Twelve-Months Continuous Eligibility for Children on Medicaid and CHIP (APA WF 23-18)

The proposed revisions will implement the changes required by the Consolidated Appropriations Act of 2023 (H.R. 2617 – Public Law 117-328, Section 5112) which mandates that all states implement 12-months continuous eligibility for children on Medicaid and CHIP, effective January 1, 2024.

Please view the circulation document here: APA WF # 23-18 and submit feedback via the comment box below.

Circulation Date: 08/22/23

Comment Due Date: 09/8/23

MAC Meeting: 9/7/23

Board Meeting: 9/20/23

Steven:

How does continuous coverage operationalize initially on Jan 1, 2024? Do all children with existing enrollment on Jan 1, 2024 receive the continuous coverage protection?......Or, does the protection begin only after a re-determination AFTER Jan 1 (or a new enrollment)?  There is concern that a new child enrollment on Jan 1 receives the 12-month continuous coverage protection.......but an existing child member with a June re-determination date stays at risk of losing coverage from Jan-June, if the continuous coverage protection does not begin until AFTER a re-determination after Jan 1, 2024.

OHCA Response:

Existing members will receive 12 months continuous eligibility based on their most recent determination of eligibility. Those applying on or after January 1, 2024, will receive 12 months continuous eligibility if approved.

Steven:

Rules note that the Child category continuous coverage protection ends if the member becomes categorically related to "Former Foster Care" category. Are there income eligibility limits for the "Former Foster Care" category? Are there situations that would mean loss of SoonerCare for a member changed to the  "Former Foster Care" category? What is the age limit for the "Former Foster Care" category?

OHCA Response:

There are no income limits for the Former Foster Care Youth category. There are no situations that would mean loss of SoonerCare for someone changed to Former Foster Care. The only overlap between the child program and Former Foster Care is while the child is 18.  Former Foster Care is higher in the eligibility hierarchy so an 18-year-old that is potentially for both Former Foster Care and Child coverage would be approved as Former Foster Care.  Once a member is approved for Former Foster Care they are essentially guaranteed coverage to age 26.   The age limit for Former Foster Care Youth is 26.

Steven:

Rules note that child continuous coverage ends if the person becomes categorically related to the Pregnancy category. Since Pregnancy coverage is capped at 210%FPL, there will be situations where a pregnant child during their 12-month Child-category continuous coverage period  will *not* be within income limits for the Pregnancy category, and lose SoonerCare coverage completely. Please comment on this situation and what it may mean for pregnancy outcomes.

OHCA Response:

If a child is locked-in, then goes over 210% FPL and while over income applies for pregnancy coverage, we would determine eligibility using the increased household size (adding any unborn children).  If eligible for pregnancy with this increased household size, they would be moved to pregnancy coverage and the extended pregnancy coverage rules would be applied.  If not eligible for pregnancy the pregnancy coverage would be denied, and they would remain under child coverage for the duration of the lock in period.

Steven:

Rules note that Child category continuous coverage ends at Age 19. Currently, 19-year-olds are *not* automatically transferred into Adult Expansion/Healthy Adult category, even if household application info demonstrates their eligibility. An auto-transfer seems to be an easy computer process, and would promote positive health outcomes. What regulatory or policy changes would be needed to have 19-year-olds automatically put in Adult Expansion category when application data shows eligibility? This will be important since the 19th birthday will come during an expected 12-month continuous eligibility period, leading to confusion among members and uncertainty about seeking treatment. Also, the current OHCA letter to 19-year-olds only says "coverage will end" -- it does not mention options of Adult Expansion or Marketplace plans. How might this member communication be improved?

OHCA Response:

As a member ages out of coverage they are re-evaluated for other coverage before coverage is ended and referred to the Marketplace.  If eligible as either a Needy Parent/Caretaker Relative or an Expansion Adult they will be moved to that coverage the month after child coverage ends.

Emma:

Oklahoma Policy Institute – a nonpartisan, nonprofit think tank focused on equitable and fiscally responsible state policy – appreciates the opportunity to comment on this proposed rule change. We strongly support the proposed change to implement 12-months of continuous eligibility for children under the age of 19. We applaud the Oklahoma Health Care Authority for its work to implement the changes in a timely and efficient manner, as required by the Consolidated Appropriations Act of 2023.

Providing a year of continuous eligibility for children will improve health outcomes in Oklahoma. On the individual level, continuous coverage has been shown to increase access to necessary health care, improve health equity, and mitigate the negative impacts of volatile income.(1) More broadly, we expect continuous coverage to contribute to more efficient health care spending, reduce administrative work for the Health Care Authority, and increase the agency’s and managed care organizations’ ability to measure quality of care.(2,3)

We have two questions about the proposal:

1. Will the continuous coverage provision apply to every child who is enrolled on January 1, 2024, or will it only apply to children who apply for and enroll in coverage after that date? To maximize the benefit to individuals, cost savings, and administrative efficiency, we would strongly recommend applying the provision to all children who are enrolled on the effective date.

2. With a state cost of $37 million in SFY 2025, will the agency require increased appropriations in that and future years, or will the cost come out of the existing budget?

OHCA Response:

1: Existing members will receive 12 months continuous eligibility based on their most recent determination of eligibility. Those applying on or after January 1, 2024, will receive 12 months continuous eligibility if approved. 

2: The budget impact for this change was already built into our budget as this change was known to the Agency.