States Invited to Join a Community of Practice to Improve Immunization Rates
/in Policy Blogs, Featured News Home CHIP, CHIP, Chronic Disease Prevention and Management, Eligibility and Enrollment, EPSDT, Health Coverage and Access, Immunization, Integrated Care for Children, Integrated for Pregnant/Parenting Women, Maternal Health and Mortality, Maternal, Child, and Adolescent Health, Medicaid Managed Care, Population Health /by NASHP StaffThe National Academy for State Health Policy (NASHP) and AcademyHealth are seeking five to seven states to join a community of practice focused on improving immunizations rates.
To apply, complete an expression of interest form by Dec. 10, 2020.
Funded by the Centers for Disease Control and Prevention (CDC) cooperative agreement entitled Eliminating Barriers to Immunization through Collaborative Use of State Agency Resources, each state’s community of practice will be comprised of a multidisciplinary team, including a Medicaid medical or policy director, an immunization state program manager, and a state immunization information system coordinator.
Through virtual and in-person engagement over the course of the three-year project, NASHP and AcademyHealth will work with states to identify immunization barriers and share promising practices for increasing immunization rates for children and pregnant women enrolled in Medicaid.
If a state’s Medicaid agency is interested in joining this community of practice, please send an email to Sunita Krishnan (Sunita.Krishnan@academyhealth.org ) with a completed expression of interest form by Dec. 10, 2020.
Explore NASHP’s State Immunization Services and Policies Resource Page for more resources.
How States Address Social Determinants of Oral Health in Dental and Medical Medicaid Managed Care Contracts
/in Medicaid Managed Care Blogs, Featured News Home Child Oral Health, CHIP, CHIP, Chronic Disease Prevention and Management, Essential Health Benefits, Health Coverage and Access, Maternal, Child, and Adolescent Health, Medicaid Managed Care, Medicaid Managed Care, Oral Health, Population Health, Social Determinants of Health, Special Populations and Services /by Ariella Levisohn, Allie Atkeson and Carrie HanlonInequities in oral health and health outcomes are driven by upstream factors, including diet, education, transportation, and access to care. A growing number of states are working to improve the oral and physical health of Medicaid enrollees and reduce costs by addressing these social determinants of health in their managed care contracts.
Recently, states have used Medicaid managed care contracts and value-based purchasing agreements to address the education, food, and transportation needs of their enrollees. However, less is known about how states leverage their purchasing clout to improve dental care or address social determinants of health (SDOH) directly in dental contracts.
To learn how state Medicaid programs include social determinants of health in their dental and medical Medicaid managed care contracts, view this interactive map.
A 50-state review by the National Academy for State Health Policy (NASHP) of Medicaid dental and medical managed care contracts, requests for proposals, and other similar documents publicly available through September 2020, identified how states address social determinants of oral health. Dental contracts were reviewed for a comprehensive list of social determinants and medical contracts were analyzed for references to care coordination, community resources, food access, social determinants of health screening, and coordination with dental contractors. In total, NASHP scanned dental contracts in 19 states and medical contracts in 38 states.
Of the dental contracts, nine referenced coordination between dental plans and medical plans and 13 referenced coordination with social and community services. Other common references in dental contracts included equity/cultural competence, education, and transportation (each referenced in 10 state contracts).
All but one of the 38 medical contracts referenced coordination with social and community services. Thirty-three states referenced food in their medical contracts, 25 referenced adverse experiences (such as domestic violence and child abuse), and 15 referenced care coordination between dental and medical care. Three states (Florida, Michigan, and Virginia) referred to food in both their dental and medical contracts, while only one (Virginia) referenced adverse experiences in both contracts.
State Medicaid Program Delivery of Dental Care
While Medicaid covers some form of adult dental care in 47 states and Washington, DC, and all states cover dental care for children under 21 as part of the Early Periodic Screening, Diagnosis and Treatment (EPSDT) program, adult dental coverage is optional for state Medicaid programs. Currently, 35 states provide limited dental benefits for adults and 19 states offer extensive adult dental benefits.
States have different options for delivering dental care. Some states with managed care use a carve-in model, where the dental benefit is integrated into medical managed care programs. With a carved-in benefit, managed care organizations (MCOs) may administer the dental benefit or subcontract the dental benefit to another vendor. In carve-out dental programs, states contract with a dental MCO or dental benefits manager (DBM). Alternatively, states with Medicaid managed care medical delivery systems may have fee-for-service dental systems.
Medicaid dental and medical contracts illustrate how states can consider social determinants affecting oral health and overall health through:
- Screening, referral tracking, and follow-up;
- Educational initiatives;
- Staffing and training requirements;
- Data sharing and technology;
- Coordination between dental and medical systems; and
- Performance improvement.
Social Determinants of Health in Dental and Medical Medicaid Contracts
Almost all states scanned have some requirement for plans to refer members to community resources and social services. NASHP focused specifically on requirements that are applicable to the general population, rather than individuals designated as high risk or high needs. States use a variety of strategies to encourage investment in SDOH.
Screening for SDOH Needs
Sixteen states use routine screenings for certain social determinants, including employment status and access to food and transportation. The scan of 14 medical contracts and two dental contracts indicate that states are more likely to require medical plans to conduct needs assessments, often within a specified time frame after enrollment, than dental plans. States may also require medical plans to use this data to appropriately target interventions to meet enrollees’ needs.
While dental plans do not necessarily have the same explicit requirement to conduct a screening, some states do ask their dental plans to use SDOH data to target their educational and outreach activities.
- Michigan’s dental plan is required to use social determinants of oral health data from the state in order to target interventions, outreach, and education efforts.
- Nevada’s dental contract requires the contractor to complete a community-based needs assessment to inform their health promotion and educational activities, including ensuring that any interventions are culturally appropriate and meet the needs of the target population.
Referral Tracking and Follow-up
While screening is an important first step in identifying members’ social needs, it also raises a question of how states use the data to address social determinants. NASHP found that in almost every state with publicly available contracts, Medicaid agencies partner with community-based organizations to meet the social needs of enrollees. For example, plans may facilitate referrals to these community agencies based on information collected through SDOH screenings. States can use tracking, follow-up, and reporting requirements to ensure that referrals to community resources and organizations are effective and successful. Contractors can support these efforts by documenting “closed-looped” referrals that ensure that an enrollee is successfully connected with a community-based organization to address other health and social needs.
- In Louisiana, the Dental Benefit Program Manager is required to connect enrollees with community-based service providers and document referrals and referral outcomes in enrollees’ dental records.
Dental contracts are less likely to require or encourage the plan to monitor referral follow-up. However, dental plans could adopt some of the medical MCOs’ language in order to track the status of referrals, strengthen care coordination between insurance plans and community resources, and ensure individuals are receiving adequate social services that meet their evolving needs. For example, New Hampshire requires MCOs to track the effectiveness of community-based providers and resources, and Oregon requires reporting on referrals to culturally diverse social and support services.
Educational Initiatives
Healthy People 2020 identified health literacy as a component of SDOH, noting that individuals’ ability to access and understand relevant health information affects their health and health outcomes. To help improve health literacy, many states require managed care plans to implement educational initiatives. For dental plans, this includes educating members about the importance of oral health or launching community oral health initiatives designed to help eliminate barriers to dental services and improve population oral health.
- In both Nevada and Texas, the dental contractor must develop and implement programs designed to educate members about nutrition, the importance of oral health, and the relationship between oral health and overall health.
- Florida’s dental plan includes incentives for participation in health education classes. Examples of incentives members can receive that support healthy child development include clothes, food, books, safety devices, publications, and memberships in health and education clubs.
- In its response to Nebraska’s request for proposals (RFP), dental contractor MCNA referenced a program it implemented in Texas that uses the fotonovela (a comic book-style communication popular in the Latinx community) to distribute health information materials to children of migrant farm workers.
Staffing and Training Requirements
Plans may also be responsible for training their employees to better meet members’ needs. In their contracts, states can prioritize the type of training that a plan’s staff receive.
- Nebraska’s dental contract requires all staff to be trained on how social determinants (including food, housing, education, violence, and physical and sexual abuse) affect members’ health and wellness. Staff also receive training on how to find community resources and make referrals.
Both medical and dental plans also employ staff members who are responsible for care coordination, addressing social determinants, and improving access to care for historically marginalized populations.
- Nebraska’s dental contract requires the plan to employ a tribal network liaison to coordinate and expand dental services to Native Americans and connect them to community resources. Arizonaand New Mexico both require medical MCOs to employ someone to coordinate services with Native Americans.
Examples of other medical plans’ required staff positions include a community liaison in Illinois, who connects enrollees with community-based services, and a service coordination director in Kansas, who oversees quality improvement initiatives related to SDOH. Dental contractors could potentially leverage medical MCO positions and their expertise to streamline care experiences for enrollees across medical and dental systems.
Coordination between Dental and Medical Systems
To better integrate dental and medical care, dental and medical managed care use staff members to connect physical health and oral health services across contracts. These staff members also connect Medicaid enrollees to community services to meet social needs.
- In its dental contract, Tennessee requires a coordinator to work with the medical MCO and develop a system to exchange data with the MCO.
- Florida requires MCOs to have a liaison for their prepaid dental health plan to help integrate medical care, behavioral health, and long-term benefits with the dental plan.
- Iowa requires the dental contractor to send a care facilitation plan to the state with information on how the plan will facilitate coordination between dental and medical plans and providers.
Data Sharing and Technology
Eleven states require some form of data sharing between dental and medical plans, or between plans and community organizations. Requirements for integrating different agencies’ social determinant data and sharing information across systems allow medical, dental, and social services to work together to coordinate care for members and encourage referrals and follow-up tracking.
- In Tennessee, the dental benefits manager must facilitate data exchange with school-based health programs to coordinate any needed follow-up care.
- Washington State tasks its dental contractors with using health information technology and health information exchanges to coordinate care between physical health, behavioral health, and social services and other community-based organizations.
Other states are creating their own online platform or mobile applications to improve access to social services for their Medicaid enrollees. These platforms are mentioned specifically in medical managed care plan contracts, but have the potential to be used by dental contractors as well.
- Kansas developed a web-based, mobile-friendly application that connects service coordinators to community resources, such as food banks and pantries, housing, clothing, legal resources, and transportation.
- Medicaid Prepaid Health Plans in North Carolina will use a telephonic, online, and interfaced IT platform to refer members to social services and track the outcomes of these referrals.
Performance Improvement
A number of states encourage both dental and medical plans to engage in performance improvement projects (PIPs) in order to address SDOH.
- In Nevada, dental vendors are required to conduct both a clinical and non-clinical PIP every year. Non-clinical PIPs can focus on cultural competency and accessibility of services, among other SDOH.
- Oregon Coordinated Care Organizations (CCOs) must implement PIPs that address at least four of eight designated focus areas, which include addressing SDOH and equity, and integrating primary care, behavioral health care, and/or oral health care.
Through these PIPs, state managed care plans (both dental and medical) can launch pilot interventions to improve health outcomes by addressing SDOH and reducing barriers to care.
Conclusion
Research shows that addressing individual social needs leads to better oral health outcomes. Despite having different levels of funding and varying Medicaid adult dental benefits, states across the country are finding ways to invest in SDOH. While not all states have started to include SDOH requirements in their dental contracts, these examples show potential opportunities for dental plans to integrate some of the medical plans’ language and guidance into their own work. To learn more about how state Medicaid programs include SDOH-related language in their dental and medical Medicaid managed care contracts, view this interactive map.
Acknowledgements: This blog and map were made possible by the DentaQuest Partnership LLC. The authors would like to especially thank Trenae Simpson for her guidance and assistance, and Trish Riley and Jill Rosenthal for their helpful feedback. This information, content, and conclusions are those of the authors’ and should not be construed as the official position or policy of the DentaQuest Partnership LLC.
Medicaid Supports for Family Caregivers
/in The RAISE Act Family Caregiver Resource and Dissemination Center Featured News Home, Reports Children/Youth with Special Health Care Needs, Children/Youth with Special Health Care Needs, Chronic and Complex Populations, Chronic Disease Prevention and Management, Cost, Payment, and Delivery Reform, Council Meeting Materials and Resources, Long-Term Care, Maternal, Child, and Adolescent Health, Medicaid Managed Care, Population Health, Program Design, State Resources, The RAISE Family Caregiver Resource and Dissemination Center /by Neva Kaye and Salom Teshale
Executive Summary
Most individuals with long-term care needs prefer to remain in their homes and communities rather than enter an institution. Family caregivers play an important role in states’ efforts to help Medicaid enrollees safely fulfill that preference. Their contributions also help offset the cost of personal care services and can delay the need for more costly services, such as hospital and nursing facility services. Recognizing their importance, state Medicaid agencies already support family caregivers through training, services, or, sometimes payment. However, there are strong indications that family caregivers could benefit from additional supports, especially those targeted to meet caregivers’ specific needs. These supports would, in turn, benefit the Medicaid enrollees receiving their care.
Some states have already implemented innovative strategies that address critical issues in family caregiver support. The following are among the many examples discussed in this report.
- Colorado, in some circumstances, waives scope of practice laws to enable family caregivers to be paid to provide skilled health-related activities.
- In Florida, the managed care organization (MCO) that serves children and youth with special health care needs (CYSHCN) provides behavioral health services for family caregivers as a value-added service.
- Georgia has established a mechanism to identify and deliver individualized training to family caregivers that is based on information collected through the care coordination process.
- Tennessee requires its MCOs to conduct formal caregiver assessments and plan to meet needs identified in the assessment.
An examination of state strategies, research, and input from state officials identified four interdependent actions that the federal government could take to improve family caregiving as part of the national strategy.
- Foster the spread of innovative family caregiver support strategies already tested by leading states.
- Support the efforts of states to continue to advance their existing innovations and develop new ones.
- Conduct a comprehensive, systematic effort to identify and disseminate information about states’ innovative and tested family caregiver strategies that would help other states choose and implement the strategies that would work best for them, especially in the areas of cost and effectiveness.
- Measure and evaluate the number, demographics, contribution, needs, and priorities of the family caregivers who assist Medicaid enrollees.
When considering these actions, it is important to consider that the current pandemic and its impact on state budgets will, at least temporarily, make it difficult for states to contemplate implementing any new policies, especially those that require upfront investments. COVID-19 is, however, taking its greatest toll on nursing facility residents[1] and members of low-income and minority populations.[2] Supporting family caregivers in their efforts to help their loved ones remain in their own homes could help mitigate the impact of the infection. The pandemic also creates a window of opportunity that both federal and state policymakers could use to prepare for future action.
