In light of the first, and hopefully only, global pandemic in our lives, my colleagues and I, with help from others, have pulled together a list of policy steps that we think are essential. The challenges the health and humans services sector face are unlikely any in our lifetime. Unless we take extraordinary steps, lives will be lost, and the health and human services sector and those it serves will be permanently damaged and may never recover. If we take these steps (and others) we can help flatten the coronavirus curve, help the reinforce the health care sector today and help it recover from this epidemic sooner, and -- not unimportantly -- help our economy recover faster. We welcome the ideas of others and appreciate the enormous amount of work it would take to accomplish all these steps. But if there was ever a time to be bold, that time is now.
Unless we take extraordinary steps, lives will be lost, and the health and human services sector and those it serves will be permanently damaged and may never recover.
Our recommendations fit into four categories:
- Getting Medicaid coverage to people who don’t have health insurance or who have lost their health insurance as soon as possible and helping those who have it to keep it.
- Protecting patients and health care providers by eliminating every payer barrier to telemedicine. This includes for individuals involved in the criminal justice system, and by suspending all prior authorizations and copays for doctor ordered health care services, pharmaceuticals, and medical equipment during the state of emergency.
- Maximizing the capacity of the delivery system to screen, test and treat communities by suspending any recertifications associated with clinical licensure, expanding the potential locations where services can be provided and making any eligibility determinations and payments made during the period of emergency disqualified for future program integrity penalties.
- Public benefit programs can help alleviate suffering and provide economic stimulus during this critical time. Benefit levels must be increased, application processes streamlined, work requirements eliminated and no one should be terminated from these benefits during the state of emergency.
Medicaid
Eligibility
- Medicaid should consider using an 1135 waiver under the Stafford Act to seek federal approval to expand Medicaid to higher income levels – 300 percent for children and 200 percent for adults.
- Make COVID-19 a cause “special enrollment” in Marketplace plansThe following proposals should be in place until both the state and national emergency declarations have expired.
Temporary Changes
- Suspend program participation and licensure renewal requirements for providers
- Suspend or eliminate facility requirements that inhibit maximum ability to test and screen (i.e. allow for motels to serve as a potential screening, testing and/or treatment location)
- Allow for “license equivalency” i.e. licensed providers from other states can practice in Ohio. This should apply to labs and to any telemedicine that may be provided.
- Decrease or eliminate benefit limits which can inhibit social distancing (i.e. increase number of meals able to be delivered under waivers).
- Remove current restrictions on presumptive eligibility (PE), including those that preclude PE to only happen once in the last 12 months.
- Suspend all Medicaid redeterminations - extend coverage indefinitely.
- Suspend all Medicaid prior authorizations for pharmacy, services, durable medical equipment, etc.
- Require managed care plans to suspend prior authorization requirements and to extend current prior authorizations indefinitely.
- Draft a state plan amendment requesting all copays be eliminated, but especially for those services covered under the pharmacy benefit and non-emergency services obtained in a hospital or emergency room.
- Eliminate all barriers to telemedicine. There should be no payment difference for these services whether they are paid in person or provided through telehealth, whether through audio/video or only using audio.
- Suspend any regulatory requirement regarding the JMOC threshold.
- Provide presumptive eligibility for justice-involved individuals, allow telemedicine for justice-involved individuals.
Other
- Minimum Medicaid benefits should include COVID-19 testing as a mandatory lab testing benefit. Medicaid should also consider extending these benefits to tests that do not meet the standard of having the service provided in an office or similar facility. In particular, determine if mobile health units can be deployed to provide tests, based on actionable information, and allow them to be eligible for technical fees or to be considered for a federally qualified health center payment.
- Ask the federal government to reduce risk to states administering Medicaid benefits. Declare any payments made during emergency ineligible for Medicaid fiscal accountability regulation (MFAR) calculation. Eliminate any penalties for states and counties associated with ineligible enrollment. Suspend public charge policies for Medicaid.
- Create a centralized website explaining Medicaid changes made due to COVID-19. Include information like what benefits have changed, what has changed about eligibility, and copies of any documents submitted to CMS.
SNAP
The following proposals should be in place until both the state and national emergency declarations have expired.
- Suspend all SNAP redeterminations, interim reports and case closures.
- Eliminate SNAP interview requirements.
- Accept SNAP application as self-declaration of eligibility without requiring any further documentation.
- Increase SNAP benefit level.
WIC
- Ask the federal government to waive federal requirements that retailers stock specific food products and a specific amount of those products in order to be certified by the WIC program. Since there is uncertainty as to how food supply chains may be affected we don't want retailers to fear losing their WIC certification and stop serving low-income families
TANF
- Suspend mandatory work requirements for applicants and recipients, and do not impose any TANF sanctions or time limits during a time of emergency.
- For the purpose of establishing or maintaining eligibility, disregard any discontinued income from prior months or even if received earlier in the month.
- Consider creating a new COVID19-specific or disaster-relief specific program to provide temporary cash to families. There could be minimal eligibility detail required with no asset tests and broad income guidelines, such as serving families with income below 200 percent of the federal poverty line.
