, enrollment, and renewal processes and fight improper coverage termination – highlighting how the lack of such streamlining in Tennessee has impacted TJC clients and how these proposed changes would benefit Tennessee residents. The comment also details areas where the changes could be made even more effective and efficient. 

TJC offers insights into how Tennessee residents’ struggles navigating the TennCare (Tennessee’s Medicaid program) enrollment and renewal processes can serve as an example of the value of CMS’ proposed streamlining measures. Tennessee residents have faced myriad challenges in obtaining and keeping health care coverage.  In 2018, Tennessee experienced the largest percentage drop in children covered by Medicaid and CHIP.  In 2017 and 2018, more than 200,000 TennCare enrollees erroneously lost coverage.  During that same time period, more children were denied benefits because they faced procedural hurdles than actual ineligibility for coverage.  These bureaucratic issues lead to real world harms.

TJC frequently supports clients struggling to navigate  the TennCare enrollment or renewal process. For instance, one family was sent renewal paperwork, which they never received.  The state had mailed the paperwork to the wrong address, and when the family did not respond, they lost their health care coverage.  The state was not required to attempt to contact the family by phone or email, or otherwise get in touch with them, before terminating their coverage.  The mother was pregnant, and between COVID-19, injuries, and a C-section, the family was left with more than $100,000 of medical debt, and they were forced to abandon their dream of buying their first home.  CMS’s measure would require Tennessee to take additional steps to contact the family before terminating coverage.

Read the comment here.