Introduction
The relatives and friends who provide hours of often unpaid care to help their loved ones with their self-care needs are linchpins in states’ long-term services and supports (LTSS) systems. These family caregivers, who are often members of the Medicaid enrollee’s own community and likely to speak the enrollee’s preferred language, provide companionship, help with household chores, and assistance in medical care. This support, in turn, helps children with special health care needs, adults with disabilities, and older adults remain in their own homes rather than enter institutions. Caregiver support also can prevent costly hospitalizations and other adverse medical events.
Medicaid, and Medicaid-financed LTSS, are major costs to states. Medicaid accounted for 28.9 percent of all state expenditures in fiscal year (FY) 2019[3] and in FY 2017, more than 20 percent of all Medicaid spending was for LTSS.[4] Medicaid is also the major payer for LTSS in the United States. In 2018, the program paid over half of all LTSS spending – almost $197 billion – including about $92 billion on home- and community-based services (HCBS).[5] As a result, Medicaid reaps substantial benefits from family caregivers’ contributions and could benefit from helping these individuals better meet the needs of their loved ones over the long term. The National Academies of Sciences, Engineering, and Medicine (National Academies) provides compelling evidence for the benefits that better family caregiver support could offer to the caregiver, care receiver, and payer:
…several randomized controlled trials have demonstrated that when older adults’ caregivers receive a standard assessment, training, respite, and other supports, caregiver outcomes improve. In addition, older adults’ nursing home placement is delayed, they have fewer hospital readmissions, decreased expenditures for emergency room visits, and decreased Medicaid utilization.[6]
To better support family caregivers, Congress passed the Recognize, Assist, Include, Support, and Engage Family Caregivers Act of 2017 (RAISE Family Caregivers Act), which established the Family Caregiving Advisory Council. In the legislation, the advisory council, along with the Secretary of the Department of Health and Human Services, was tasked with producing and maintaining a national Family Caregiver Strategy that identifies “recommended actions that federal (under existing federal programs), state, and local governments, communities, health care providers, long-term services and supports providers, and others are taking, or may take, to recognize and support family caregivers.”[7] One part of this strategy will be an assessment of how family caregiving impacts the Medicaid program and the role Medicaid plays (and could play) in supporting family caregivers. This report provides that assessment, which will be presented in the council’s initial report to Congress, that in turn will form the basis of the national family caregiving strategy.
This report is designed to both inform the national family caregiving strategy and help state officials weigh options to better support family caregivers. Both goals are met through an examination of promising practices that some states have already implemented. The impact of the COVID-19 pandemic on state budgets may make it difficult for states to implement new policies that have upfront costs for some time, even if the investment is expected to generate longer-term savings. However, not all of these innovations require upfront investments, and some costs may be almost immediately offset by reductions in other services (e.g., replacing a minimum number of hours of paid personal services with a stipend to a family caregiver). Even if states can’t make immediate investments to help family caregivers improve their ability to care for their loved ones, the potential benefits of these initiatives will remain after the economy recovers. Additionally, the federal government could use the delay to prepare to support states and state officials can use the time to consider their options.
Report Development Process
The actions for federal consideration presented in this report were developed by the National Academy for State Health Policy (NASHP), based on the organization’s previous work on these issues and with significant state research, guidance, and input. NASHP, with the support of The John A. Hartford Foundation, created the RAISE Act Family Caregiver Resource and Dissemination Center to support the Advisory council and its work. The information in this resource center, including advisory council meeting material and notes, as well as reports, was the starting point for developing this report. NASHP staff reviewed this information to identify information gaps, an initial set of key issues, and promising practices in use by one or more Medicaid agencies. This information was augmented by review of other relevant literature and state websites. All states highlighted in the report were offered an opportunity to review the information presented about their policies and provide input on all other aspects of the paper. The authors also held individual report review meetings, via telephone, with representatives of three states who serve as faculty to the advisory council. Finally, a draft of the report was reviewed by members of NASHP’s long-term and chronic care steering committee and its state leadership council on palliative care.
Background: Family Caregiving and its Effect on Medicaid
Family caregivers include “all who are caring for individuals across the life span with chronic or other health conditions, disabilities, or functional limitations.” The support may include help with feeding, bathing or toileting (i.e., Activities of Daily Living or ADLs) or help with shopping, cooking or handling finances (i.e., Instrumental Activities of Daily Living or IADLs).
Caregivers’ contributions lessen the need for home health and help prevent unnecessary hospitalizations or nursing facility stays.[8] One study, which focused on adults with LTSS needs, estimated that, the “economic value of family caregiving was $470 billion in 2017, based on about 41 million caregivers providing an average of 16 hours of care per week, at an average value of $13.81 per hour.”[9]
What do caregivers contribute?
- One study of adults with LTSS needs, estimated the value of family caregiving was $470 billion in 2017, based on 41 million caregivers providing 16 hours of care weekly.
- Another study of CYSHCN’s caregivers estimated they provided 1.5 billion hours of care to 5.6 million children worth between $11.6 and $35.7 billion.
Another study examining the contributions of children’s caregivers estimated that each year these caregivers provide 1.5 billion hours of care to about 5.6 million children and youth with special health care needs (CYSHCN) with an estimated economic value of between $11.6 and $35.7 billion.[10]
No nationwide family caregiver statistics are available showing the economic value that family caregivers provide to Medicaid. Little is known about the needs and priorities of the family caregivers who serve Medicaid enrollees or the cost and effectiveness of the support strategies that states have already implemented. However, available information indicates that family caregivers make significant contributions to state Medicaid programs and that providing more support to family caregivers would benefit the Medicaid enrollees for whom they care, the caregivers themselves, and the Medicaid program.
Given that the cost of Medicaid LTSS is substantial — $196.9 billion in 2018[11] — and that Medicaid pays for over 50 percent of all LTSS costs,[12] it is expected that family caregivers play an important role in the delivery of these services. This is especially true for the millions of individuals participating in HCBS programs[13] – who all need assistance to perform some ADL or IADLs – because it is often the family caregivers’ contributions that prevent the need for institutional and other services, including hospitalizations and home health aide services.
In addition, family caregivers help Medicaid agencies deliver care that respects enrollees’ cultural and language preferences. Most family caregivers understand the care receivers’ cultural preferences and typically speak the individual’s preferred language. Because family caregivers are often members of the Medicaid enrollee’s own community, they are well-suited to helping enrollees maintain the community ties they value.
Finally, family caregivers are critical to Medicaid agencies’ decades-long effort to eliminate institutional bias by increasing access to non-institutional services (i.e., balance the long-term care system). This bias resulted from federal Medicaid rules that require states to cover nursing facility services, but not HCBS. As a result, Medicaid spending on institutional care was much greater than its spending on HCBS — in 1981, HCBS made up just 1 percent of all LTSS spending and it wasn’t until 2013 that Medicaid agencies first began spending more on HCBS than institutional care.[14] Despite this progress, in FY 2018, 41 states reported that there was a waiting list for at least one of their HCBS programs, indicating that unmet need for non-institutional services remains.
CMS describes a balanced LTSS system as:
“.. a person-driven, long-term support system that offers people with disabilities and chronic conditions choice, control and access to services that help them achieve independence, good health and quality of life.”
States are seeking to rebalance the system because most people prefer to stay in their own homes.[15] Also, due to the Supreme Court’s 1999 ruling in the Olmstead Case that “unjustified segregation of persons with disabilities constitutes discrimination in violation of Title II of the Americans with Disabilities Act.”[16] The federal government has supported states’ efforts to respond to this ruling with its strong direction to make HCBS more available. Supports included guidance through a series of Medicaid Director letters, legislation creating new pathways for HCBS coverage (described later in this report), and state funding opportunities. The contributions of family caregivers are critical to these efforts because, as previously discussed, it is often the family caregivers’ assistance that enables individuals with LTSS needs to remain in their communities.
Family caregivers’ contributions to Medicaid’s LTSS system are clearly valuable. But most Medicaid agencies’ caregiver supports are designed to help those who have taken on new tasks and there are strong indications that caregivers would benefit from skill building. There are also indications that caregivers would benefit from other supports that would give them a break from caregiving. For example, some studies have found high rates of avoidable hospitalizations among HCBS program participants with both Medicaid and Medicare coverage (the dually eligible). One of these studies did not provide comparative nursing facility information and may not be generalizable to other groups who are participating in HCBS.[17] However, another study did find that dually eligible HCBS program participants with dementia had higher rates of hospitalization than those in a nursing facility. This difference was even more pronounced among Black Americans. This study found that caring for a person with dementia can be more stressful than caring for others and, “the presence of dementia may exacerbate caregiver burden such that outcomes for the care recipient suffer.[18] In addition, the National Academies have documented the toll that caregiving can take on caregivers’ health, well-being, relationships, and economic security. Taken together, these studies indicate that alleviating caregiver burden, especially among those caring for Medicaid enrollees with dementia, could lead to improved care for enrollees and, perhaps, reduce family caregiver burnout. Also, helping family caregivers improve their skills, especially those that could prevent avoidable hospitalizations, would benefit Medicaid enrollees and the agencies themselves.
Primer: Medicaid and Family Caregiver Support
The innovations and actions presented in this report are enhanced by an understanding of the Medicaid program’s strictures and flexibilities, especially as they apply to family caregiver support.
Introduction to Medicaid
Medicaid provides coverage to millions of people, in October 2019 the Centers for Medicare & Medicaid Services (CMS) reported the program covered over 64 million individuals.[19] Medicaid serves low-income families and children, pregnant women, people with disabilities, and older adults. The program is a partnership between federal and state governments, meaning that states establish program policies according to federal rules and share program costs with the federal government.
States document their policy choices in their Medicaid state plans. These plans describe which types of services the state will cover, which people the program will cover, what qualifications providers must meet, and how much they will be paid. States obtain approval for changes to these policies by submitting a state plan amendment (SPA) to CMS, which is the federal agency that administers the program. If a state wishes to implement a program policy that does not meet standard federal rules, such as covering a service that is not a standard benefit or limiting the number of enrollees who may receive a service, it must obtain CMS approval of a waiver of that rule. There are several types of waivers, which offer varying types of flexibility to states. Collectively, waivers, state plans and SPAs are referred to as federal authorities. The federal authorities that states use to provide LTSS, including caregiver supports, are described here in order of the flexibilities they offer states (least to most).
State Plan Services
Among LTSS, federal rules require states to cover nursing facility and home health services in their state plans (making them mandatory benefits). States may also choose to cover several optional LTSS benefits in their plans, including personal care, services in an intermediate care facility for individuals with intellectual disability (ICF/ID), and inpatient psychiatric services for individuals under age 21. Services provided under a state plan must be available to Medicaid enrollees across the state in the same amount, scope, and duration. Enrollees must also be able to choose the Medicaid-enrolled provider for their care. Also, under the mandatory Early and Periodic, Screening Diagnosis and Treatment (EPSDT) benefit, states must provide all services that can be covered under federal Medicaid law that are needed to correct or ameliorate a child’s physical, developmental, or mental condition(s). In no case can a state cover a service provided by someone who is not covered by the program, such as a family caregiver who is not also a Medicaid enrollee. The state may cover benefits, such as respite care, that are provided to the enrollee but also support the caregiver.
As previously mentioned, states also use their state plans to document which individuals they will cover. There are both mandatory and optional eligibility groups. Mandatory groups include a few who are likely to need LTSS, such as individuals receiving Supplemental Security Income (SSI). Most people who receive LTSS, such as individuals eligible for HCBS under institutional rules, are, however, members of optional eligibility groups. Many people qualify for Medicaid based solely on their income. These people may qualify to receive LTSS based only on their functional need. For example, their need for assistance with ADLs or IADLs must be sufficient to meet a state standard, which is usually set at the level needed to qualify for institutional care, such as that provided by a nursing facility. Many states have also chosen to cover some people who need LTSS whose income would otherwise be too high to qualify for Medicaid. These people must meet both financial and functional criteria to qualify for Medicaid. Family caregivers are not a group that states may choose to cover under their state plan.
In recent years, Congress has enacted legislation that offers states greater ability to cover HCBS under a state plan. States may now choose to offer the following coverage by obtaining CMS approval of an SPA. (Note that under these provisions, states may not cover family caregivers nor may they provide services to family caregivers.)
Section 1915(i) of the Social Security Act was enacted as part of the Deficit Reduction Act of 2005 (DRA) and amended by the Patient Protection and Affordable Care Act of 2010 (ACA). Under this provision, states can elect to provide HCBS to older adults and individuals with disabilities by submitting an SPA. Eligibility for the services is determined based on functional and financial criteria. Medicaid enrollees with incomes up to 150 percent of the federal poverty level (FPL) who meet functional criteria set by the state may receive the HCBS. States may also opt to extend the services to individuals with higher incomes, if they would qualify for one of the state’s HCBS waivers (i.e., qualify for care in an institution, such as a nursing facility, hospital or ICF/ID). States may choose to allow enrollees to self-direct services, enabling enrollees to hire a caregiver of their choice, including a family caregiver, to provide their Medicaid-covered services. States may target this service to subgroups of enrollees based on age, disability, diagnosis, and/or eligibility group, but if they choose to do so they will need to seek a renewal of their SPAs every five years. States may not limit the number of enrollees they will serve under this provision nor may they limit program availability based on geography. As of August 2020, 19 states had a current 1915(i) SPA. (Three had SPAs that were no longer in effect.)[20]
Section 1915(j) of the act was enacted as part of the DRA. Under this provision states can elect to allow enrollees to self-direct the personal assistance services for which they qualify by obtaining approval of an SPA. As previously indicated, self-direction enables enrollees to use Medicaid funding to pay family caregivers for providing personal assistance services. Through the SPA, states establish policies about whom the Medicaid enrollee may hire, including whether or not the enrollee may hire legally responsible relatives. States can limit the number of enrollees who can choose to self-direct and can limit program availability to part of the state. As of May 2017, eight states had a 1915(j) SPA.[21]
COVID 19 and Family Caregiving under Medicaid
States have taken action to support enrollees and their caregivers, including family caregivers, during the COVID-19 pandemic. Most often, states have used Appendix K amendments, which were created to speed response to national disasters, to modify their 1915(c) home- and community-based services waivers to incorporate flexibilities that can support family caregivers, such as flexibilities on home-delivered meal services or allowing family caregivers to receive reimbursement for providing specified services. As of August 2020, almost all states and Washington, DC have submitted at least one Appendix K application to amend a waiver. Information about states that have submitted Appendix K amendments is available at Medicaid.gov.
- At least one state (Georgia) has used Section 1135 waiver authority, which allows waivers of federal Medicare, Medicaid, and Children’s Health Insurance Program rules in a public health emergency, to temporarily allow payment for personal care services provided by legally responsible individuals, including legally responsible family caregivers.
- Six states have submitted COVID-19-related 1115 waiver requests, including North Carolina’s request for waivers to allow expedited LTSS eligibility.
