Looking Ahead: A Timeline of State Policy & Operational Considerations if Federal CHIP Funding Ends for States
Without Congressional action, federal funding for the Children’s Health Insurance Program (CHIP) is due to end in September 2017. The National Academy for State Health Policy (NASHP) created this infographic to highlight the main policy and operational issues that would need to be considered and addressed in states with separate CHIP programs if future federal funding for CHIP remains uncertain in the coming months.
States with separate CHIP programs can limit enrollment if federal funds are not available, and this timeline reflects the key issues for 42 states with these types of CHIP programs. However, Medicaid expansion CHIP programs are required through the Affordable Care Act’s (ACA) maintenance of effort (MOE) provision to maintain eligibility levels for children through 2019, even if federal CHIP funding ends; they would receive the regular Medicaid match rate for children enrolled in these programs.*
Infographic: A Timeline for States
Printable version of Timeline.
Blog: Planning Now: State Policy and Operational Considerations if Federal CHIP Funding Ends
Supported by the David and Lucile Packard Foundation.
A Timeline for state health policy and operational considerations if CHIP funding ends.
Color key below chart.
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Month |
January |
February |
March |
April |
May |
June |
July |
August |
September |
October |
November |
December |
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Budgetary Cycle |
Budgeting for FY2017 and FY2018, depending on state budget cycles (Making assumptions re: federal funding for programs) |
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States with Biennial budgets may need to begin an amendment process to address major budgetary changes |
Implementing State Budget Contingency Plans |
Begin internal planning for systems changes and care transitions |
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Begin finalizing FY2017 budgets |
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Statutory Change Cycle |
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Develop transition plans to ensure continuity of care
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Begin internal planning for systems changes and care transitions |
Develop transition plans to ensure continuity of care
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Draft & Pass State Legislation |
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Enrollment Policy and Practices |
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Consider other coverage options available |
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Begin internal planning for systems changes and care transitions |
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Minimize Disruption of Care |
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State by State review of EHB vs. CHIP (identify services children may lose in transition) |
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Develop transition plans to ensure continuity of care
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Develop transition plans to ensure continuity of care Begin internal planning for systems changes and care transitions |
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Contractual Obligations |
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Begin internal planning for systems changes and care transitions |
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Systems Changes |
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Begin internal planning for systems changes and care transitions |
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Exchange Plan Cycle |
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QHPs set rates for 2017 |
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Begin internal planning for systems changes and care transitions |
Consider a pediatric benefit in exchanges |
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Month |
January |
February |
March |
April |
May |
June |
July |
August |
September |
October |
November |
December |
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Budgetary Cycle |
Begin finalizing FY2018 budgets |
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Review agency staffing needs |
Start of Many State Fiscal Years |
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Budgeting for FY2018 and FY2019, depending on state budget cycles (Making assumptions re: federal funding for programs) |
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Current Authorization for Federal CHIP Funding Ends |
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Statutory Change Cycle |
Ideal time for Federal Government decision on CHIP funding (Latest possible date for any state law changes) State law should include a transition plan |
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Assess current state policies, regulations and laws and make changes to regulations (4-5 mo.) |
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State Laws take effect unless stated otherwise State Transition plan can begin |
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Current Authorization for Federal CHIP Funding Ends |
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Enrollment Policy and Practices |
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Develop comprehensive communications plan |
Work with CMS on the clarification of maintenance of effort (MOE) and address continuous eligibility
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Develop and submit appropriate information to CMS: SPA, waiver, financial plan (dependent upon CMS timeline – could take 9 months or longer) |
Draft Notices to Families |
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Freeze CHIP Enrollment (6 months from end of allocation) |
Send notices to families (3 mo. from end of program/ allotment) |
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Current Authorization for Federal CHIP Funding Ends |
Transition Enrollees (will depend on when allotment ends) |
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Minimize Disruption of Care |
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Develop comprehensive communications plan |
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Identify children receiving long-term treatments |
Identify children receiving long-term treatments |
Engage provider and health plans on payment issues in advance of losing funds |
Implement communications plans with health providers, plans, and stakeholders |
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Current Authorization for Federal CHIP Funding Ends |
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Contractual Obligations |
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Develop comprehensive communications plan Evaluate all system contracts (e.g. MMIS, etc.) to identify possible changes needed |
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Address Call Center Contracts (likely increased demand as notices sent and to set end date for service) |
Modify existing or future managed care or third party administrator contracts |
Modify existing or future managed care or third party administrator contracts |
Modify existing or future managed care or third party administrator contracts |
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Current Authorization for Federal CHIP Funding Ends |
Final IBNR** and Payment Appeals |
Final IBNR and Payment Appeals |
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Systems Changes |
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Develop comprehensive communications plan Review and identify needed changes for systems |
Review and alter RFPs, contracts for system upgrades
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Implement MMIS, eligibility system changes |
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Current Authorization for Federal CHIP Funding Ends |
Develop manual workaround during the transition period |
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Consider interagency agreements and data sharing obligations necessary to transition children to other coverage sources
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Exchange Plan Cycle |
Engage QHPs with Medicaid/CHIP early to inform rate setting and to plan a pediatric benefit |
Review existing and establish new transitions rules/policies for Medicaid and exchanges |
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QHPs set rates for 2018 |
Coordinate with marketplace leadership to transition enrollees |
Take initial steps to implement a pediatric benefit to be offered by QHPs for 2018 |
Current Authorization for Federal CHIP Funding Ends |
Open Enrollment for Exchanges |
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Month |
January |
February |
March |
April |
May |
June |
July |
August |
September |
October |
November |
December |
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Budgetary Cycle |
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Statutory Change Cycle |
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Enrollment Policy and Practices |
Transition Enrollees (will depend on when allotment ends) |
Transition Enrollees (will depend on when allotment ends) |
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Minimize Disruption of Care |
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Contractual Obligations |
Final IBNR** and Payment Appeals |
Final IBNR and Payment Appeals |
Final IBNR and Payment Appeals |
Final IBNR and Payment Appeals |
Final IBNR and Payment Appeals |
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Systems Changes |
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Exchange Plan Cycle |
Open Enrollment for Exchanges |
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Month |
January |
February |
March |
April |
May |
June |
July |
August |
September |
October |
November |
December |
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Budgetary Cycle |
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End of Federal Maintenance of Effort (MOE) Requirement for children |
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Statutory Change Cycle |
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End of Federal Maintenance of Effort (MOE) Requirement for children |
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Enrollment Policy and Practices |
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End of Federal Maintenance of Effort (MOE) Requirement for children |
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Minimize Disruption of Care |
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End of Federal Maintenance of Effort (MOE) Requirement for children |
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Contractual Obligations |
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End of Federal Maintenance of Effort (MOE) Requirement for children |
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Systems Changes |
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End of Federal Maintenance of Effort (MOE) Requirement for children |
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Exchange Plan Cycle |
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End of Federal Maintenance of Effort (MOE) Requirement for children |
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* This timeline was developed based on guidance and input from state CHIP officials, and outlines key budgetary, statutory, and programmatic issues and changes that states would need to consider and/or implement. This timeline assumes that states will have funds available to spend from their federal CHIP allotment through at least the first quarter of federal fiscal year 2018. States have different budget cycles and while this timeline notes critical decision points for states, the time in which changes will need to be made, especially those with biennial budgets, may differ. Also, states will need to work closely with CMS to make many of the policy changes needed if the future of federal funding remains uncertain, so the timing of federal guidance will affect states’ ability to make some critical changes.
**Incurred but not reported


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