CMS Proposed Rule Could Simplify Medicaid/MSP Enrollment and Renewal

Vicki Jessup, BeneLynk's VP of Government Relations and I have spent most of our careers helping people to get and keep Medicaid benefits. We have seen first-hand the incredible, life-changing impact that enrollment in a Medicare Savings Program (MSP) can have for low-income, older Americans. As a former Medicaid/SNAP Eligibility Policy Section Chief, Vicki has a particularly insightful perspective on the challenges associated with Medicaid enrollment and renewal. As such, she has been given the opportunity to offer feedback to CMS in a variety of forums encouraging a claimant-centered approach to application requirements. It is very gratifying for Vicki and for the entire BeneLynk team to see these concepts mirrored in the CMS proposed rule publicized last week.

The frank acknowledgement by CMS of just how many older Americans are eligible for MSPs but are still not enrolled in these life-changing programs, serves as clear call to action here:

“Additionally, enrollment in Medicare Savings Programs (MSPs), through which Medicaid provides coverage of Medicare premiums and/or cost-sharing for lower income Medicare beneficiaries, has remained relatively low. The MSPs are essential to the health and economic well-being of those enrolled, promoting access to care and helping free up individuals’ limited income for food, housing, and other of life’s necessities. Yet a 2017 study conducted for Medicaid and CHIP Payment and Access Commission (MACPAC) estimated that only about half of eligible Medicare beneficiaries were enrolled in MSPs” (Page 6)

CMS further illustrates just how valuable these programs are for Medicare enrollees:

“The MSPs are essential to the health and economic well-being of low-income Medicare enrollees, helping to free up limited income for food, housing, and other life necessities. For example, in 2022, the Part B premium is $170.10 a month, which is more than 10 percent of the income of individuals who qualify for the QI group, and an even higher percentage of income for those who qualify for the QMB or SLMB groups.” (Page 13)

The above quotes from CMS illustrate that MSPs remain under-utilized despite the life-changing value they provide to Medicare recipients. It is in the context of this challenge that CMS’s proposed changes are best understood. So, what are some of those changes? CMS is proposing to:

• Strengthen policy alignment between MSP and the federal Low-Income Subsidy (LIS) program

• Update renewal procedures for elderly and disabled Medicaid members with procedures already required for children, pregnant women, and adults without dependent children

• Require states to reconsider applications when verification is provided after the state deadline

• Establish specific procedures for responding to returned mail

• Lessen the burden on claimants to provide some documentation, etc.

As long-time advocates with decades of experience helping Medicare recipients to apply for Medicaid and the MSPs, we are very familiar with the challenges for older Americans asked to document the value of an automobile, attain the cash surrender value of a whole life policy, or document in-kind support provided by a family member. So often these relatively low-value items can derail an application. We applaud CMS for recognizing that this generally insignificant accounting represented a disproportionate burden on claimants who qualify for these benefits.

While we must wait to see how much of what is proposed is ultimately included in the final rule, we support CMS recognizing the real challenges that Medicaid applicants face and for setting out commonsense adjustments to address them. In our experience, however, one of the primary reasons that potentially eligible Medicare recipients are not enrolled in the Medicare Savings Programs (and Medicaid more broadly) is because they do not know about the programs, and do not know that they qualify! That is why it is so important for outreach programs to identify qualifying members and conduct human-to-human outreach to help them understand the benefits.

Over the next few weeks, we’ll be unpacking the proposed requirements, options, and recommendations, and preparing public comments. After the final rule is published, we will be closely monitoring state policy and procedure changes to ensure that we both stay in compliance and continue to assist our clients’ members in accessing and keeping the benefits they deserve.