Source: CMS
Section 1915(k) of the act (i.e., Community First Choice or CFC) was enacted as part of the ACA. Under this provision states may elect to provide personal care and a limited package of associated services to most Medicaid enrollees who require an institutional level of care by obtaining approval of a SPA. States may allow self-direction of these services. To incent uptake the federal government offered to pay a greater share of the cost of providing CFC services than other services. As of August 2020, nine states had an active 1915(k) SPA.[22]
Waivers
States primarily use two types of waivers to provide LTSS. A 1915(c) waiver allows the provision of HCBS while 1115 waivers allow the waiver of almost all federal Medicaid rules under certain circumstances. An 1115 waiver is the only federal authority under which a state Medicaid program can currently cover or provide services to family caregivers who do not otherwise qualify for Medicaid. Unlike SPAs, waivers are approved for a defined period of time after which states must secure approval of a new waiver or revert program policies back to standard Medicaid rules.
Section 1915(c) of the act was enacted in 1983. A 1915(c) waiver enables states to offer HCBS services as an alternative to institutional care. As of August 2020, 47 states and Washington, DC were operating almost 300 HCBS programs under approved 1915(c) waivers.[23] States can target these waivers to any group of enrollees who meet the state’s criteria to receive institutional care (e.g., adults with physical disabilities or children with autism). States may also:
- Limit the number of enrollees who may participate in the program;
- Limit the program to certain parts of the state;
- Cover people in the community who meet the financial standard to qualify for institutional care; and
- Offer a range of HCBS benefits, including services provided to the enrollee that also support family caregivers.
Among other requirements, states must demonstrate that the cost of providing services under the waiver will be no more than the cost of providing institutional services and ensure that the services are provided under a person-centered plan of care. Waivers are granted for no more than five years.
Section 1115 of the act has been part of the Medicaid program since its creation in 1965. These Research and Demonstration Waivers can, with the approval of the HHS Secretary, be used to waive almost any federal Medicaid rule, including those that restrict the provision of services to family caregivers. These waivers must be designed to allow research and demonstration projects (including statewide projects) and “promote the objectives of the Medicaid program.” They must also be budget-neutral, meaning that the cost to the federal government of serving enrollees under the waiver must be no more than what the cost would have been without the waiver. These 1115 waivers are usually approved for an initial five-year period followed by three- to five-year renewals. In FY 2018, three states (Arizona, Rhode Island, and Vermont) delivered HCBS services solely under an 1115 waiver. Another nine states delivered HCBS services under both 1115 and 1915(c) waivers.[24]
Medicaid Managed Care Opportunities
In 2019, 36 states enrolled at least some Medicaid enrollees with disabilities and older adults into Medicaid managed care programs—and 26 states enrolled more than half of the members of these populations into MCOs.[25] In these programs, the state Medicaid agency contracts with a managed care organization (MCO) or other managed care entity to deliver a specified package of benefits to enrolled enrollees. In 2019, 23 states operated managed LTSS (MLTSS) programs through which the state delivered LTSS services through MCOs to one or more groups of enrollees.[26]
Managed care offers three additional opportunities to support family caregivers. States establish performance expectations in the contracts they sign with MCOs and other managed care entities, including expectations that support family caregivers. As will be discussed in the Innovations section, Tennessee, for example, requires MCOs to formally assess caregiver needs as part of each enrollee’s care planning process. Florida requires its MCO that serves children and youth with special health care needs (CYSHCN) to provide training to family caregivers which will enable them to better care for their children with special health care needs. MCOs and other types of managed care entities can also, with the approval of the state, offer their members services or settings in-lieu-of one covered by a state plan. The cost of these services is usually considered in MCO payments. Finally, MCOs and other types of managed care entities can also voluntarily provide value-added services to their enrollees. Value-added services are services that are not in the state plan. Florida’s MCO for CYSHCN offers value-added benefits that support caregivers, including benefits counseling and behavioral health counseling. The cost of value-added services is not considered in MCO payments.
Addressing Medicaid Enrollees’ Social Determinants of Health Needs
In recent years, both the federal and state governments have recognized the importance of addressing the social determinants of health (SDOH) to improve overall health. It is now broadly accepted that clinical care alone may not produce health outcomes. Factors such as food and housing insecurity have major influences on health outcomes.[27] In light of this, some states have, with CMS support, been developing pathways to address some SDOH needs of Medicaid participants. Many of these result from the flexibilities offered by Medicaid managed care. Others rely on waivers and SPAs. While a family caregiver is not the same as an SDOH, they like an SDOH have a major impact on Medicaid enrollees’ health and well-being. Therefore, the paradigm shift that led to state and federal government action to address SDOH for Medicaid participants may lay the groundwork for a similar shift that not only recognizes the needs of family caregivers but meets more of those needs.
Introduction to Family Caregiver Support in Medicaid
It is important to understand the basics of family caregiving in Medicaid when considering the innovations and recommendations presented in this report. This section provides that information and details who can receive and who can deliver family caregiving, as well as introductory information about the types of supports that Medicaid currently provides to family caregivers.
Children and Family Caregiving Across the Lifespan
This report explores issues in family caregiver support across the lifespan, but there are several important differences between family caregiving to children and to adults, including:
- Determining children’s functional eligibility for HCBS, which is often a major entry point for family caregiver support, is complicated by the parent’s expected role. Functional eligibility is traditionally tied to the need for assistance with ADLs or IADLs like bathing, dressing, and cooking — activities that parents are expected to assist their children in completing.
- Children are expected to be able to act more independently as they grow older. While states have noted the benefit of leveraging a universal assessment across HCBS programs, children may benefit from an assessment that is tailored to identify their age-specific needs.
- Many states, due to program integrity concerns, have established policies that prevent payment to legally responsible caregivers (parents and legal guardians) under a self-directed HCBS option. While these concerns are real, they need to be balanced with the potential impact of that lack of payment on the caregiver parent.
Source: Honsberger, K, et al. State Approaches to Reimbursing Family Caregivers for Children and Youth with Special Health Care Needs through Medicaid. NASHP, report forthcoming.
Whom Do Family Caregivers Serve?
Eligible older adults, children, and adults with physical, intellectual, developmental, or cognitive disabilities can receive services through Medicaid, along with people with behavioral health needs. Family caregivers serve members of all of these groups. Family caregivers care for those who reside in institutions as well as those who live in the community. Also, the family caregiving role can begin before the enrollee becomes functionally eligible for institutional care (i.e., meets institutional level of care requirements), which is the point at which the enrollee qualifies for both institutional and HCBS services. Unfortunately, little is known about the demographics, health conditions, or functional status of the group of enrollees who are served by family caregivers. However, the information presented here, while not specific to this group, does provide some insight into its probable make-up.
CYSHCN, adults with disabilities, and older adults are most likely to need the support of family caregivers. In FY 2015, an estimated 8 percent of approximately 70 million Medicaid enrollees were ages 65 and older, and 15 percent were people with disabilities under the age of 65.[28] Further, the Medicaid and CHIP Payment and Access Commission (MACPAC) estimates that in 2013, approximately 600,000 dual-eligible (those covered by both Medicaid and Medicare) used HCBS waiver services, and about 400,000 used HCBS State Plan services.[29] In 2017, 47 percent of 13.3 million CYSHCN were covered through Medicaid and the Children’s Health Insurance Program (CHIP).[30]
Medicaid enrollees participating in HCBS programs are most likely to rely heavily on family caregivers to augment the services provided by their Medicaid program. According to the Kaiser Family Foundation,[31] in FY 2018 about 2.3 million enrollees received HCBS under a state plan (home health and/or personal care services). About 2.5 million did so under a waiver — with 1.8 million receiving HCBS under a 1915(c) waiver.[32] Information about the national number of individuals in different populations receiving HCBS through waivers or state plans is limited, although one study estimated about 630,000 individuals with I/DD were served on 1915(c) waivers in FY 2015.[33]
Who Are Family Caregivers?
The term ‘family caregivers’ is used to convey the difference between informal or “family” caregivers and those who are caregivers by profession. In other words, family caregivers are not just immediate relatives but also the neighbors, friends, and others who provide care. There is also a dearth of information about Medicaid enrollees’ family caregivers in terms of demographics, contributions, and needs, distinct from those of other family caregivers. It is expected that as the characteristics of Medicaid enrollees vary from that of the US population as a whole, the characteristics of their family caregivers will similarly vary. Also, Medicaid is designed to serve poor or low-income people and, as a result this population has fewer resources than others to dedicate to their own care. (This income difference probably holds true even for those who qualify for HCBS services, which often allow people with higher incomes to enroll into Medicaid.) The relative lack of financial resources may result in a higher caregiver burden, and perhaps different priority needs, for the family caregivers of Medicaid enrollees than caregivers as a whole.
A 2014 snapshot of family caregivers to Medicaid enrollees in Texas found:
- 19% were spouses;
- 47% were their children;
- 10% were other relatives; and
- 12% were grandchildren, grandparents, life partners, or siblings.
- 97% were unpaid.
During report production authors identified one state (Texas) that had collected information on family caregivers from applications submitted to three community services programs. Only one of these programs was Medicaid-funded, but all incorporated income limits, thus the report’s findings begin to reveal the demographics and needs of Medicaid enrollees’ caregivers in one state. In 2014, this assessment of informal caregivers found that 19 percent of respondents were spouses, 47 percent were children of the care recipient, 10 percent were other relatives, and 12 percent were grandchildren, grandparents, life partners or siblings of the care recipient, with 97 percent reporting they were not paid to provide care. Additionally, 38 percent of responding caregivers were self-reported as Hispanic, 26 percent were non-Hispanic White, and 25 percent were Black/African American. Also, 84 percent of informal caregivers were of working age (between the ages of 18 and 64).[34]
Supports Medicaid Provides to Family Caregivers
States have long recognized the importance of supporting family caregivers and all provide some type and amount of support. The major types of support that states currently offer include services that serve both the enrollee and the caregiver, including payment, training and education, and care coordination.
Services for the enrollee that also support the caregiver. All states must provide home health services in their state plans. These services, although provided to the enrollee, also support the family caregiver. Other similar types of services that at least some Medicaid programs provide include home health aide services, home modifications, transportation, home-delivered meals, and adult day care. Some Medicaid HCBS programs also cover respite support for care recipients, which can give relief to family caregivers. Respite refers to providing short-term care in order to allow a primary caregiver to have a break from caregiving. One study found that, in 2015, 47 states and Washington, DC provided some form of caregiver support or respite in state plan or waiver programs for older adults and people with physical disabilities.[35] Also, a 2019 article analyzing 1915(c) waivers that included children with complex medical needs found that, across 142 waivers in 45 states, 81 percent of waivers (115) covered respite care.[36]
Payment. All 50 states and Washington, DC have at least one Medicaid self-direction option.26 Self-direction enables enrollees to use Medicaid funding to pay for aides of their choice, including family caregivers, to provide personal assistance services. Further, states can define which family caregivers can be paid under the self-directed option. Representatives who direct the services that enrollees receive may not also receive payment for providing care, and in some states, family caregivers cannot live in the same home as the care recipient and receive payment. States may place other restrictions on this flexibility. Additionally, states have reported considerations about flexibilities in family caregivers’ ability to receive payment due to concerns about replacing enrollees’ natural caregiver support.[37]
Training and education. Training supports can be targeted toward helping family caregivers of specific populations — for example, supporting training and education for caregivers of individuals with Alzheimer’s disease or related dementias, or caregivers of individuals with developmental disabilities. Education and training could also include training on helping caregivers assist care recipients with functional needs. According to a NASHP scan,[38] as of March 2020, approximately half of states provided some form of education, training, or counseling support through a Medicaid waiver or SPA, targeted toward family caregivers of older adults and people with functional limitations. Another study that analyzed 88 I/DD waivers from 41 states and Washington, DC, reported 29 waivers (about 33 percent) offered some form of family or caregiver training.[39] A 2016 review of waivers for children with autism found that 10 waivers specifically targeting children with autism included support for caregiver training.[40]
Care coordination. Medicaid programs can also cover care coordination services. These services, often provided through a person-centered plan of care based on a formal assessment of the enrollee’s needs and goals, can seek to coordinate different LTSS, other Medicaid-covered services, and social services. This support relieves caregiver burden. According to Kaiser Family Foundation,26 in FY 2018, seven states offering 1915(i) state plan services reported offering case management services (two states reported I/DD target populations, two states reported seniors and/or people with physical disabilities target populations, and three states reported mental illness target populations), though this data was limited by the small number of states responding. Also, a 2013 AARP report found that approximately 30 percent of states included some form of family caregiver assessment in their Medicaid HCBS waiver assessment processes.[41] These states have begun to build an infrastructure that would enable them to consider caregiver needs in enrollee care planning.
How the Federal Government Promotes State HCBS Innovations
The federal government has offered funding to states to incentivize and support implementation of new strategies that shift care toward HCBS. Two programs offer examples of two different funding mechanisms.
Balancing Incentive Program (BIP). BIP was created by the Affordable Care Act and ran from 2011 to 2015. It provided funding to states by temporarily increasing the federal share of the cost of providing LTSS (increasing the Federal Medicaid Assistance Percentages, or FMAP, for the services). It targeted states with a strong bias toward institutional services in their Medicaid programs. Only states that were spending more than half of their LTSS funding on institutional services were eligible to participate. Participating states committed to increasing non-institutional LTSS spending in order to receive the FMAP increase. For example, states spending 25 to 50 percent on non-institutional LTSS agreed to increase non-institutional LTSS spending to 50 percent by September 2015 in order to receive a 2 percent increase in FMAP for specified non-institutional LTSS provided during the term of the program. Participating states also committed to implementing No-Wrong-Door systems to increase access to information on Medicaid LTSS, core standardized assessments, and conflict-free case management. States used the funding to pay for new or expanded noninstitutional services. They also received technical assistance from contractors and CMS staff. According to an ASPE evaluation, the majority of the 18 participating states met goals for increasing the proportion of HCBS spending and developing infrastructure.
