A Trail Guide for States Ascending to the ACA Medicaid Mountaintop

States are hiking up a challenging trail to bring their Medicaid programs into compliance with the Affordable Care Act (ACA) by 2014.  The ACA and subsequent regulatory guidance make changes that affect nearly all aspects of Medicaid operations. This new checklist provides a comprehensive list of ACA requirements for Medicaid programs. It can help states navigate the path ahead by breaking the ACA requirements into manageable components, and by providing resources and information on their statutory and regulatory basis.
States are already working on these changes, which are required for all states, regardless of whether they expand Medicaid eligibility to adults with incomes at or below 133 percent of the federal poverty level. As a Nevada analysis shows, some of these requirements are not significantly different from past practice and may have little or no impact to a state’s Medicaid program.  However, many requirements are very different from the path that Medicaid programs have been walking for decades. In these cases, states are in uncharted terrain as they advance toward 2014.  Here’s a quick look at how states are progressing toward meeting even the most significant obligations:

• Automating eligibility: In the past, states could exclusively use a paper-based process to determine whether applicants were eligible for Medicaid coverage based on their income, and the burden of providing documentation defaulted to the applicant. For 2014, states face manyrequirements to make determining eligibility an electronic process that automatically pulls applicant information from state and federal data sources, with the applicant only needing to provide documentation as a last resort. To enter the automated world, states are well on their way to a making host of program changes, such as building new technological systems, redesigning workflows, and developing new applications, notices to consumers, and appeals processes. In Colorado, Medicaid has been putting out biweekly newsletters that describe its system and process changes. The publications link to documents such as timelines and work plans. Washington has also posted a detailed timeline with many changes they’re making.

• Designing an alternative benefit plan: States could previously choose to offer non-disabled adults in Medicaid a fairly limited package of benefits. Now, states will have to develop an “Alternative Benefit Plan” benefit package, covering the ten categories of Essential Health Benefits required under the ACA, and provide that package to (1) the new adult group in states that choose to expand eligibility to adults at or below 133 percent FPL, and (2) current optional or waiver adult groups that receive a benchmark or benchmark-equivalent benefit under Section 1937 of the Social Security Act.  At this point, states are analyzing their options. Washington put out a document with goals, considerations, and a detailed timeline for selecting their alternative benefit plan. New York, Iowa, and Oregon have each shared their own analyses as well.

• Providing new types of customer assistance: Most states already have chosen to provide assistance to consumers in Medicaid, such as through telephone hotlines, in-person application assisters or enrollment brokers. However, for the first time the ACA makes assistance a requirement. All state Medicaid programs will need to provide consumer assistance online, by phone, and in person. They must update existing assistance programs to ensure that assistance is accessible, and that consumers can receive help at all stages in the coverage process. Most state Medicaid programs are still in the process of re-envisioning existing assistance and developing training materials. But a few states that are developing joint exchange and Medicaid customer service programs—examples are Nevada and Maryland—have described their plans in more detail.

States will each need to face the challenging implementation trail; a guide and the experience of other states can smooth out the terrain. How is your state progressing in its path to implementing Medicaid changes by 2014? Let us know in the comments below.
The States’ Medicaid ACA Checklist for 2014, was written by the National Academy for State Health Policy for the Robert Wood Johnson Foundation-funded State Health Reform Assistance Network.