New Issue Brief Explores Proposed Rule’s Potential to Stabilize Medicare Savings Program and Medicaid Coverage

Earlier this year, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule to streamline Medicaid and Medicare Savings Program applications, determinations, and redeterminations. The Kaiser Family Foundation (KFF) has now released a new issue brief that explores how many Medicare-eligible people might be affected by the proposed changes.

Medicare-eligible individuals with lower incomes may be enrolled in both Medicare and Medicaid. Full Medicaid coverage is through “Aged, Blind, and Disabled” (ABD) Medicaid. Medicare Savings Programs (MSPs) also help many individuals afford Medicare costs. Both ABD Medicaid and MSPs have strict eligibility criteria in many states. The ABD Medicaid and MSP populations rarely see major increases in their incomes from month to month.

Currently, some states require people with ABD Medicaid and MSP coverage to confirm their eligibility multiple times a year and provide detailed financial information rather than relying on data from state and federal government sources that demonstrate eligibility. The repeated burden of demonstrating eligibility may result in churn, a cycle of gaining, losing, and regaining coverage.

The KFF analysis strongly suggests that individuals lose coverage for administrative reasons such as redeterminations and lack of data matching. In 2018, 38% of all people with ABD Medicaid lost at least one month of Medicaid coverage in their first year. The number is even higher (46%) for people under 65 years old. Most lost coverage for more than three months and about a quarter of those who lost ABD Medicaid coverage retained MSP coverage.

In that same year, 33% of all people with MSPs lost at least one month of MSP coverage. Again, this number was higher for people under 65, with 36% losing at least one month of coverage. As with ABD Medicaid, most who lost MSP coverage lost it for more than three months.

These data show that the proposed rule has the potential to reduce churn by lessening the paperwork burden on ABD Medicaid and MSP enrollees, limiting redeterminations of eligibility to once per year, and requiring states to use already available financial data sources to demonstrate eligibility.

Medicare Rights strongly supports these proposals, especially given the coming end of the COVID-19 public health emergency (PHE). The PHE’s end will trigger states to restart the process of redetermining eligibility for Medicaid programs and may result in losses of coverage for millions as states and individuals struggle with administrative burdens.

Read the issue brief from KFF.

Read Medicare Rights’ comments on the proposed rule.

Read more about churn.