Real Choice Systems Change Grant Program. Beginning in 2001, the Real Choice Systems Change grant program was designed to support states in shifting LTSS spending towards HCBS through development of infrastructure. In 2001, CMS made noncompetitive $50,000 starter grants available to states, and initial grants averaged $300,000 to $800,000 over a three- to four-year period, targeting specific parts of states’ HCBS systems. Grantees were required to provide a 5 percent non-financial contribution to the total grant award. A shift occurred in 2005 toward awarding fewer grants for larger amounts in order to support overarching change. A synthesis of initial states’ experience shows that almost all grantees reported successfully implementing and sustaining their improvements. According to the synthesis, some grantees reported that they would have been unable to implement the improvements absent the grant funding and many noted that they were able to leverage this grant opportunity to implement additional reforms.[42]
Medicaid Innovations to Address Five Critical Family Caregiver Issues
Many state Medicaid agencies have already implemented strategies that support family caregivers, as highlighted in the Medicaid Primer section. Here are some of the more recent and less common strategies states have used to address five critical issues in family caregiving. These strategies were chosen to represent state efforts to support the family caregivers of a range of enrollees (e.g., from CYSHCN to older adults), implemented through different delivery systems (e.g., managed care and fee-for service), and by a diverse set of states (e.g., rural and urban). Other states have implemented innovations that address these and other issues and clearly states will continue to develop new innovations that address emerging issues. The critical issues and state innovations presented here should be considered first steps toward identifying promising practices in family caregiving — and not the final word about best practices that all should adopt.
Develop outreach to inform enrollees and caregivers about available caregiver supports.
Offering supports to family caregivers does little if enrollees and their families are unaware of the supports or don’t think they qualify for the assistance. State agencies and other organizations have already done a significant amount of work to inform enrollees and their families about available LTSS. For example, Aging and Disability Resource Centers provide information to family caregivers of all income levels in most states. But, the primary emphasis of this work is to support the individual who needs LTSS and the family’s role is often assumed to be that of helping their loved one obtain care.
Washington State’s outreach to family caregivers. Washington’s experience implementing its benefits for caregivers indicates that targeted outreach for family caregivers is often needed. When implementing its benefit for caregivers, Washington found that more individuals applied for the benefit than caregiver/care recipient dyads. They reported that one cause was that, “many informal caregivers do not think of themselves as caregivers until they become very stressed and, as a result, delay seeking these supports.” The state found it needed to conduct a broad-based awareness and outreach effort that included work with hospitals, employers, and community-based organizations. They also found benefit in partnering with local Area Agencies on Aging (AAA) to administer the outreach program. Many turn to AAAs in their local communities for help in obtaining LTSS, which gives the AAAs a natural link to family caregivers. These agencies have also contributed resources to the informing effort. Washington’s Pierce County, for example, developed a video to help family caregivers understand that help was available to them as well as their loved one. Much of the state’s effort was based on a campaign developed by the Amherst H. Wilder Foundation in Minnesota. This campaign was designed in partnership with the Minnesota Department of Human Services (which administers Medicaid[43]) and with replication in mind. The primary goal of the research-based campaign was to help caregivers recognize themselves as caregivers, a critical and often delayed first step to accessing caregiver services.
Train caregivers so that they can better meet the needs of their loved one.
As previously discussed, many states already offer training to caregivers, including family caregivers. Most training focuses on helping caregivers meet medical needs, such as training on how to use medical equipment, but some training focuses more directly on caregiver needs, such as coping skills.
Utah’s training to help caregivers deliver care. Utah’s New Choices 1915(c) waiver for adult enrollees living in institutions who wish to transition to a community setting covers training for unpaid family caregivers. The training is designed to enable caregivers to safely and effectively fulfill their responsibilities in delivering the services in enrollees’ care plans. It can include training on care regimens or the use of equipment. The training itself must be included in the care plan.[44] Similar family/caregiver training is also provided in Utah’s Community Supports and Community Transitions 1915(c) waivers that serve individuals with intellectual disabilities and other related conditions. This training may include behavioral support strategies in addition to navigating service delivery systems and support for self-administered services.
Georgia’s individualized training based in care coordination. Georgia’s Structured Family Caregiving program takes the concept of targeting caregiver training to enrollee medical needs one step further by offering individualized assistance (and a daily stipend) to unpaid family caregivers who live with a qualified 1915(c) elderly and disabled waiver participant. The individualized assistance features telephone and electronic support, including access to a secure electronic system for case management documentation (e.g., care plan notes) that is shared among the care team, including the family caregiver. The family caregiver has the support of other care team members, a health coach, and a registered nurse. According to the waiver request, family caregivers receive a minimum of eight hours of training each year that is targeted to individual needs identified through caregiver self-reporting, review of caregiver documentation, or case management activities. Training may be offered through a home visit, secure electronic communication, web-based training or other ways that are, “flexible, accessible and meaningful for the caregiver.”
Georgia’s Medicaid agency began offering this program in 2019 and estimated that in FY 2020 the cost of providing the service would be about $6.9 million ($2.2 million from the state). However, the state crafted the program so that its cost would be offset by a reduction in personal support services by setting the stipend rate at the equivalent of the cost of five hours of extended personal support services and then limiting program participation to waiver participants who need five or more hours of personal support services each day. The caregiver support is offered in lieu of the personal support, so the costs are certain to be equivalent [45]
Florida’s formal training delivered by MCOs. In 2013, Florida launched a managed LTSS (MLTSS) program that serves older adults and adults with disabilities who meet nursing facility level of care criteria.[46] The MCO contract for this program requires all MCOs to offer a formal family caregiver training program as a quality enhancement. The program must address “the financial, emotional, and physical elements of caregiving, as well as outline the resources available to caregivers in crisis.”[47] Contracted MCOs must maintain at least two training providers in each county it covers. Any MCO that fails to meet these requirements may be required to pay damages of $500/day. Florida Medicaid does not factor the cost of providing this training into MCO payment.
Identify and address relevant caregiver needs as part of care planning for the enrollee.
Existing federal Medicaid rules provide a starting point for caregiver assessment. As discussed in the AARP report, Family Caregivers and Managed Long-Term Services and Supports, caregiver assessments are required under 1915(i) and managed care regulations acknowledge the need in MLTSS. The example below illustrates how states can leverage MLTSS to identify and meet the needs of family caregivers.
Tennessee’s caregiver assessment and care planning. Since 2010, Tennessee’s Medicaid agency (TennCare) has contracted with MCOs to deliver LTSS through its CHOICES in Long-Term Services and Supports program (CHOICES). CHOICES serves adults with disabilities and those over age 65 who require LTSS. In its contract with MCOs, TennCare requires them to conduct a formal assessment of an enrollee’s caregiver and to include actions that address caregiver needs identified in the assessment within the plan of care developed for the enrollee. MCOs must assess the caregiver within 10 days of the enrollee’s referral to CHOICES and before completing the enrollee’s person-centered plan of care — and then at least once per year thereafter. Caregiver assessment may be conducted as part of enrollee assessment.
TennCare does not require that all MCOs use the same caregiver assessment tool. However, the agency does require each MCO to obtain approval for a standardized tool that the MCO will use in all assessments. TennCare’s contract also specifies the domains that the assessment must address. Required domains include:
- The family caregiver’s willingness and ability (e.g., employment status and other caregiving responsibilities) to serve effectively in that role;
- The caregiver’s health and well-being as it relates to the caregiver’s ability to support the person needing care;
- Caregiver stress due to providing care;
- Caregiver needs for training to assist the person needing care; and
- Service and support needs to better prepare the caregiver for their role.
Caregiver training and support needs identified in the caregiver assessment must be documented in the enrollee’s plan of care.
Offer services to help family caregivers.
Caregiving is a very stressful task, especially for family caregivers who often have other responsibilities, such as a holding a job or caring for other family members. This stress is intensified when the enrollee’s health, cognitive abilities, or ability to care for themselves decline. This stress can become so intense that caregivers become unable to reliably, effectively and safely perform their caregiving duties. If this occurs the enrollee’s health may suffer, the individual may need to be admitted to an institution, or the family caregiver may need to be replaced with a home health aide or other type of provider. Some states, such as the four profiled here, have found ways to offer family caregivers certain services that can help them manage the stress of caregiving, including connecting them to community resources that can help address their own potential needs for social services, such as housing assistance. As described below, Tennessee and Washington also use their 1115 waiver authority to extend these benefits to those at-risk of institutionalization.
Colorado’s coverage of family counseling for family caregivers. Since 2007, Colorado Medicaid has operated a 1915(c) palliative care waiver that serves children with life-limiting illness. The families that care for these children, who are unlikely to live long, are under extreme stress. Therefore, Colorado covers therapeutic life-limiting illness support, which includes family counseling services to “alleviate the feelings of devastation and loss related to a diagnosis and prognosis for a limited lifespan, surrounding the failing health status of the client, and the impending death of a child.” The intent of (and justification for) offering this service is to help the family, especially the caregiver, manage the stress that results from providing the intensive, daily care that a terminally ill child needs to, in turn, increase the likelihood that the child can continue to be cared for at home instead of in an institution. The counseling can be delivered by a licensed social worker, psychologist, and others. The provider can attend physician visits and hospital discharge meetings or connect the family with community resources. The family can receive up to 98 hours of therapeutic life-limiting illness support, every 365 days.
Florida’s requirement that an MCO provide behavioral health services for family caregivers. In 2016 Florida’s Children’s Medical Services (FCMS), which serves CYSHCN, began redesigning the program, which has operated for over 20 years. The goals of the redesign included enhancing care coordination and expanding benefits through a managed care contract (i.e., contract requirements and value-added benefits). The redesign was implemented in February 2019 when FCMS began providing statewide services through a single managed care contract (WellCare). Under the MCO’s contract it provides enhanced benefits to enrolled children that also support family caregivers, such as expanded non-medical transportation and housing assistance. The MCO also offers two value-added benefits that explicitly help family caregivers. As described on the program website, these are:
- Behavioral Health Services for Caregivers: Education and training for patient self-management by a qualified, non-physician health care professional using a standardized curriculum and 30-minute, face-to-face sessions with the patient/caregiver/family.
- Computerized Cognitive Behavioral Analysis for Non-Medicaid Caregivers: Including, health-focused clinical interview, behavioral observations, psychophysiological monitoring, health-oriented questionnaires, health and behavioral interviews. This counseling can be provided without the enrollee’s presence.[48]
Tennessee’s development of a family caregiver benefit based on caregiver input. During 2013 and 2014, TennCare conducted an extensive stakeholder input process to design a new HCBS program to better serve people with I/DD and their families. This process sought input from providers, advocacy groups, I/DD waiver participants and their families, and people on the waiting list to join the waivers and their families. The process sought input through individual interviews, statewide community meetings/discussion circles and a survey. When all of the input was analyzed, state officials unexpectedly found that the benefits that family caregivers reported they would find most helpful differed significantly from those that providers expected them to value. For example, HCBS providers thought that caregivers would benefit most from respite care, but waiver participants and their families reported that caregivers would benefit most from, “consistent, well-trained, quality staff,” and those on the waiting list asked for “personal assistance.” Both participant and waiting list respondents chose “family education/ navigation/support” as their second priority, but both groups also equally valued another type of service. The stakeholder process culminated in an amendment to the state’s 1115 waiver creating the Employment and Community First CHOICES (ECFC) program in 2016. (Note: This program structure is only currently possible through a 1115 waiver.)
Originally, the ECFC program divided participants into three categories: essential family supports, essential supports for employment and independent living, and comprehensive supports for employment and community living. (Two other categories for those with intensive behavioral health needs were added later.) Each group has access to a different benefit package and annual expenditures are capped at different dollar amounts. All children who live at home with their families receive the essential family supports benefit as do some adults who choose that benefit. All other adults receive one of the other two benefits depending on whether they qualify for nursing home placement. All three benefits include services that support caregivers (e.g., respite care and community transportation). However, the essential family supports benefit consists almost entirely of services to support and sustain the family caregiver in supporting the participant (e.g., caregiver stipend in lieu of supportive home care and health insurance counseling/forms assistance) while the other two benefit groups are aimed mostly at helping the participant (and supporting the caregiver to help the participant) achieve employment and integrate into the community (e.g., job coaching and independent living skills training).
Washington State’s coverage of a caregiver benefit package. In 2017, Washington established two benefits that include services for family caregivers. For the first five years of the program, both benefits are paid for by federal Medicaid funding under the state’s 1115 waiver. The Medicaid Alternative Care (MAC) benefit is targeted to older adults (55 and older) who qualify for Medicaid-financed LTSS but have chosen to wrap services around their unpaid caregiver rather than receive traditional Medicaid-funded services. The Tailored Supports for Older Adults (TSOA) benefit targets older adults who are not currently Medicaid-eligible but are at-risk for future Medicaid-financed LTSS use. TSOA offers two packages of services. If the older adult has an unpaid caregiver, the adult receives a package that consists solely of supports for the benefit of the caregiver. If the older adult does not have an unpaid caregiver, the package offers services, such as in-home personal care, to the older adult. According to state officials, the ability to offer enrollees a choice of individual or caregiver benefits (rather than a package that included both individual and caregiver benefits) has been critical to making the program work for both enrollees and the legislature. This option, which is currently only available under an 1115 waiver, like the concept of rebalancing the LTSS system puts choice in the hands of the enrollee and offers the opportunity for cost savings because the caregiver benefit is much less costly than the individual benefit.
The two benefit packages are almost identical, with both including the following services targeted to the caregiver.
- Caregiver assistance services, are defined as, “Services that take the place of those typically performed by the unpaid caregiver in support of unmet needs the care receiver has for assistance with activities of daily living and instrumental activities of daily living,” such as home delivered meals.
- Caregiver training and education, is defined as, “Services and supports to assist caregivers with gaining skills and knowledge to implement services and supports needed by the care receiver to remain at home or skills needed by the caregiver to remain in their role,” such as caregiver coping training and caregiver clinical training.
- Health maintenance and therapies, are defined as, “Clinical or therapeutic services that assist the care receiver to remain in their home or the caregiver to remain in their caregiving role and provide high quality care,” such as counseling.
Other services are also included in the benefits that are primarily targeted to the care recipient. but also support the caregiver and the TSOA package, which serves people who are not yet eligible for Medicaid and also offers personal assistance services to the care receiver. These benefits are both self-directed and, within the assigned budget, services are selected based on both enrollee and caregiver need.
Over a six-month period, caregivers who received support from these programs showed a statistically significant improvement in outcomes such as, stress burden, comfort with the care giver roles and depression. Also, there are indications that participation in these programs delayed the need to access Medicaid LTSS.[49] In 2019, Washington’s TSOA served a total of 1,574 dyads (caregiver/care receiver) and 3,033 individuals at a total cost of about $8.5 million; during this same time Washington served 142 MAC dyads at a cost of about $166,272. Officials indicated that the cost of the programs was offset by reductions in the need for LTSS.[50]
Facilitate family caregivers’ ability to receive payment for the services they provide.
As described in the Medicaid primer section, states can use multiple federal authorities to implement self-directed care in HCBS, which enables enrollees to use Medicaid funding to pay aides of their choice, including family caregivers for the services they provide. All but one state has implemented these provisions for at least some enrollees who receive HCBS.[51] However, there are barriers to payment even within these programs, which some states have moved to address.
