Today, Colorado Center on Law and Policy (CCLP) and the National Health Law Program (NHeLP) filed a complaint with the U.S. Department of Health and Human Services Office for Civil Rights and the U.S. Department of Justice.
Bethany Pray provided testimony for Senate Bill 24-093, Continuity of Health-Care Coverage Change. CCLP is in support of SB24-093.
CCLP Policy Fellow, Milena Castañeda testified at the Medical Services Board meeting regarding emergency rules for the NEMT.
Chaer Robert provided testimony against House Bill 24-1065, Reduction of State Income Taxes. CCLP is in opposition of HB24-1065.
Unwinding Continuous Coverage
Since March 2020, Coloradans enrolled in Medicaid and Child Health Plus (CHP+) have been able to maintain their health coverage. This policy has meant fewer gaps in care, less paperwork, and more peace of mind. States kept people enrolled in exchange for the additional federal funding provided under the Families First Coronavirus Response Act, and in recognition of the benefit of health coverage in battling a public health crisis.
Continuous coverage is nearing its end, however, with disenrollments due to resume on April 1, 2023. Every state, Colorado included, is reckoning with their ability to assess accurately and efficiently whether each enrollee meets eligibility requirements. And communities, clinics, and advocates are facing the prospect of thousands more without health coverage and the repercussions that will have on health and economic stability.
The eligibility team at our state Medicaid agency, Health Care Policy and Financing (HCPF), deserves credit for meeting with the public about the coming renewal processes and sharing data, partnering with community organizations on a campaign to update addresses, and developing public-facing materials.
However, major obstacles remain that could result in tens of thousands of Coloradans unnecessarily losing coverage.
Counties will be unable to keep up with the volume of work. Our county-based eligibility system is unusual, with fewer than 10 states delegating enrollment and eligibility processing to counties. And county-based systems are by nature less efficient and more costly, with Colorado estimated to spend about 30% more on administration of the SNAP program, for example, than states that use a centralized system, based on recent budget documents. The same is almost certainly true of Medicaid administration.
On top of that, counties have struggled to retain and train county workers because eligibility is a tough job. It’s not easy to find staff who are able to work well with people from a range of cultures, who know the local resources, are computer savvy, and have a detailed knowledge of some ridiculously complicated programs. Reports are widespread about current county backlogs for the SNAP program, with Colorado Springs and Mesa County as two recent examples. Add Medicaid processing to that, and where will that leave counties, let alone the individuals and families that have relied on this coverage?
Eligible Coloradans will lose coverage for the wrong reasons. People who have income sufficient for plans through Connect for Health or who have access to employer coverage can be appropriately disenrolled, but substantial numbers of people lose coverage every year because they don’t return paperwork – either because they didn’t receive it, didn’t understand it, or made errors. Other glitches may occur for people with disabilities, whose cases require extra time and coordination between counties and case management entities.
Those who get dropped from Medicaid despite low incomes or disability may end up returning to coverage when they have a crisis. While uninsured, though, they are much less likely to get the care they need, whether that’s behavioral health services or blood pressure medication.
The systems and processes Colorado uses to manage eligibility and enrollment create their own barriers to access. Colorado’s outdated IT system, the circa 2004 Colorado Benefits Management System, is one giant obstacle to better processing, and this coming year will likely show just how costly antiquated technology can be – both in a human and a fiscal sense. Another issue is a renewal packet that is not postage paid, as in other states. And, as CCLP has long advocated, there are major issues with Colorado’s returned mail policies and processing, which fail to incorporate some recommended practices for updating addresses, a particularly burdensome challenge for people who have unstable housing, as well as low-income renters who struggle to maintain an address.
There is no way to make the unwinding easy. Colorado’s leadership needs to be ready to pause processes if counties are unable to keep up with processing, if error rates are high, and if particular populations experience harm. It will be essential that HCPF continue to share information, ideally through an updated dashboard that includes geographical and demographic information, so that localities, providers, and advocates may identify the trouble spots. This is an all-hands-on-deck situation, and CCLP promises to update regularly as the process begins and we learn more.