Unwinding the Public Health Emergency: Ohio Medicaid
by Loren Anthes / March 14, 2022
On March 10, 2020, Ohio recorded its first case of Covid-19. In the two years after that case, the state Medicaid program played a critical role in ensuring access, providing coverage, and enabling budget stability as the state grappled with the complexities of the pandemic and its effects. And while the clinical science has not changed, the pandemic’s political science and public sentiments have, with states relaxing measures sought to curb the spread and limit the impact of the virus. With this transition also comes the termination of the Public Health Emergency (PHE) declaration, carrying the potential for significant disruptions to the services and supports upon which Ohioans relied over the last couple of years. That’s why the Center for Community Solutions has joined Advocates for Ohio’s Future in the Covid Recovery Coalition, convening around strategies to minimize or eliminate disruptions wherever possible, including in Ohio’s Medicaid program.
Bringing care home with telehealth and long-term care
First, it’s worth noting the permanent impact the pandemic will have on the ways services are provided, particularly in telehealth and long-term care. The imperatives of physical distancing catalyzed more virtual and home-based services typically delivered in institutions with providers. In fact, as of March of last year, the use of telehealth services in Ohio Medicaid grew 35 times what had existed previously. And as of December 2021, legislation passed expanding the number and type of clinicians who may provide telehealth services inside and outside Medicaid. Long term, this means routine care may change significantly as long as individuals have access to reliable broadband.
While this can positively impact the accessibility of services for key populations, including those who may be geographically or physically limited, it also carries the potential for longer-term challenges for local government budget stability. If, for example, more clinicians can practice and provide care outside of a hospital or the state itself, the revenue impact could create long-term challenges.
Beyond telemedicine, long-term services and supports were and will continue to be one of the most challenged sectors in healthcare. Between significant issues with infection control for a vulnerable population, staffing shortages, vaccine hesitation and the influence of private equity investment on safety, the industry has faced a mountain of problems that will continue to affect services in the years to come. And while nursing facilities and home health care agencies received some of the largest amounts of relief funding, there will be significant changes to the system as Ohio unrolls its American Rescue Plan Act funding for Home and Community Based Services (HCBS).
This effort, which focuses on building the capacity of the HCBS system, may be able to provide meaningful enhancements to the home-based delivery network in Ohio. Still, what remains to be seen is how this increased capacity in HCBS affects Nursing Facilities long term. In all likelihood, policymakers will have to keep a close eye on how facility-based care will become less pervasive and should explore strategies to enable that transition.
Plugging budget holes and managing increasing caseloads
Currently, every $1 the state of Ohio spends via General Revenue in Medicaid leverages $5.93 in resources. As we have written about previously, much of the increased resources from the enhanced federal rate has enabled the state to stave off a budget crisis, with the dollars netting an additional $100 million a month in Ohio Medicaid, easing budgetary pressure in other priorities like education. However, unless Congress acts, the termination of the PHE also means the termination of the enhanced funding.
During the budget and in a recent Joint Medicaid Oversight Committee meeting, Medicaid Director Maureen Corcoran revisited this dynamic, once again referring to this dual challenge of caseload increase and evacuation of federal resources the “pig in the python.” Fortunately, Ohio planned for this dynamic, using the Health & Human Services fund to manage the caseload and spending transition upon the termination of the PHE. Notably, enhanced funding did not apply to all populations, specifically those enrolled via Medicaid Expansion (also referred to as “Group VIII” or non-disabled adults without dependents). This means the disproportionate benefit of these resources has gone to the most vulnerable populations in the program, including children, older adults, and persons with disabilities.
Avoiding a Medicaid enrollment catastrophe
Of all the activities of the Recovery Coalition, the issue of enrollment has received the most attention. When looking at enrollment since March 2020, the total caseload for the program increased by nearly 550,000. Out of this group, over 141,000 are parents, about 134,000 are children, and nearly 255,000 are working-age adults.
