Proposed CMS rule set to streamline application and enrollment for vulnerable populations
With any health and human services benefits program, when eligibility is lost, the effects can be detrimental. For those who rely on regular access to services to navigate daily life, especially intellectual/developmental disability (I/DD) populations, any interruption in coverage can be a major setback.
The U.S. Centers for Medicare & Medicaid Services (CMS) recently proposed a new rule that could remove unnecessary administrative barriers to enrollment and retention for Medicaid recipients. In January 2021 and April 2022, the Biden administration issued directives to address enrollment challenges in vulnerable communities, which led to the development of this rule .
Functional limitations make current renewal practices challenging. The new rule would make Medicaid and Children’s Health Insurance Program (CHIP) enrollment and re-enrollment easier by:
- Eliminating requirements for in-person interviews
- Ensuring applicants have 30 days to respond to requests for information
- Pre-populating renewal forms
- Including a 90-day consideration period in cases where a beneficiary is unable to meet a re-enrollment deadline
FEI Systems applauds CMS’ efforts to streamline the application, eligibility determination, enrollment and renewal processes for Medicaid, CHIP and Basic Health Program. The proposed rule would undoubtedly further CMS’ mission to provide health and human services to low-income individuals and families living with disabilities and chronic health issues. However, in the course of our work providing person-centered case management solutions to state and local agencies—particularly those serving waiver populations—we have seen those enrolled in I/DD waiver programs lose Medicaid eligibility in some instances. Those enrollees must then wait significant periods of time before regaining access to services, causing disruptions to members and their families and caregivers.
Given that those enrolled in I/DD waiver programs will likely always need specialized care and services, should the CMS add a provision to accommodate these populations and protect their enrollment status?
At FEI, we understand the need for routine re-assessments of care, and we believe such re-assessments could be triggered to determine if a change to the level of service is required. But shouldn’t those enrolled in I/DD programs remain eligible by default, because of the nature of their conditions? For most of this population, some level of service will always be required. Such a provision to this proposed rule would allow for continuous waiver coverage and access to care, without fear of interruption for these individuals.