New Rules Allow Integration of Human Services Programs in Health Eligibility Systems: Limited Exemption to Cost Allocation
On August 10, 2011, the U.S. Department of Health and Human Services (HHS) and the Department of Agriculture (USDA) issued a joint letter that provides for a time-limited, specific exemption to the cost allocation requirements outlined in OMB Circular A-87, Section C.3. This exemption would allow human service programs, including the Temporary Assistance for Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP, formerly Food Stamps), and Child Care Development Fund (CCDF), to benefit from the investments in state eligibility systems being created through the state-operated health insurance exchanges, Medicaid, and Children’s Health Insurance Program (CHIP), as required by the Affordable Care Act (P.L.111-148).
Many states will be making significant investments in eligibility systems to implement the Affordable Care Act. The letter from HHS and USDA would allow states, at their discretion, to integrate human service program eligibility determination functions in the creation of the Exchanges and overhaul of Medicaid eligibility. The letter allows human service programs to use the systems developed for the purpose of determining an individual’s health coverage, e.g. Medicaid, CHIP, Exchange, without having to share the common system development costs, as long as the costs would have been incurred anyway. However, there are two important caveats. First, the systems that determine an individual’s eligibility for health coverage must be operational and fully tested by the summer of 2013 and launched as of January 1, 2014. States who choose to include human service programs in the eligibility determination system cannot interfere with these deadlines. Second, any incremental costs for additional requirements made necessary for human service programs must be charged to the benefiting program. An example of an incremental cost could be an additional screen to verify and collect additional information from applicants that would not otherwise be needed in the Exchanges, CHIP or Medicaid. The charge of such screen would be charged to the human service program requiring the information
The flexibility offered by this letter expires December 31, 2015. HHS and the USDA will issue additional guidance in the coming months. NCSL will continue to provide updates as more information becomes available.
To read the letter, go here: http://www.acf.hhs.gov/programs/cse/pol/DCL/2011/dcl-11-13a.pdf
OMB Circular A-87: http://www.whitehouse.gov/omb/circulars_a087_2004/#c
For further information, please contact either Sheri Steisel or Emily Wengrovius at NCSL’s Washington DC office at 202-624-5400.