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January 9, 2022

CMS COVID-19 Emergency Preparedness FAQ (Comin' to ya on a dusty road. I got a truckload) State Medicaid Collaborative Disaster Preparedness Flexibility and PHE Authorities

 












CMS COVID-19 Emergency Preparedness FAQ: State Medicaid Collaborative Disaster Preparedness Flexibility and PHE Authorities

 

 

Medicaid Authorities Available in Emergencies Allowed by Existing Regulations

Allow self-attestation to verify eligibility for all criteria except citizenship and immigration status on a case-by-case basis; 

verify assets if financial institution unable to verify due to disaster; 

verify incurred medical expenses for spend down eligibility 

Extend renewal timeframes

Exempt enrollees from premiums

Temporarily suspend periodic data checks on case-by-case basis 

Temporarily delay acting on certain changes in circumstances affecting eligibility 

Reinstate services or eligibility if discontinued because whereabouts unknown due to evacuation, after whereabouts become known and if still eligible

Consider people evacuated from state as temporarily absent to maintain enrollment

Treat Federally facilitated Marketplace assessments as eligibility determinations or fully delegate eligibility determination authority to Federally facilitated Marketplace

Expand application processing times 

Suspend adverse actions for those in disaster area where state has completed determination but has not yet sent notice or state believes notice likely not received

Temporarily increase HCBS waiver service payment rates if no change to rate methodology and no impact on cost neutrality 

Amended/Updated Verification Plan –

No CMS Approval Required 

Accept self-attestation and conduct post-enrollment verification for eligibility criteria other than citizenship and immigration status (beyond case-by-case basis)

Adopt or increase reasonable compatibility thresholds for income inconsistencies

Allow reasonable explanation of inconsistencies in lieu of paper documentation

Temporarily suspend periodic data checks (case-by-case basis)  

State Plan Amendment – Retroactive to 1st Day of Quarter Coverage:  

Increase financial eligibility thresholds (e.g., adopt ACA expansion, cover nonelderly MAGI group above 138% FPL).

 Cover non-residents or state-defined subset of non-residents, such as those living temporarily in state due to disaster in home state.

Apply host state’s asset limit, or if less restrictive, asset limit from state where individual evacuated (if statewide rule)  

Enrollment & Renewal:

Adopt or extend presumptive eligibility for certain populations

Extend hospital presumptive eligibility to non-MAGI groups 

Establish state as presumptive eligibility qualified entity to enroll individuals based on preliminary application information

Provide 12-month continuous eligibility for children 

Develop simplified paper application for affected areas 

Extend reasonable opportunity period to provide documentation for immigration status Benefits:

Temporarily modify copayment requirements to support access to services (if rule applies statewide) 

Offer additional benefits (if comparable for all categorically needy groups and statewide with free choice of provider, or via alternative benefit plan with free choice of provider)

Change amount, duration, or scope of covered benefits 

Amend payment methodology to account for increased cost of personal protective equipment for home care workers 

Health Plan Contract/Oversight

Temporarily suspend out of network requirements for managed care enrollees 

Require health plans to expedite processing of new prior authorization requests and allow flexibility in documentation (e.g., physician signature) Section 1115 

Waiver – state is deemed to meet budget neutrality if federally declared disaster, waiver can be retroactive to date of Secretary-declared public health emergency, exemptions from public notice in emergencies 

Coverage: 

Increase eligibility limits for specific categories in specific geographic regions 

Enrollment & Renewal: 

Provide 12-month continuous eligibility for adults or for a subset of children 

Allow self-attestation for citizenship and immigration status if unable to verify by data sources and individual unable to document due to disaster 

Benefits: 

Provide benefits to targeted group of enrollees impacted by disaster 

Temporarily modify copayment requirements to support access to services (less than statewide)

Authorize off-island coverage for those in territories eligible for FEMA transitional shelter assistance who are temporarily relocated to a state 

Long-Term Services and Supports:

Temporarily suspend requirement to be institutionalized at least 30 days and have income below 300% SSI to be eligible for special income group

Temporarily suspend asset transfer rules for those placed in nursing homes 

Apply host state’s asset limit, or if less restrictive, asset limit from state where individual evacuated (if less than statewide) 

Do not reduce institutional provider payments by post-eligibility treatment of income 

Section 1135 

Waiver – if President declares national emergency and HHS Secretary declares public health emergency Benefits:

Temporarily suspend fee-for-service prior authorization requirements and/or require providers to extend prior authorization through the termination of emergency declaration 

Covered Providers:

Temporarily waive requirements for out-of-state providers to be licensed in state where they are providing services if provider is licensed by another state 

Medicaid agency or Medicare 

Temporarily waive provider screening requirements, such as application fees, criminal background checks, and site visits, to ensure sufficient number of providers 

Temporarily cease revalidation of providers in state or who are otherwise directly impacted by disaster

 Temporarily suspend pending enforcement or termination actions or payment denial sanction to specific provider 

Allow facilities to provide services in alternative settings such as temporary shelters when provider facility is inaccessible

Temporarily allow non-emergency ambulance providers 

Long-Term Services and Supports: 

Provide nursing home care to evacuees in host state for less than 30 days if individual is Medicaid-eligible in home state

 Temporarily suspend pre-admission screening and annual resident review assessments for 30 days 

Extend minimum data set authorizations for nursing home and skilled nursing facility residents 

Temporarily suspend requirement that home health agency aides be supervised for 2 weeks by registered nurse 

Temporarily suspend requirement that hospice aides be supervised by registered nurse every 14 days

Modify or suspend certain state survey agency activities Appeals: 

Allow direct access to fair hearing without first exhausting managed care appeal 

Extend timeframes for individuals to request managed care appeals or state fair hearings Section 1915 (c)

Home and Community-based 

Services Waiver Appendix K – can be submitted before or during emergency, can be retroactive to date of event

 Eligibility:

Increase number of unduplicated waiver enrollees 

Temporarily increase individual cost limit to assure health and welfare 

Modify eligibility targeting criteria to serve more enrollees and forestall institutionalization in emergency 

Extend level of care authorizations for 12 months Benefits: 

Add covered services not expressly authorized in statute if necessary to assist waiver enrollees to avoid institutionalization 

Modify scope of covered services and temporarily exceed individual service limits to ensure health and welfare 

Institute or expand self-direction 

Temporarily suspend prior authorization and extend medical necessity authorizations

Modify person-centered planning process, including qualifications of individuals required to develop plan Providers:

Temporarily increase payment rates with a temporary change in rate methodology and/or impact on cost neutrality 

Amend payment methodology to account for increased cost of personal protective equipment for home care workers 

Allow payment for services provided by family caregivers or legally responsible relatives 

Temporarily modify provider types, qualifications, and licensure or other setting requirements 

Include retainer payments to personal care assistants when waiver enrollee is hospitalized or absent from home up to 30 days

Expand covered settings to include out-of-state

Temporarily allow payment for waiver services up to 30 days to support enrollees in acute care hospital or short-term institutional stay when services are required for communication and behavioral stabilization and not provided by institution 

 

MORPHOLEX VP Text Untitled, Level k-1, Framework nfl7, Word tokens 1044 LEVEL 2 (inflections)

leaders 7 making 4 scientists 4 happened 3 mentioned 3 used 3 concerning 2 does 2 following 2 posts 2 words 2 appeared 1 avengers 1 broken2 1 checks 1 concerned 1 continued 1 continuing 1 dinosaurs 1 driven2 1 during 1 fears 1 fighting 1 guardians 1 happens 1 hearing 1 institutes 1 killed 1 later2 1 listening 1 living 1 loads 1 looked 1 lots 1 movies 1 nursing 1 offered 1 others 1 photos 1 presented 1 reading 1 returns 1 scripps 1 shots 1 shows 1 sporting 1 stoking 1 students 1 studies 1 suggesting 1 suggests 1 taken2

1 takes 1 taking 1 teams 1 telling 1 terms 1 touching 1 trained 1 trying 1 wanted 1 wants 1 LEVEL 3 (derivations) leader 8 twitter 5 really 3 completely 2 simply 2 spreader 2 absolutely 1 actually 1 daily 1 exactly 1 fully 1 governor 1 hammer 1 happiness 1 keith 1 sickness 1 slightly 1 tony 1 totally 1 truly 1 tucker 1 avenger 1 LEVEL 4 scientists 4 scientist 4 additional 2 management 2 reality 2 government 1 national 1 LEVEL 5 situation 1 suggestion 1 guardian 1 LEVEL 6 information 4 addition 2 reese 1 returns 1 situation 1 

DERIVATIONS SUMMARY Number of derivative affixations (Levels 3-6) is 62 Derivs.

62/1044=5.94% of text lex 

Number of different derivational affixes is 16 18 ~er 15 ~ly 5 ~ation 4 ~ists 4 ~ist 3 ~al 3 ~ment 2 ~ness 2 ~ity 2 ~ion 2 re~ 1 ~or 1 ~th 1 ~y 1 ~ian 1 ~ition