Colorado’s waiver of scope of practice laws to enable family caregivers to provide skilled health-related activities. Colorado has addressed the barrier that state scope-of-practice laws can sometimes pose to family caregiver payment. This state offers in home support services (IHSS) as a benefit in three of its 1915(c) waivers, so the service is available to both children and adults. IHSS is a self-directed benefit, so waiver participants can choose family caregivers to serve as their paid attendants. However, an IHSS agency acts as the enrollee’s agent — hiring, training, and paying the caregiver/employee. If the participant chooses the family caregiver as an attendant, this unlicensed caregiver can be paid for providing health maintenance services, including assistance with skilled health-related activities (e.g., skilled feeding or skilled bowel care) that are typically provided by a certified or licensed attendant. Colorado waived the Nurse Practice Act for IHSS, which is what enables the unlicensed caregiver to be paid for providing the skilled services. All IHSS agencies must employ a registered nurse who is responsible for verifying the caregiver’s skills and competency. Waiver participants may receive up to 40 hours of personal care from a relative each week. They can also receive more personal care from other providers.[52]
Idaho’s program integrity process recognizes the unique situation of family caregivers. An important aspect of facilitating payment to family caregivers is to maintain public support for these payments. Therefore, maintaining program integrity (preventing fraud, waste, and abuse of Medicaid funds) is key to facilitating caregiver payment over the long term. As one state official observed, the vast majority of family caregivers comply with Medicaid program rules and bill appropriately. But a few people do take advantage of the system, which can be very problematic, especially if these cases are reported in the media. Idaho officials, recognizing that paid family caregivers usually provide services to only one person, understand that caregivers might not follow all program rules simply because they do not understand the complexities of Medicaid billing. Idaho Medicaid staff work very closely with the family members to ensure that they understand the complicated process of employer records and documentation. Family caregivers often provided the same care without pay before being tapped by their family member to provide paid care. So, one shift that can be difficult is moving from simply providing the care to both providing the care and documenting their time for billing purposes. Idaho has also established close connections between the team that trains the caregiver on Medicaid billing and the program integrity team so that program integrity staff can help improve training for family members who are now providers.
How Can the Federal Government Help States Implement Family Caregiver Strategies?
The actions for federal consideration described here were developed by the authors based on previous NASHP work in this area, their knowledge of state health policy, presentations and discussions at the RAISE advisory council meetings, and significant input from state policymakers. These actions would enable the federal government to help states build on the many strategies that states are already using to support family caregivers. They are not intended as stand-alone actions but rather a package that would culminate in widespread state adoption of innovative practices.
When considering these actions, it is important to understand that the current top priorities of most Medicaid officials are to address the COVID-19 pandemic and plan for related state budget reductions. As a result, it is unlikely that states will choose to implement bold new initiatives, especially those that require upfront investments, now. However, there are factors that could lead states to consider new strategies even in these challenging times. States are already making a financial investment in family caregivers who are paid under a self-directed HCBS program and also already have these individual’s contact information. These factors would both ease implementation and strengthen the incentives for states to implement innovations targeted to this group. However, most importantly, the epidemic is taking the greatest toll on nursing facility residents,[53] as well as low-income individuals and communities of color.[54] Family caregivers can provide the culturally and linguistically competent services that help people remain in their own homes and connected to their communities. Increased support for family caregivers, especially supports that improve their ability to care for their loved ones and manage caregiver stress so they can continue to provide that care, could help mitigate the impacts of the virus.
This situation makes the collection of information about state innovations and family caregiver needs and priorities particularly important as this information would enable states to understand the costs and benefits of their options for support, as well as target those efforts to the specific needs of Medicaid enrollees’ family caregivers. States would also be more likely to quickly adopt these strategies if there was an associated implementation funding strategy, such as that created for the BIP or a dedicated technical assistance center, such as those created to support other national efforts.
Action 1: Conduct a comprehensive, systematic effort to identify and disseminate information about family caregiver strategies tested by states. This report has identified state innovations that address five critical issues in family caregiver support. These issues and innovations are just the first step in identifying the full scope of state innovations. It is expected that other states have also developed innovations that address these and other critical issues that authors were unable to identify during the writing of this report. Because states differ in terms of operating authority, delivery systems, and policy environment, the same innovation is unlikely to work well in all states. Therefore, states seeking to improve family caregiver support by adopting tested strategies would benefit from access to a more comprehensive toolbox of promising practices. Ideally, the information in the toolbox would offer states sufficient information to assess their options and begin developing their own plans, type of support, target population, key partners, federal authority used, implementation cost, expected impact on state budget, anticipated and confirmed outcomes, etc. The state officials who reviewed this report emphasized the importance of having information that details strategy effectiveness for their decision making. The federal agencies dedicated to research, such as the office of the Assistant Secretary for Planning and Evaluation, Office of Office of Behavioral Health, Disability, and Aging Policy, could commission this initiative.
Action 2: Measure the number, demographic, contribution, and needs of family caregivers who assist Medicaid enrollees. Little is known about the demographics, contributions, needs, and priorities of family caregivers who assist Medicaid enrollees as distinct from other caregivers. Nor is there an estimate of the economic value these caregivers provide to states. Many states use the information gathered by the Centers for Disease Control and Prevention’s Behavioral Risk Factor Surveillance System (BRFSS) to better understand the demographics and needs of caregivers in their state. However, not all states collect caregiver information and the data collected may not be specific to caregivers of Medicaid enrollees. A few states have made efforts to collect data about Medicaid enrollees’ family caregivers and their needs. Texas, for example, gathers information on caregivers (demographics, hours provided, stress level, effect on employment, etc.) for a state legislative report as part of the assessment process, but it does not track caregiver needs. Also, as Tennessee discovered, family caregivers’ assessment of which services would help them most differed from that of providers and officials themselves. A better understanding of the needs, priorities, and contributions of those who care for Medicaid enrollees would enable states to more efficiently and effectively target their efforts to implement caregiver supports. States would also benefit from assistance, such as toolkits or templates, that would help them use this information to select, implement, and evaluate current or future strategies. The information presented to the RAISE advisory council members in May, as well as their discussion of that information provides a good starting point for this effort. For example, changes to existing national data collection efforts, such as BRFSS, could create an avenue for collecting Medicaid-specific caregiver data.
Action 3: Promote innovative family caregiver support strategies already tested by leading states. Much of this report is dedicated to exploring a sampling of the strategies and innovations that state Medicaid agencies have already implemented to support family caregiving. 
Because supporting family caregivers can help Medicaid meet its objectives, it is expected that more states would implement these innovations if they were encouraged to do so and had the resources. But not every innovation is right for every state, and one aspect of the assistance that the federal government could provide is helping states make data-driven decisions about which strategies would work best in their state. The federal government could use its resources to broadly inform other states about these innovations and offer funding to encourage state adoption. Other tools, however, could also foster spread of tested innovations without a major investment of federal resources. For example, developing waiver and SPA templates, such as those developed to support state uptake of Health Homes, could be developed to assist states seeking to adopt certain strategies. CMS also has a portfolio of other technical assistance resources and states could draw on those to ease implementation of specific strategies.
Action 4: Support state efforts to continue to advance their existing innovations and develop new ones. Although, as illustrated in the Medicaid innovations section, some states have developed and tested innovative family caregiver supports, more work is needed. For example, other strategies could be developed to address the critical issues identified in this report in order to begin to develop options that would work under different state circumstances and for different populations (e.g., caregivers to CYSHCN are likely to need different supports than caregivers to older adults). It is expected that leading states will continue to refine and build on their existing family caregiver support strategies. These states have already exhibited a commitment to improving family caregiver support and the federal government has resources to help them do so. These states could leverage the individual technical assistance that CMS staff offers to states, which identifies “promoting community integration through long-term services and supports,” as a program area. These states could also benefit from the type of technical assistance offered by the Medicaid Innovation Accelerator Program, which has identified “promoting community integration through long-term services and supports,” as a program focus.
Summary
Family caregivers play an important role in states’ efforts to eliminate institutional bias in Medicaid’s LTSS system. Their contributions also offset the cost of personal care services and have the potential to delay institutional admissions and prevent avoidable hospitalizations. All state Medicaid agencies already support family caregivers through training, services, or, sometimes, payment. However, there are strong indications that family caregivers (and the Medicaid enrollees they care for) could benefit from additional supports. Some states have implemented innovative strategies that address critical issues in family caregiver support. An examination of these strategies, research, and input from state officials identified four interdependent actions that the federal government could take to improve family caregiving as part of the national strategy.
- Promote innovative family caregiver support strategies already tested by leading states.
- Support state efforts to continue to advance their existing innovations and develop new ones.
- Conduct a comprehensive, systematic effort to identify and disseminate information about family caregiver strategies tested by states
- Measure the number, demographics, contributions, and needs of the family caregivers who assist Medicaid enrollees.
It is important to acknowledge that the current pandemic and its expected impact on state budgets will, at least temporarily, make it difficult for states to contemplate implementing any new policies, especially those that require upfront investments. The pandemic, however, has also created a window of opportunity during which the federal government can prepare to support states and state officials can use to consider their options.
End Notes
[1] Soucheray, S. (2020). “Nursing homes might account for 40% of US COVID-19 deaths.” University of Minnesota Center for Infectious Disease Research and Policy. https://www.cidrap.umn.edu/news-perspective/2020/06/nursing-homes-might-account-40-us-covid-19-deaths
[2] Gebeloff, R., Lai, K., Oppel, R., Smith, M., Wright, W. (2020). “The Fullest Look Yet at the Racial Inequity of Coronavirus.” The New York Times. https://www.nytimes.com/interactive/2020/07/05/us/coronavirus-latinos-african-americans-cdc-data.html
[4] https://www.kff.org/medicaid/issue-brief/medicaid-financing-the-basics/view/print/
[5] Chidambaram, P., Musumeci, M.B., Watts, M. (2020). “Medicaid Home and Community-Based Services Enrollment and Spending.” Kaiser Family Foundation.
[6] National Academies of Sciences, Engineering, and Medicine 2016. Families Caring for an Aging America. Washington, DC: The National Academies Press. p. 216. https://doi.org/10.17226/23606.
[7] Recognize, Assist, Include, Support, and Engage Family Caregivers Act of 2017, Public Law No. 115-119, U.S. Statutes at Large H.R. 3795 (2017-2018): 1-5
[8] Van Houtven, C. H., & Norton, E. C. (2004). Informal care and health care use of older adults. Journal of health economics, 23(6), 1159-1180. https://www.researchgate.net/profile/Courtney_Van_Houtven/publication/8171549_Informal_Care_and_Health_Care_Use_of_Older_Adults/links/5a10b6aa0f7e9bd1b2bf314f/Informal-Care-and-Health-Care-Use-of-Older-Adults.pdf
[9] Choula, R., Evans, M., Feinberg, L., Houser, A., Reinhard, S. (2019). “Valuing the Invaluable: 2019 Update.” AARP Public Policy Institute. https://www.aarp.org/content/dam/aarp/ppi/2019/11/valuing-the-invaluable-2019-update-charting-a-path-forward.doi.10.26419-2Fppi.00082.001.pdf
[10] Chung, P., Elliott, M., Romley, J., Schuster, M., Shah, A., Vestal, K. (2017). “Family-Provided Health Care for Children with Special Health Care Needs.” Pediatrics January 2017, 139 (1).https://pediatrics.aappublications.org/content/139/1/e20161287
[11] Chidambaram, P., Musumeci, M.B., Watts, M. (2020). “Medicaid Home and Community-Based Services Enrollment and Spending.” Kaiser Family Foundation. https://www.kff.org/report-section/medicaid-home-and-community-based-services-enrollment-and-spending-issue-brief/
[12] Chidambaram, P., Musumeci, M.B., Watts, M. (2020). “Medicaid Home and Community-Based Services Enrollment and Spending.” Kaiser Family Foundation.
[13] Chidambaram, P., Musumeci, M.B., Watts, M. (2020). “Medicaid Home and Community-Based Services Enrollment and Spending.” Kaiser Family Foundation.
[14] https://www.medicaid.gov/sites/default/files/2019-12/ltssexpenditures2016.pdf
[15] Barrett L., “Home and Community Preferences of the 45+ Population,” Kaiser Family Foundation, Washington DC, September 2014, http://www.aarp.org/research/topics/ community/info-2015/Home-and-Community-Preferences- 45Plus.html.
[16] United States Department of Justice Civil Rights Division. “Olmstead: Community integration for Everyone.” Information and Technical Assistance on the Americans with Disabilities Act. https://www.ada.gov/olmstead/index.htm
[17] Walsh, EG et al., Potentially avoidable hospitalizations of dually eligible Medicare and Medicaid enrollees from nursing facility and Home- and Community-Based Services waiver programs. J Am Geriatr Soc. 2012 May; 60(5):821-9.
[18] Gorges R., Sanghavi P., and Konetzka R. “A National Examination of Long-Term Care Setting, Outcomes, And Disparities Among Elderly Dual Eligibles.” Health Affairs 38, No. 7 (2019): 1110–1118
[19]Centers for Medicare & Medicaid Services. “Medicaid Facts and Figures.” (Baltimore, MD: January 2020). https://www.cms.gov/newsroom/fact-sheets/medicaid-facts-and-figures#:~:text=71%2C395%2C465%20individuals%20were%20enrolled%20in,individuals%20were%20enrolled%20in%20Medicaid.
[20]States with active 1915(i) SPAs: AL: AR, CA, CT, DC, DE,IA, ID, IN, MD, MI, MN, MS, NH, NV, OH, OR, TX, WI; States with discontinued SPAs: : FL, LA, MT Source: Centers for Medicare & Medicaid Services. “Medicaid State Plan Amendments.” (Baltimore, MD: accessed August 24, 2020). https://www.medicaid.gov/medicaid/medicaid-state-plan-amendments/index.html
[21] States with 1915(j) SPAs: AL, AR, CA, FL, NJ, OR, TX, WI Source: Kenya Cantwell, “Self-Directed Services Under Medicaid 1915(j) and (k) State Plan Authorities.” Division of Benefits and Coverage, Disabled and Elderly Health Programs Group, Center for Medicaid and CHIP Services, Centers for Medicare & Medicaid Services. http://www.appliedselfdirection.com/sites/default/files/Self%20Direction%20under%201915j%20and%20k%20Slides_0.pdf
[22] States with 1915(k) SPAs: AK, CA, CT, MD, MT, NY, OR, WA. Source: Centers for Medicare & Medicaid Services. “Medicaid State Plan Amendments.” (Baltimore, MD: accessed August 24, 2020). https://www.medicaid.gov/medicaid/medicaid-state-plan-amendments/index.html?search_api_fulltext=%22community%20first%20choice%22&field_approval_date%5Bmin%5D=06/01/2001&field_approval_date%5Bmax%5D=08/05/2020&field_effective_date%5Bmin%5D=12/31/2000&field_effective_date%5Bmax%5D=08/05/2022&sort_by=field_approval_date&sort_order=DESC&items_per_page=10&page=2#content
[23] The three states not using a 1915(c) waiver to provide HCBS were: AZ, RI, and VT Source: Centers for Medicare & Medicaid Services. “Medicaid State Waivers List.” (Baltimore, MD: accessed August 24, 2020). https://www.medicaid.gov/medicaid/section-1115-demo/demonstration-and-waiver-list/index.html
[24] States using both 1115 and 1915(c) waivers to deliver HCBS: CA, DE, HI, NJ, NM, NY, TN, TX, WA Source: Chidambaram, P., Musumeci, M.B., Watts, M. (2020). “Key State Policy Choices About Medicaid Home and Community-Based Services.” Kaiser Family Foundation.