As a public health safety measure, the PHE prevents states from unnecessarily disenrolling beneficiaries as a condition of accepting enhanced federal funds. This coverage maintenance has created a lifeline for families experiencing the economic fallout of the pandemic, ensuring individuals had access to treatments, vaccinations, and tests during the pandemic. However, once the PHE ends, so does this protection, meaning millions of Ohioans’ coverage is at risk.
Exacerbating this challenge is a budget provision requiring Ohio Medicaid to complete all renewals and redeterminations within 90 days after the end of the PHE, including a mandate to a contract a vendor incentivized to identify individuals who are likely ineligible for the program.
Eligibility and renewals guidance for Ohio Medicaid
On March 3, the Centers for Medicare and Medicaid Services (CMS) released guidance to states about how states can better manage eligibility and enrollment work once the PHE ends. Included in this guidance are many recommendations regarding a timeline for processing redeterminations, strong expectations regarding automated or “ex parte” renewals, and efforts to “risk manage” the caseload so individuals with the most acute need are not disenrolled, unnecessarily.
Specifically, CMS identified several temporary authorities for states to pursue, including powers that enable managed care to participate in the outreach process, lengthen administrative action timeline on fair hearing requests, and connecting Medicaid eligibility to other programs such as the Supplemental Nutrition Assistance Program (SNAP, commonly known as “food stamps”).
Because the guidance timeline identified by CMS may be in conflict with the General Assembly’s mandate, the Recovery Coalition is preparing recommendations for the Ohio Department of Medicaid to consider and ensure there is no undue coverage loss. Especially as overdose deaths are on the rise and children are missing critical developmental screenings, maintaining coverage is paramount. To assist, we are strongly encouraging agencies to ensure their clients’ information is up to date by working with them and advising they:
Call (844) 640-6446. After selecting the option for their preferred language, they should select option 2 and will be prompted to enter their zip code;
Individuals with an existing Self-Service Portal (SSP) account can report changes online at https://ssp.benefits.ohio.gov. After logging in, they should click the Access my Benefits tile, then click Report a Change to my Case from the drop down and follow the prompts;
Contact their County Department of Job and Family Services (CDJFS). Ohio Medicaid members can find their CDJFS by viewing the County Directory at https://jfs.ohio.gov/County/County_Directory.stm.
Additionally, to ensure people have access to the services they need, we’re working with colleagues from the Legal Aid communities across Ohio to help human service agencies better understand how to advocate on behalf of their beneficiaries in the event their due process rights have been violated. For any interested parties, please be sure to visit Advocates for Ohio’s Future, https://www.advocatesforohio.org/, for the latest information and to stay connected on these future educational opportunities.
Additionally, to ensure people have access to the services they need, we’re working with colleagues from the Legal Aid communities across Ohio to help human service agencies better understand how to advocate on behalf of their beneficiaries in the event their due process rights have been violated. For any interested parties, please be sure to visit Advocates for Ohio’s Future, https://www.advocatesforohio.org/, for the latest information and to stay connected on these future educational opportunities.
Additionally, to ensure people have access to the services they need, we’re working with colleagues from the Legal Aid communities across Ohio to help human service agencies better understand how to advocate on behalf of their beneficiaries in the event their due process rights have been violated. For any interested parties, please be sure to visit Advocates for Ohio’s Future, https://www.advocatesforohio.org/, for the latest information and to stay connected on these future educational opportunities.
Extensions and timelines for Ohio Medicaid
Secretary Beccera of the Department of Health and Human Services (HHS) has indicated that states will receive 60 days’ notice before the termination of the PHE. Currently, without an extension, April 16 is set to be the termination date, but because there was no notice to states, it’s more likely the deadline could be July 15, meaning states would receive guidance by May 15, but it may be extended beyond that timeline as well. Whatever the timeline, many of the flexibilities provided to states through waivers or statutes would expire at that time. And, in regards to the services, finances, and coverage the PHE enabled, the Recovery Coalition will do its best to keep advocates, agencies, and beneficiaries up to date with the latest information.