Oregon is asking the Centers for Medicare and Medicaid Services for permission to allow Medicaid enrollees to stay on the rolls continuously for two years without eligibility redeterminations. The state also wants children to be able to stay on Medicaid until age six without a redetermination.
Oregon appears to be the first state to ask for two years of continuous Medicaid eligibility. The state made its request in a Medicaid waiver renewal application, which was sent to CMS last Friday. All states have paused redeterminations in order to receive enhanced federal Medicaid funds during the ongoing COVID-19 public health emergency. However, only Montana and New York offer continuous eligibility for Medicaid enrollees outside of the PHE. In addition, both states only allow one year of continuous eligibility, and Montana's government is working to eliminate the policy altogether.
Oregon says its proposal builds off of lessons learned from the COVID-19 public health emergency. The state expects the change to reduce the number of people that are kicked off Medicaid rolls, due to administrative issues.
Nearly 25% of new Oregon Medicaid enrollees in 2018 and 2019 had enrolled in coverage during the last six months, according to the state's waiver. Throughout the last six months of 2020—after the federal continuous enrollment requirement was in place— this rate dropped down to 5%. The figures indicate that beneficiaries may have been losing Medicaid coverage during redeterminations, even though they were eligible, and that the PHE policy seems to have kept people covered.
The state decided to push for two years of continuous enrollment, following the PHE. After all, the amount of people going off Medicaid every two years seems to be much smaller than the number of people churning through it in one year, Jeremy Vandehey, director of the health policy and analytics division for the Oregon Health Authority, said in an interview prior to submitting Oregon's official application.
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The state also requests federal Medicaid matching dollars to fund continuous Medicaid eligibility for children through their sixth birthday. Oregon currently has one year of continuous eligibility for children, but lengthening this requirement will enable more stable health coverage, along with better access to preventative care and treatment, the waiver says.
"This is really an important, groundbreaking proposal that we think is exactly the kind of thing that states should be testing," Joan Alker, executive director and co-founder of the Georgetown Center for Children and Families, said. Other states—as well as Washington—are looking into similar policies.
Oregon reached a record low rate of uninsured residents this year at 4.6%, and the largest coverage gains were among low-income adults, as fewer people were uninsured due to losing Medicaid coverage, according to Vandehey. But when the PHE ends, Oregon estimates 300,000 people will lose their Medicaid coverage.
Separately from its Medicaid waiver, Oregon health officials are asking the legislature to approve a plan to reduce churn for enrollees who find themselves kicked off Medicaid when their income fluctuates above the eligibility threshold. If approved by state lawmakers, Oregon would work with CMS to create a more affordable coverage option for residents making up to 200% of the federal poverty level.
"I think we're now really concerned—like a lot of states—around how do we not lose these gains," Vandehey said. "It'd be a really unfortunate situation where the pandemic ends and suddenly access to healthcare ends."
The looming end of the PHE's Medicaid continuous enrollment requirement provokes anxiety for states and payers across the country. The PHE presently runs into April, and officials have said they'll give a 60-day notice before ending the designation. That means it's likely to be renewed at least one more time. But lobbying organizations recently requested at least three months' notice, and state officials want more time and money to take care of the backlog of redeterminations once they start back up.
Oregon's waiver additionally seeks expenditure authority to let individuals in custody access Medicaid benefits before their release, provide social determinants of health transitional services to select vulnerable groups, refine its Quality Incentive Program to promote health equity and more. Oregon aims to eliminate health inequities by 2030, and the waiver builds on—and is key to— achieving that goal, the document says.
Oregon expects a final decision from CMS on its waiver by the end of this summer, but said in a news release that timing could shift.