[25] Kaiser Family Foundation. (2020). Medicaid Managed Care Penetration Rates by Eligibility Group. https://www.kff.org/medicaid/state-indicator/managed-care-penetration-rates-by-eligibility-group/?currentTimeframe=0&sortModel=%7B%22colId%22:%22Location%22,%22sort%22:%22asc%22%7D
[26] Diaz, M., Hinton, E., Singer, N., and Rudowitz, R. (2019). “10 Things to Know about Medicaid Managed Care.” https://www.kff.org/medicaid/issue-brief/10-things-to-know-about-medicaid-managed-care/
[27] Braveman, P., & Gottlieb, L. (2014). The social determinants of health: it’s time to consider the causes of the causes. Public health reports (Washington, D.C. : 1974), 129 Suppl 2(Suppl 2), 19–31. https://doi.org/10.1177/00333549141291S206
[28] Rennie, K., Truffer, C., Wolfe, C. (2016). 2016 Actuarial Report. Centers for Medicare & Medicaid Services. https://www.cms.gov/Research-Statistics-Data-and-Systems/Research/ActuarialStudies/Downloads/MedicaidReport2016.pdf
[29] Medicare Payment Advisory Commission and the Medicaid and CHIP Payment and Access Commission. Data Book: Beneficiaries Dually Eligible for Medicare and Medicaid. (2018). https://www.macpac.gov/wp-content/uploads/2020/07/Data-Book-Beneficiaries-Dually-Eligible-for-Medicare-and-Medicaid-January-2018.pdf
[30] Musumeci, M., and Chidambaram, P. (2020). How Do Medicaid/CHIP Children with Special Health Care Needs Differ from Those with Private Insurance?. Retrieved from https://www.kff.org/medicaid/issue-brief/how-do-medicaid-chip-children-with-special-health-care-needs-differ-from-those-with-private-insurance/
[31] Musumeci, M., O’Malley Watts, M., and Chidambaram, P. (2020). Key State Policy Choices about Medicaid Home and Community-Based Services. Retrieved from https://www.kff.org/report-section/key-state-policy-choices-about-medicaid-home-and-community-based-services-appendix-tables/
[32] Chidambaram, P., Musumeci, M.B., Watts, M. (2020). “Medicaid Home and Community-Based Services Enrollment and Spending.” Kaiser Family Foundation. http://files.kff.org/attachment/Issue-Brief-Medicaid-Home-and-Community-Based-Services-Enrollment-and-Spending
[33] Friedman (2017). A national analysis of Medicaid home-and community-based services waivers for people with intellectual and developmental disabilities: FY2015. Intellectual and Developmental Disabilities 55(5), 281-302. https://doi.org/10.1352/1934-9556-55.5.281
[34] Texas Human Health and Services Commission. A Profile of Informal Caregiving in Texas, February 2017. Retrieved from https://hhs.texas.gov/reports/2017/02/a-profile-informal-caregiving-texas-february-2017
[35] Meucci, M. R., Kurth, N. K., Shireman, T. I., & Hall, J. P. (2018). Availability of Medicaid home-and community-based services for older Americans and people with physical disabilities. Home Health Care Services Quarterly, 37(1), 41-59.
[36] Keim-Malpass, J., Constantoulakis, L., & Letzkus, L. C. (2019). Variability In States’ Coverage Of Children With Medical Complexity Through Home And Community-Based Services Waivers. Health Affairs, 38(9), 1484-1490.
[37] http://lbfc.legis.state.pa.us/Resources/Documents/Reports/527.pdf
[38] Teshale, S., Mette, E., Spradlin, P., and Fox-Grage, W. (2020). State Approaches to Family Caregiver Education, Training, and Counseling. Retrieved from https://www.oldsite.nashp.org/state-approaches-to-family-caregiver-education-training-and-counseling/
[39] Rizzolo, M.C., Friedman, C., Lulinski-Norris, A., and Braddock, D. (2013). Home and Community Based Services (HCBS) Waivers: A Nationwide Study of the States. Intellectual and Developmental Disabilities 51(1). https://meridian.allenpress.com/idd/article/51/1/1/6266/Home-and-Community-Based-Services-HCBS-Waivers-A
[40] Velott, D. L., Agbese, E., Mandell, D., Stein, B. D., Dick, A. W., Yu, H., & Leslie, D. L. (2016). Medicaid 1915 (c) Home-and Community-Based Services waivers for children with autism spectrum disorder. Autism, 20(4), 473-482.
[41] Kelly, K., Wolfe, N., Gibson, M. J., Feinberg, L. (2013). Listening to Family Caregivers: The Need to Include Family Caregiver Assessment in Medicaid Home- and Community-Based Service Waiver Programs. Retrieved from https://www.aarp.org/content/dam/aarp/research/public_policy_institute/ltc/2013/the-need-to-include-family-caregiver-assessment-medicaid-hcbs-waiver-programs-report-AARP-ppi-ltc.pdf
[42] O’Keeffe J, et al. Real Choice Systems Change Grant Program, FY 2001 to FY 2004 Systems Change Grants: Summary Final Report. September 2009.
[43] Cordano, R., Johnson, K. and Kenney M. (2015/2016). A Campaign to Raise Community Awareness of Caregiving. Generations, 39(4),101-104.
[44] Utah Department of Health Medicaid. Utah Medicaid Provider Manual, Home and Community Based Waiver Services New Choices Waiver (updated July 2020). https://medicaid.utah.gov/Documents/manuals/pdfs/Medicaid%20Provider%20Manuals/Home%20And%20Community-Based%20Waiver%20Services/New%20Choices%20Waiver/NewChoicesWaiver7-20.pdf
[45] Georgia Medicaid. Application for 1915(c) HCBS Waiver: GA.0112.R07.02 – Apr 01, 2019 (as of Apr 01, 2019).
[46] https://www.flsenate.gov/Laws/Statutes/2012/409.979
[47] AHCA Contract No. ###, Attachment II, Exhibit II-B, Update 02/01/20 Page 21 of 71
[48] Florida WellCare. Children’s Medical Services Health Plan: Medicaid. (accessed August 25, 2020). https://www.wellcare.com/Florida/Members/Medicaid-Plans/CMS/Additional-Benefits-T19
[49] Rector, B. Family Caregiver Policies & Innovations: Washington State, presentation to the July 16, 2020 Advisory council Meeting.
[50] Rector, B. Family Caregiver Policies & Innovations: Washington State, presentation to the July 16, 2020 Advisory council Meeting.
[51] KFF. Appendix Table 8: State HCBS Waiver Self-Direction and Provider Policy Choices, FY 2018 https://www.kff.org/report-section/key-state-policy-choices-about-medicaid-home-and-community-based-services-appendix-tables/
[52] Colorado Department of Health Care Policy & Financing. (2020) “In-Home Support Services (IHSS) FAQs for Case Managers & Provider Agencies.” https://www.colorado.gov/pacific/sites/default/files/In-Home%20Support%20Services%20FAQ-July%2024%202020.pdf
[53] Soucheray, S. (2020). “Nursing homes might account for 40% of US COVID-19 deaths.” University of Minnesota Center for Infectious Disease Research and Policy. https://www.cidrap.umn.edu/news-perspective/2020/06/nursing-homes-might-account-40-us-covid-19-deaths
[54] Gebeloff, R., Lai, K., Oppel, R., Smith, M., Wright, W. (2020). “The Fullest Look Yet at the Racial Inequity of Coronavirus.” The New York Times. https://www.nytimes.com/interactive/2020/07/05/us/coronavirus-latinos-african-americans-cdc-data.html
Acknowledgements: The authors thank the state officials who contributed to this report by providing input on the recommendations or reviewing a draft of this publication. They included representatives from Colorado, Florida, Georgia, Idaho, North Carolina, Tennessee, Utah, and Washington. We also thank the members of NASHP’s Long-term and Chronic Care Steering Committee and State Leadership Council on Palliative Care for their input. Trish Riley, Kitty Purington, Wendy Fox-Grage, and Paige Spradlin of NASHP provided helpful guidance or assistance. We also thank Rani Snyder and Scott Bane of The John A. Hartford Foundation for input and guidance, and The John A. Hartford Foundation for its generous support of this work.
Infographic: Policy Levers to Address Health Equity by Reducing Lead Exposure
/in Policy Featured News Home CHIP, Chronic Disease Prevention and Management, Health Equity, Housing and Health, Lead Screening and Treatment, Maternal, Child, and Adolescent Health, Population Health, Social Determinants of Health /by Rebecca Cooper and Elinor HigginsThis infographic highlights how lead exposure and poisoning is a health equity issue, and the role that state Medicaid agencies and other systems play in reducing exposure to improve health outcomes. Additional resources are listed below the infographic.
Additional Resources:
- Associations of Maternal & Child Health Programs: Lead poisoning prevention webpage.
This project is supported by the Health Resources and Services Administration (HRSA) of the US Department of Health and Human Services (HHS) under grant number UJ9MC31105 – Maternal and Child Environmental Health Collaborative Improvement and Innovation Network (CoIIN) for $849.999. This information or content and conclusions are those of the author and should not be construed as the official position or policy of, nor should any endorsements be inferred by HRSA, HHS or the US government. NASHP thanks the Maternal and Child Health Collaborative Improvement and Innovation Network (MCEH COIIN) leadership partners for their review of the infographic.
States Curb Racial Inequities in Rx Drug Affordability with Targeted Legislation
/in Prescription Drug Pricing California, Colorado, Minnesota Blogs, Featured News Home Administrative Actions, Chronic Disease Prevention and Management, Consumer Affordability, Health Equity, Health System Costs, Population Health, Prescription Drug Pricing, State Rx Legislative Action /by Amanda Attiya and Jennifer ReckLow-income individuals and communities of color, already besieged by poor access to health care, limited insurance coverage, and other health inequities exposed by COVID-19, also suffer another health disparity – they are among the hardest hit by continually rising prescription drug prices.
Since 2017, states across the nation have taken action to lower rising drug costs, enacting 163 laws that include regulating pharmacy benefit managers, increasing drug cost transparency, importing drugs from Canada, and limiting cost-sharing by consumers. Many of these laws are most likely to combat rising drug costs for individuals covered by public and private insurance plans.
Because high drug prices disproportionately affect low-income, uninsured, and people of color, state laws that work to lower drug costs for these communities are important. Recent examples include a Minnesota law that extends insulin affordability measures to uninsured individuals, and states laws that target a discriminatory practice within insurance benefit design known as adverse tiering. Adverse tiering occurs when insurers place drugs – including those used to treat HIV/AIDS and hepatitis B and C that predominantly affect communities of color – in a drug formulary’s highest cost-sharing tier, forcing patients to pay more even when the drug is a generic.
Background
People of color are disproportionately impacted by chronic illnesses and certain health conditions, such as diabetes, HIV/AIDs, hepatitis B and C, hypertension, cardiovascular diseases, obesity, and asthma. Today’s increased rate of chronic conditions found in communities of color can be traced back to numerous discriminatory policies, including employment, education, and the practice of redlining, which placed loans and insurance out of the reach of residents of certain areas based on race or ethnicity. Systemic discriminatory practices have resulted in poorer households and neighborhoods, higher incidences of adverse childhood experiences, and limited access to quality health care, healthy food, parks, and public transportation. The combination of poor environmental quality, food scarcity, and limited access to health care increases the risk of asthma, obesity, and diabetes.
Not only are people of color more likely to suffer from chronic illness, they are also more likely to be uninsured and are therefore disproportionately hit hardest by ongoing rises in the list prices for prescription drugs. While insured individuals benefit from drug rebates negotiated for plans and drug coverage, the uninsured face higher prices for the same drugs – though they may be eligible for manufacturer coupons to help subsidize high costs. Other programs that help low-income patients obtain lower cost medications, such as MedAccess, require time-consuming applications, income verification, the cooperation of their providers, and computer access. The lack of ability to afford medication can result in under-usage of needed medications and overall poorer health outcomes.
In one study of Medicare beneficiaries without drug coverage, Black and Latinx individuals used 10 to 40 percent fewer medications than their White counterparts did for the same illnesses. Disparities are also seen in the under-use of insulin for the treatment of diabetes, a disease that is 60 percent more likely to impact Black adults than non-Latinx White adults.
Insulin Spending Caps
To make insulin more affordable and accessible, 11 states* have adopted legislation to impose spending caps on insulin for consumers. In most states, insulin spending caps affect only those covered by state-regulated drug plans. However, Minnesota’s recently enacted legislation also extends assistance to uninsured patients who cannot afford treatment for their diabetes.
Signed into law in April 2020, Minnesota’s Alec Smith Insulin Affordability Act caps insulin costs both in the commercial market and for the uninsured or under-insured. The legislation establishes two plans:
- An emergency plan that allows for a once-per-year, 30-day supply of insulin with a payment cap of $35; and
- A long-term plan that provides insulin supplies in 90-day increments for a capped payment of $50.
Both the urgent-need plan and the continuing safety net program are targeted towards uninsured populations, with the latter program requiring a household income less than 400 percent of federal poverty guidelines. Manufacturers who fail to comply with this bill face an administrative penalty of $200,000 per month for noncompliance, with the penalty increasing over time. Since passage of the Minnesota law, the Pharmaceutical Research and Manufacturers of America (PhRMA) has filed suit, claiming the act confiscates private property for public use without proper compensation to manufacturers.**
Adverse Tiering
People of color requiring expensive drugs to treat chronic illness also face a discriminatory practice within insurance markets known as adverse tiering. Adverse tiering occurs when insurance plans structure their drug formularies to require substantial out-of-pocket cost-sharing for drugs in a certain class, particularly for expensive-to-treat conditions such as HIV/AIDS. This discourages patients needing those drugs from selecting an insurance plan with adverse tiering, and forces those who do buy into the plan to pay hefty out-of-pocket co-pays for expensive, life-saving medications. Adverse tiering can cost HIV-positive individuals (of whom 87 percent were Latinx, Black, or of multiple races in 2018) enrolled in such a plan an additional $3,000 each year.
