January 11, 2018: Medicaid Work Requirements
Today, CMS released a massive change to the Medicaid program by introducing regulations that would allow for work requirements. The new guidance will allow states to seek waivers that will require Medicaid beneficiaries to work or seek work or community service. The guidance suggests exemptions for disabled, medically frail or pregnant status from a work requirement but states are not required to include the exemption. It also allows states to account for other factors (such as unemployment rate) in applying work requirements (this may result in rural areas being less affected). Generally, states that have proposed to impose work requirements expect enrollment declines . Legal challenges are expected over this regulatory change.
CHIP
Unfortunately, the recent infusion of CHIP money has been barely made a dent into the potential closing of multiple state CHIP programs. CBO recently scored the a ten year extension of CHIP a net saver to the government as many of the CHIP eligible enrollees would migrate to the Exchange, where they would be eligible for Federal subsidies.
Health Reform
There has been ongoing discussion on whether health reform or entitlement cuts may be a potential issue for Republicans for the spring. There has been increased reporting that major healthcare topics will not in the cards for before the 2018 elections. While this doesn’t preclude minor legislation on Market Stabilization activities (e.g., reinsurance) or health tax delays, it does sound like repeal and replace or major changes to healthcare programs will be off the table, at least through the spring and summer.
MACRA
This week CMS introduced the second stage of the Bundled Payment for Care Improvement (BPCI) program, “BPCI Advanced”. Similar to the original BPCI program it is voluntary, participants can select which of the 29 episodes of care to participate in, and a quality component is included. But there are some differences, including:
- All episodes of care will include the initial inpatient stay or outpatient visit, and all services for 90 days afterwards, with very few exceptions;
- There are 29 inpatient episodes; 28 of which are a carry-over from the original BPCI, with the addition of an episode for liver disorders;
- Outpatient episodes are being included; covering percutaneous coronary intervention (PCI), cardiac defibrillator, and back and neck except spinal fusion;
- This program will count as an Advanced Alternative Payment Model (APM) underneath MACRA. Participating in this model may exempt provider groups from required reporting under the Merit-Based Incentive Payment System (MIPS), and allow those groups to qualify for the 5% bonus available under the Advanced APM track.
Applications for this program are being accepted now, with the application window closing in March, and the program beginning October 1, 2018. As with the prior program, participants will be provided detailed data to enable comprehensive analysis of current and historic performance underneath the selected bundles.
HHS Secretary
Alex Azar’s confirmation hearings have gone well with multiple Democratic Senators signaling support. At this stage it is a matter of time before he is confirmed as the next Secretary of HHS.