APA WF 24-09 Twelve-Months Continuous Eligibility for Children on Medicaid and CHIP
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 # 24-09 and submit feedback via the comment box below.
Circulation Date: 12/01/2023
Comment Due Date: 01/02/2024
Public Hearing: N/A
Board Meeting: 01/17/2024
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Comments
Steve:
The OHCA proposed Policy Change related to Child 12-month Continuous Coverage does not seem to include the full range of eligible children.
The OHCA document seems to only apply to NEW child enrollments with the wording:
If "coverage BEGAN on or after Jan 1, 2024" not to current member renewals or re-determinations during 2024 and later and not to current 2023 child members who should have continuous coverage in 2024 until their next renewal/re-determination date in 2024
The OHCA wording limited to just if "coverage BEGAN on or after January 1, 2024"
Where is wording in OHCA policy that applies C12CC to both:
(1) Renewals and re-determinations during 2024 and subsequent years which should re-start a C12CC period?
(2) Current child members who renewed in late 2023, so have remaining coverage months in 2024 that should have CC protections?
As background for (1) and (2) above:
(1) The CMS State Health Official letter (SHO 23-004) uses the phrase about C12CC being applicable at the "initial application or a regularly scheduled annual renewal". The OHCA wording seems to leave out current members and renewals.
(2) The CMS State Health Official letter (SHO 23-004) about C12CC has a specific example about a child re-determined back in Sept, 2023 who should get Continuous Eligibility starting Jan 1, 2024 for the remainder of the usual eligibility period until their next regular renewal.
"Current Enrollees Whose Eligibility Period Ends After January 1, 2024." Because the CE period is based on the effective date of the child’s last eligibility determination (either at initial application or last renewal), for states newly implementing CE [like Oklahoma] children under age 19 enrolled in Medicaid and CHIP will receive CE for the remainder of their eligibility period based on the date of their last determination.
CMS example:
Elijah is enrolled in a state that implements CE for the first time [like Oklahoma] on January 1, 2024. Elijah’s most recent determination of eligibility was completed in September 2023, and his current eligibility period began on October 1, 2023. Effective January 1, 2024, the state must provide Elijah with CE for the remainder of his 12-month eligibility period (through September 30, 2024), unless he experiences one of the exceptions to the provision of CE.
OHCA Response:
Thank you for your response. OHCA has updated the text at OAC 317:35-6-61(d) to state that coverage shall be maintained for any child who meets the continuous eligibility criteria as of January 1, 2024, not only to those starting coverage. The text was also updated to clarify the 12 months of continuous coverage is based on the effective date of their certification period, as defined in OAC 317:35-1-2.