Adverse tiering became more prevalent between 2014 and 2015 for conditions such as HIV/AIDs, hepatitis B and C, and multiple sclerosis. In 2016, the US Department of Health and Human Services (HHS) released a regulation extending consumer protections from discriminatory practices found in the Affordable Care Act (ACA) to:
- All health entities receiving HHS funding;
- HHS-administered health programs; and
- Insurers participating in health insurance marketplaces.
The final rule also affirms the broad definition of “disability,” allowing for the inclusion of persons with chronic conditions that affect major life activities and bodily functions. In the final rule’s preamble, HHS lays out factors that the Office of Civil Rights (OCR) will consider when assessing potential discriminatory practices in plan benefit design on a case-by-case basis. One notable consideration is whether or not the covered entity utilized a nondiscriminatory rule or principle when adopting a certain plan design feature.
Insurers have taken advantage of this language by justifying their placement of all drugs in a given class on specialty tiers as resulting from high drug costs. While this approach avoids the regulation’s definition of discrimination, it none-the-less has the effect of deterring low-income patients needing high-cost drugs for chronic conditions from enrolling in their plans.
Because the chronically ill population is disproportionately made up by people of color, this practice is most likely to impact minority populations. Some states have taken direct action to combat adverse tiering:
- Delaware implemented legislation that prohibits insurers from placing all drugs in a given class on a specialty tier; and
- Both California and Colorado prohibit formulary designs that discourage enrollment by individuals with certain health conditions.
These laws, in addition to Minnesota’s insulin affordability law, provide first steps for policymakers who want to address drug affordability through a lens of racial justice by ensuring that affordability is extended to individuals beyond the commercially-insured market, and that benefit designs within commercial insurance markets do not have discriminatory impacts.
*States with insulin caps include New Hampshire, Colorado, Delaware, Illinois, Maine, Minnesota, New Mexico, Utah, Virginia, Washington, and West Virginia
**Track the status of this case and others on NASHP’s Rx Legal Resources page.
Harm Reduction in the COVID-19 Era: States Respond with Innovations
/in COVID-19 State Action Center Blogs, Featured News Home Behavioral/Mental Health and SUD, Chronic and Complex Populations, Chronic Disease Prevention and Management, COVID-19, Health Equity, Population Health /by Mia Antezzo, Eliza Mette and Jodi ManzDespite COVID-19 workarounds, such as telehealth and virtual recovery programs enabled by flexible federal guidelines, more than 40 states have reported increases in drug overdoses during the pandemic, underscoring the importance of keeping state harm reduction programs as accessible as possible.
As COVID-19 upends the nation’s health care systems, treatment for substance use disorder (SUD) has shifted to telehealth environments and recovery programs have gone virtual as state and federal policymakers adjust regulations and guidance to maintain access to services. But the unique risks facing people with SUD during this time of isolation and mandatory social distancing are also becoming more clear.
State-authorized harm reduction programs that provide syringe exchange services, testing for infectious diseases and referral to treatment, and connections to treatment for opioid use disorder and other SUDs provide a critical intervention. Despite the challenges of implementing COVID-19 protocols for what have traditionally been in-person services, states have developed flexibilities and innovative approaches to ensuring that these programs continue to provide critical, ongoing support to people with SUD until they are ready for treatment.
State guidance for harm reduction providers in response to COVID-19:
The guidance that state officials and agencies have developed recognize the unique challenges that face harm reduction providers during the COVID-19 pandemic. Many states acknowledge harm reduction as an essential service and some have temporarily loosened program restrictions to ensure the continuity of services during the pandemic.
- The Oregon Health Authority (OHA) authorized its Syringe Service Programs (SSP) to provide curbside services and phone orders for syringes, naloxone, and other supplies. OHA also suggested operational shifts in staffing, distancing protocols, and volunteer management to mitigate COVID-19 transmission among staff, volunteers, and clients. OHA included messaging in support of people who use drugs (PWUD) in order to maintain their safety during the pandemic. The messaging emphasized the increased respiratory risks associated with drug use and COVID-19 and provided guidance on how to reduce the risk of COVID-19 infection as well as the risk of overdose during the pandemic.
- In Maine, Gov. Janet Mills issued an Executive Order on March 30, 2020, suspending an existing one-to-one syringe exchange rule, thereby increasing the number of syringes individuals can take home at once. The order also allows flexibility in mail delivery services, needle exchange site locations and operational hours and provided on-site social distancing protocols.
- The Missouri Department of Mental Health issued comprehensive COVID-19 guidance in mid-March, which featured published resources from the Substance Abuse and Mental Health Services Administration (SAMHSA), the Harm Reduction Coalition, and the National Health Care for the Homeless Council (NHCHC), as well as best practices from other states and programs. Missouri’s guidance includes operational directives for treatment and harm reduction providers, as well as practical harm reduction guidance for PWUD, particularly individuals who use drugs alone.
Adaptations in harm reduction services:
Harm reduction programs are making policy shifts to develop practices that respond to the specific needs of their communities. As states and municipalities have responded to the COVID-19 pandemic at varying degrees of restrictiveness, harm reduction programs have also tailored their programs to respond to the pandemic.
- Operational changes. Programs in Washington and other states have shifted services outdoors. They now provide curbside or mobile services and have closed their fixed sites entirely and instead rely on delivery services. Many Washington State SSP programs have limited hours and scope of services. In New York, SSPs have been operating with skeletal staff and reduced resources. In response to the new limitations on in-person service, 22 of 23 of New York’s SSPs now rely on some form of peer-delivered syringe services.
- Shifts in testing priorities. In addition to continuing to provide harm reduction services, some SSPs in Washington now provide COVID-19 screening and testing at their program sites. West Virginia’s harm reduction programs have reduced the amount of non-COVID-19 infectious disease testing they’re conducting and the amount of hepatitis A and B immunizations they administer, in order to focus on COVID-19 and the immediate needs of individuals with SUD.
- Emphasizing naloxone distribution. As overdose rates continue to rise during the pandemic, states are increasing access to the overdose-reversal drug naloxone. Pennsylvania’s Secretary of Health signed an updated standing order that allows community organizations to distribute naloxone through mail. Ohio’s Department of Mental Health and Addiction Services has provided official guidance to all community programs through its statewide Project DAWN overdose reversal initiative to maintain minimal contact with individuals who need services while maximizing naloxone distribution as a strategy to mitigate overdoses. Additionally, the US Department of Health and Human Services has published guidance for first responders to safely administer naloxone during the pandemic.
Looking Ahead
As states begin to consider the impact of COVID-19 on their budgets, programming, and future planning, maintaining harm reduction programs may become more challenging. Harm reduction programs are often supported by multiple funding streams, and program administrators and policymakers may consider leveraging federal grants and other non-state funds to maintain these services. In addition to ensuring access to infectious disease prevention and life-saving treatment and recovery services, harm reduction programs offer a mechanism to maintain engagement with people who have SUD and reduce their risk of overdose, which results from isolation.
This work was funded by the Foundation for Opioid Response Efforts (FORE). The views and conclusions contained in this document are those of the authors and should not be interpreted as representing the official policies or stance, either expressed or implied, of FORE. FORE is authorized to reproduce and distribute reprints for foundation purposes notwithstanding any copyright notation hereon.
Webinar: Avoiding Dual Epidemics – State Strategies to Prevent Flu during COVID-19
/in Policy Arizona, Illinois Webinars Chronic Disease Prevention and Management, COVID-19, Health Equity, Population Health, Social Determinants of Health /by NASHP StaffStrategic planning for the 2020-2021 flu season during the COVID-19 pandemic is critically important to ensure that states do not experience dual epidemics this year. In this November, 2020 webinar, NASHP, in partnership with AcademyHealth and Immunize Colorado, provided a national overview of flu prevention priorities from the Centers for Disease Control and Prevention (CDC), and a closer look at state strategies in Arizona and Illinois.
Speakers discussed how states can ensure equitable access to the flu vaccine, including expanding access to immunizations through pharmacies and other delivery sites to reach vulnerable populations, and various payment and reimbursement strategies. This webinar was funded by the CDC.
Participants included:
- Moderator: Jill Rosenthal, MPH, NASHP Senior Project Director
- Sam Graitcer, MD, CDR, Medical Officer and Pandemic Influenza Coordinator, Centers for Disease Control and Prevention
- Jami Snyder, MA, Director, Arizona Health Care Cost Containment System
- Ngozi Ezike, MD, Director, Illinois Department of Public Health
States Work to Advance Racial Equity in COVID-19 Outcomes and Beyond
/in COVID-19 State Action Center Blogs, Featured News Home Chronic Disease Prevention and Management, Community Benefit, COVID-19, Health Equity, Housing and Health, Population Health, Quality and Measurement, Social Determinants of Health /by Elinor HigginsDisparities in states’ COVID-19’s health outcomes have driven home the need for policymakers to reassess their work to advance racial equity and redirect efforts to be more effective. A recent update to the National Academy for State Health Policy’s (NASHP) interactive map, How States Collect Data, Report, and Act on COVID-19 Racial and Ethnic Disparities, reveals that more than half of all states are now actively engaged in advancing equity in their COVID-19 responses and beyond.
States are working to ensure equitable distribution of resources and funding to promote health and safety for all during the COVID-19 pandemic. Some states are also beginning the long-term work of addressing systemic racism and other root causes of the disparities illuminated by the pandemic.
Use this interactive map to learn how each state reports race and ethnicity data on COVID-19 and how they act to address racial and ethnic disparities.
As the pandemic progresses and reveals the disproportionate impact of the disease on people of color, several states have created task forces and workgroups to ensure the equitable distribution of testing, personal protective equipment (PPE), and information about the disease. Some states are funding these efforts to better achieve equitable health outcomes for communities of color.
In Maine, for example, Black Mainers represent about 1.4 percent of the total population, but over 22 percent of the COVID-19 cases whose race is known. Gov. Janet Mills announced that $1 million from the Coronavirus Relief Fund would be dedicated to expanding services like testing, case investigation, contact tracing, and education to help reduce the disproportionately large racial and ethnic disparities in COVID-19.
As the recommendations and findings from the state task forces are published, one theme that emerges is the need for states to engage with communities and prioritize the needs they identify. The examples below underscore a critical lesson that states have learned from COVID-19 – their prior strategies to advance equity were not sufficient and integrating community feedback is essential to forge new and effective strategies. These recommendations reflect the importance of involving communities and people of color in states’ long-term policies:
- In New Hampshire, the COVID-19 Equity Response Team released its initial Report and Recommendations in which they described the need for proactive community engagement, working toward an ideal of co-creation and community ownership.
- In Oregon, the Equity Framework in COVID-19 Response and Recovery features a commitment to make community-informed policy and forge partnerships by engaging with community leaders who should be an essential part of the decision-making process.
- In Washington State, proposed recommendations from the Governor’s Interagency Council on Health Disparities include the provision of opportunities for communities to take the lead in creating information about and for themselves, including through contracts and grants.
- In Virginia, Gov. Ralph Northam announced a pilot program in Richmond to increase equitable access to PPE in underserved communities that may be more adversely impacted by the COVID-19. The pilot program includes community engagement events and training on cultural humility and implicit bias for city personnel who engage with the community.
The themes of including communities in decision-making and in the crafting of emergency responses are reflected in state funding streams as well, with some states providing funds to community groups. The Utah COVID-19 Community Task Force created a multicultural subcommittee that oversees the COVID-19 Racial Equity & Inclusion Grant Fund. The fund provides grants up to $5,000 to community-based organizations that provide emergency assistance to multicultural communities. In Michigan, $20 million was made available to the Coronavirus Task Force on Racial Disparities to respond to community needs associated with the disparate impacts the virus has had on communities of color. Community groups were able to apply for the funding through the Rapid Response Initiative, with funds available for a wide range of needs.
As states continue to work towards equitable health outcomes and look for ways to counter a long history of systemic racism, several are focusing on children’s health as a way to address disparities and potentially influence health trajectories in the future. For example:
- New Hampshire’s Equity Response Report recommended Adverse Childhood Experiences (ACEs) as an area to explore to continue understanding and serving communities of need in New Hampshire, specifically communities of color, at both the state and local levels.
- Ohio’s COVID-19 Minority Health Strike Force Blueprint highlights strategies to improve health outcomes and advance equity for children, including strengthening early childhood education and specifically ensuring that K-12 chronic absenteeism reduction efforts meet the needs of children of color. Ohio’s Plan to Advance Equity highlights how childhood poverty disproportionately affects African American and Latinx children in Ohio. To address this, the governor established the Office of Children Services Transformation within the office of Children’s Initiatives and is investing $675 million to assist students’ wellness and success.
The COVID-19 pandemic is far from over, and the effectiveness of these strategies will be evaluated based on how well they reduce disparities in COVID-19 outcomes and the advancement of health and social equity beyond the pandemic. NASHP will continue to engage states in identifying promising practices and will provide tools and support as states implement their task force and workgroup recommendations and measure change and success over time.
Support for this work was provided by the Robert Wood Johnson Foundation. The views expressed here do not necessarily reflect the views of the foundation.
States Race to Create COVID-19 Vaccination Distribution Plans
/in COVID-19 State Action Center Blogs, Featured News Home Chronic Disease Prevention and Management, Consumer Affordability, COVID-19, Health Equity, Health System Costs, Population Health, Social Determinants of Health /by Rebecca Cooper, Ariella Levisohn, Jill Rosenthal and Trish RileyAs development of a COVID-19 vaccine continues, states are racing to develop vaccine distribution plans and are eager to ensure that the administrative challenges of testing and personal protective equipment distribution are not repeated. They must orchestrate vaccine storage and administration, data tracking, and capacity issues while questions about who will ultimately pay for the massive vaccine deployment, how it will be equitably distributed, and effective vaccine messaging require a uniform federal response for best results.
Last month, the US Centers for Disease Control and Prevention (CDC) released the COVID-19 Vaccination Program Interim Playbook for Jurisdiction Operations. Its publication launched a 30-day deadline for states to create and submit their plans for vaccine-ordering, storage, and handling to the CDC by Oct. 16, 2020. The playbook, which acknowledged there are many unknowns and unanswered questions, will be continually updated by the CDC as guidance and best practices are refined. Recently, the National Academy for State Health Policy (NASHP) convened a cross-sector group of state officials to discuss their distribution strategies. The questions they raised are explored below.
How will the costs of preparation and planning for vaccine distribution be funded?
With CARES Act funding, the Department of Health and Human Services is distributing $200 million across 64 jurisdictions through the existing Vaccines for Children Program (VFC) for vaccine preparedness and planning. The funds are targeted to ensure jurisdictions can develop and update plans for their eventual vaccine distribution. These funds are used to ensure states’ Immunization Information Systems (IIS) are ready to accept all vaccine information, and that providers are enrolled and connected to the system to input their information, among other planning tasks. However, the CARES Act funding allocation uses a population-based formula and is not intended for other expenses related to vaccine administration, such as PPE, and must be spent by the end of 2020. With states already facing limited capacity given current budget constraints, these spending restrictions are expected to further strain state budgets, which could negatively impact their ability to distribute the vaccine to their most vulnerable populations.
There is currently no unified federal plan for distribution of a COVID-19 vaccine, leaving questions unanswered and states in the lead.
States will need to plan to store, administer, and track the COVID-19 vaccines, all while addressing vaccine hesitancies, ensuring equitable distribution, and addressing budget crises caused by the pandemic.
“We need… clarity [from the federal government] around financing early on, especially now that states are beginning to see the budget projections… People will take a more measured approached, and it would be helpful for plans to have a better idea of financing early on so they can plan and get ahead of the vaccine distribution and approval.”
– State Medicaid Official
State leaders also raised concerns about a variety of challenges they face in distributing the COVID-19 vaccine, such as a lack of clarity on federal funding for vaccine administration, refrigeration and storage, and availability of state funding.
According to the CDC playbook, the federal government will procure and distribute the vaccine and any associated supplies (including needles, syringes, and limited masks and face shields) at no cost to providers. Typically, insurance reimbursement to providers includes the cost of the vaccine itself and some of the associated administrative cost. The National Academies of Sciences, Engineering, and Medicine (NASEM) recommended in its framework for equitable vaccine allocation that vaccines be made available at no cost and that administration of the vaccine be adequately reimbursed. However, it is unclear how administrative expenses will be covered and by whom.
Other complications to state planning efforts include:
- What and how many vaccines will be rolled out, and over what time periods; and
- What refrigeration temperature requirements will be.
For example, given the storage and temperature requirements of one COVID-19 vaccine currently in clinical trial, states are concerned about additional costs of storing, freezing, delivering, and administering vaccines. CDC, meanwhile, has instructed states not to invest in ulta-cold freezers yet.
Vaccine administration can also be prohibitively expensive for facilities. Because there are still so many unknowns about which vaccines will be available and how they will be transported, details about who will ultimately finance these costs are still being finalized. State officials expressed concern that as they face budget crises and limited federal information and regulations, they are being set up to fail.
Who will be the first to be vaccinated?
The CDC recommends that states establish COVID-19 vaccination program implementation committees with representatives from every sector and from communities. The NASEM framework highlights the need for equal regard, maximization of benefits, evidence-based actions, and transparency in decision-making. NASEM and the Advisory Committee on Immunization Practices (ACIP) have been discussing how to prioritize the distribution of the COVID-19 vaccine to critical populations, but delayed making a final decision until a vaccine has been approved by the US Food and Drug Administration for clinical use.
Source: CDC COVID-19 vaccine implementation presentation, July 29, 2020.
The CDC playbook highlights a phased approach to distributing the vaccine and delineates three phases of distribution. However, during Phase 1, which has a limited supply of COVID-19 vaccine doses available, states are encouraged, but not required, to focus their initial efforts on reaching critical populations, including:
- Health care personnel who are likely to be exposed while treating people with COVID-19;
- Those at increased risk for severe illness, including those with underlying medical conditions and people age 65 years and older; and
- Other essential workers.
These phases align closely but differ slightly from NASEM’s equitable distribution framework for Phase 1.
Most state officials noted they intend to follow this guidance for prioritizing an equitable vaccine distribution. But, some states also noted concerns regarding using their immunization systems to identify and distribute the vaccine to these populations, especially to those who live in large, sparse, rural, and frontier areas with smaller public health administrative capacity. Others raised concerns about whether individual providers will be able and willing to administer the vaccine, and if they can do so in a way that follows the equitable allocation framework. Their concerns are tied to cost and reimbursement levels, as well as physical capacity to store and refrigerate the vaccines. Additional federal guidance and funds could alleviate these issues.
Who will pay for the vaccine and associated costs?
The NASEM framework recommends that the COVID-19 vaccine be provided and administered with no out-of-pocket costs. Paul Mango, HHS deputy chief of staff for policy, said the agency’s goal is for the COVID-19 vaccine to be free for all Americans. Anthony Fauci, director of the National Institute of Allergy and Infectious Diseases, similarly noted, “… The vaccine itself has already been bought by the federal government… A person who gets a vaccine will not pay for the vaccine.” However, Fauci did note that patients could be charged for costs related to the vaccine’s administration. Confusion remains about how these decisions will be made and it remains unclear how administrative expenses will be covered and by whom. For example, in the VFC Program, a provider who administers a qualified pediatric vaccine to an eligible child may not impose a charge for the cost of the vaccine, but can charge a fee for its administration as long as the fee does not exceed the costs of the administration.
ACIP has not yet issued a recommendation on state coverage of a COVID-19 vaccine, but Section 2713 of the Public Health Service Act requires mandatory coverage of all ACIP- recommended vaccines for state Medicaid expansion programs and most commercial health plans (state-based exchanges). ACIP-recommended vaccines are considered preventive and therefore are not subject to cost-sharing by patients. In March, Congress added a COVID-19 vaccine to the list of vaccines commercial health plans are required to cover. Usually insurers have up to a year after a vaccine is recommended by ACIP to implement coverage, but the CARES Act drastically speeds up this timeline by requiring plans to cover a COVID-19 vaccine within 15 days of its approval. The Coronavirus Preparedness and Response Supplemental Act specified that a vaccine should be priced “fairly and reasonably.” And, US officials noted over the summer that they expect insurance companies will not charge copays for COVID-19 vaccinations.
The cost of the vaccine for Medicaid enrollees is expected to vary by state. While Medicaid expansion states require complete coverage of ACIP-recommended vaccines without cost sharing, vaccine coverage is optional in non-Medicaid expansion states and remains up to the state’s discretion. However, through the Families First Coronavirus Response Act, all states are eligible for a temporary (through the end of the public health emergency) 6.2 percent increase to their Federal Medical Assistance Percentage (FMAP). One condition for states to receive this money is that the state plans must cover, without cost sharing, COVID-19 vaccinations.
For Medicare enrollees, vaccines are typically covered under Medicare Part D, which allows for cost sharing. The Centers for Medicare & Medicaid Services (CMS) can opt to cover the COVID-19 vaccine under Medicare Part B (which already covers the influenza vaccine and the pneumococcal pneumonia vaccine), a move that would prohibit cost sharing. As of mid-September, officials were still working with Medicare to figure out the cost to beneficiaries, but noted that the cost would likely not exceed $3.50 out of pocket per individual.
How will states monitor vaccine distribution?
The CDC is developing a Vaccine Administration Management System (VAMS) to manage vaccine administration and provide real-time data from mass-vaccination clinics to federal agencies and state public health departments. The system, funded by an almost $16 million sole-source contract, is designed to share data with existing Immunization Information Systems or immunization registries used by states and territories to record vaccine administration, order vaccinations, and send out vaccination reminders to patients. As of Oct. 7, 2020, however, VAMS has not yet announced plans, leaving state leaders confused about how to plan for vaccine tracking. Concerns have been raised that VAMS might bypass state systems, leaving states unsure whether they will need to use the new system or be able to enhance their existing immunization registry systems in time.
Immunization registries – either VAMS, IIS or a combination of both – will be needed to record vaccination information, identify individuals in need of a first or second dose of a vaccine, remind individuals to get vaccinated, and track follow-up. One critical concern is whether immunization registries have the capacity to ensure that people receive a second dose of the vaccine within an acceptable timeframe and that they receive the same type of vaccine for both doses.
Historical underinvestment in IIS has resulted in wide variation across states’ IIS policies, size, and scope. They have different patient consent policies, reporting mandates, and data-sharing policies. In some states, provider participation in the IIS is mandated by law, and in other states participation is voluntary. As a result, only 55 percent of immunization programs have 95 percent or more of individuals in their jurisdictions registered in their IIS. There is also inconsistent communication between systems. Many electronic health record (EHR) systems are not connected to immunization registries, leaving individuals who receive vaccines at different locations with incomplete immunization records. Although some states receive matching funds available through the Health Information Technology for Economic and Clinical Health Act (HITECH) to enhance interoperability of electronic data exchange between EHR and immunization registries, many rely on the CDC, private foundations, and health care providers and insurers to fund their systems.
Because multiple COVID-19 vaccine doses are forecast to be required, strong data-sharing capabilities between registries also is critical. State IIS need to be able to talk to other health records systems and other states’ immunization registries in order to ensure that individuals receive the correct second dose at a different facility, and even in a different state if necessary. However, in 2018, only 10 percent of immunization registries had conducted at least one query of an IIS in another jurisdiction. While the need for better systems to distribute and monitor the COVID-19 vaccine is clear, because VAMS has not yet released plans, states are left to figure out whether and how to:
- Upgrade existing systems, which requires time and resources;
- Rely on a new system that will be unfamiliar to providers and clinics; or
- Use a combination of both.
How are states promoting public trust in the vaccine?
Vaccine hesitancy will also be a critical issue. According to a recent Pew Study, the number of adults who say they will get a COVID-19 vaccine has fallen from 72 percent in May 2020 to 51 percent in September. Another study found that 35 percent of Americans would not get a vaccine, even if it were free. Mistrust of health care is especially prevalent among Black communities, who are skeptical of the medical system because of current and past discrimination against people of color. This distrust continues as Black Americans are hit hardest by COVID-19, making it even more critical that the government finds ways to boost confidence in COVID-19 vaccine safety.
The need for standardized public health messaging during this pandemic is also clear. In fact, state officials noted that currently, clear and consistent vaccination messaging is one of the biggest issues that states need the federal government to address. Typically, states use a variety of mechanisms for disseminating vaccine information, such as partnering with community organizations, hospitals, and other state agencies to disseminate information to their constituents, sending out clinician letters to providers and pharmacists, and using IIS to send vaccine reminders to patients. These strategies will continue to be important when states market the importance of getting the COVID-19 vaccination.
At the same time that state officials are concerned about gaining and developing public trust in the vaccine, they also need to manage expectations about vaccine availability and efficacy. As noted, the CDC playbook asks jurisdictions to plan for three phases of distribution:
- During Phase 1, critical populations such as essential workers and high-risk individuals are prioritized;
- In Phase 2, limited doses will be available to the public; and
- In Phase 3, there will be sufficient vaccine supply for the entire population.
Public health officials are tasked with instilling confidence in the COVID-19 vaccine and conveying the importance of getting vaccinated to the general public, while simultaneously making it clear that most individuals will not be able to get vaccinated until Phase 2 or 3, which is anticipated to start in fall of 2021. Until that point, and even after, individuals may still need to take other effective measures to present the spread of COVID-19, including social distancing and wearing masks.
State leaders are already concerned about this shift in messaging between phases, and worried about overpromising outcomes without increasing anxiety about the vaccine’s efficacy. In order to help manage expectations about when the vaccine may be available to the public while also combatting vaccine hesitancy, consistent messaging across federal and state agencies is urgently needed.
What partnerships are needed at the state and local levels to ensure seamless vaccine distribution?
As highlighted in the CDC playbook, the pandemic vaccination response requires collaboration among many public and private stakeholders to create and implement plans. State officials at the NASHP meeting noted the complexity involved in rapidly developing plans across agencies and across the public and private sectors.
Officials also raised the issue of involving pharmacists as vaccinators, and onboarding them into IIS. While all 50 states do currently allow pharmacists to vaccinate adults, and recent federal action gives state-licensed pharmacists authority to provide the COVID-19 vaccine to persons age 3 and older, only some states have pharmacists enrolled in Medicaid and the VFC program, with some pharmacists citing difficulty in being reimbursed during previous public health emergencies. Some state officials raised concerns that using pharmacies as immunization access points for COVID-19 could disrupt care in medical homes, particularly for children (although children will not be included in the first round of COVID-19 vaccines.) While the playbook highlights the need for increased access to the vaccine to ensure equitable distribution, states are considering how to balance widespread access to the vaccine with maintaining the importance of medical relationships within existing networks.
What federal leadership is needed?
Despite guidance provided by the CDC, there is currently no unified federal plan for distribution of a COVID-19 vaccine, leaving questions unanswered and states in the lead. States need to plan to pay for, store, administer, and track the COVID-19 vaccines, all while addressing vaccine hesitancies, ensuring equitable distribution, and addressing budget crises caused by the pandemic. State officials predicted that logistical issues will be worked out, but the messaging and finances require a uniform federal response for best results. NASHP will continue to track state and federal preparation for COVID-19 vaccination distribution and engage states in identifying challenges and developing appropriate policy and programmatic responses.
CDC-recommended representatives on state COVID-19 vaccine implementation committees:
• Emergency management agencies
•Health care and immunization coalitions
• Local health departments
• Health systems and hospitals (including critical access hospitals for rural areas, in-patient psychiatric facilities)
• Community and rural Health Clinics (RHCs)
• Pharmacies
• Long-term care facilities
• Businesses and occupational health organizations
• Health insurance issuers and plans
• Education agencies and providers
• Correctional facilities
• Churches or religious leaders and institutions
• Tribal leaders
• Organizations serving racial and ethnic minority groups
• Organizations serving people with disabilities
• Organizations serving people with limited English proficiency
• Community representatives
• Entities involved in COVID-19 testing center organization
“The biggest way to avoid the testing mess… [is] national leadership. [Testing] was such a mess because states were competing with each other… to get supplies.”
– State health official
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For individuals living with complex, often chronic conditions, and their families, palliative care can provide relief from symptoms, improve satisfaction and outcomes, and help address critical mental and spiritual needs during difficult times. Now more than ever, there is growing recognition of the importance of palliative care services for individuals with serious illness, such as advance care planning, pain and symptom management, care coordination, and team-based, multi-disciplinary support. These services can help patients and families cope with the symptoms and stressors of disease, better anticipate and avoid crises, and reduce unnecessary and/or unwanted care. While this model is grounded in evidence that demonstrates improved quality of life, better outcomes, and reduced cost for patients, only a fraction of individuals who could benefit from palliative care receive it. 























































































































































