Obsolete 1120 COVID 19 Questions and Answers

Date

October 14, 2020

Policy Reference

715 & 721

Topic

COVID 19 Response

General

Follow all normal eligibility policy, unless making any change makes the person ineligible, or reduces coverage. See resource below.

Question

During the COVID-19 Health Emergency, can Medicaid eligibility end?

Answer

No. For anyone who was eligible for Medicaid on March 18, 2020, or who becomes eligible during the Health Emergency, the Eligibility agency cannot terminate their Medicaid eligibility. This requirement lasts through the last day of the month in which the Health Emergency ends. After that, the agency must decide if the client is no longer eligible and provide 10-day notice.

There are a few exceptions:  If a client dies, moves out of the state permanently, or asks the agency to end their Medicaid coverage, the agency will then end eligibility. The Eligibility Agency will give proper notice.

Question

What if someone’s time-limited Medicaid would end during the emergency? For example: a child turns age 19, 12-month TR would end, TAM etc., during the emergency period?

Answer

The agency must continue Medicaid coverage until the end of the month in which the emergency ends. The agency may have to do a Forced Issuance to continue benefits. See policy 721-4.

Question

If a child turns age 6 and household income is higher than the income limit, do we continue coverage for that child?

Answer

Yes.  The child’s coverage under Medicaid must continue until the end of the emergency. The agency may have to manually issue benefits.

Question

Do we continue coverage for a lawfully present child during the emergency?

Answer

Yes. If the child is under age 19, follow the same process as for any other Medicaid child as described in this Q&A. If a change would cause the child to lose Medicaid eligibility, we must continue their eligibility through the end of the emergency.

However, if a lawfully present child turns age 19 during the emergency period, move the child aging off to the applicable emergency only coverage group.

Question

Can we move an Adult Expansion client who turns age 65 to Aged Medicaid during the emergency?

Answer

Yes, but only if the individual qualifies without a spenddown. If the client’s income will exceed 100% of the FPL under the Aged Medicaid rules force Aged Medicaid 100% of the FPL.

Question

Can a client be moved to Disability Medicaid from another Medicaid program?

Answer

Yes, but only if the individual qualifies without a spenddown. If the client’s income will exceed 100% of the FPL under the Disabled Medicaid rules, and the client would owe a spenddown, the agency must continue coverage under the program they are on until the end of the emergency period.

Question

What do we do if a pregnant woman’s post-partum period ends during the emergency period?

Answer

Her eligibility under Pregnant Woman coverage cannot be terminated until the emergency ends. The agency will likely need to do a forced issuance.

Question

What happens if someone has a review due during the emergency period?

Answer

Follow normal review policy in section 721. If the agency can renew eligibility through an ex-parte review without making any changes that make the person ineligible, or reduces coverage then renew eligibility. If a prepopulated review needs to be sent out but the client does not provide all required verification, then the agency will need to add a due process month until the review is completed or until the emergency ends.  

If a review is due for a different program, like food stamps, and verification are requested, the Medicaid program cannot end due to failure to provide the verification, or due to changes that affect the other program (like a change in income.)

Question

Can Medicaid for Emergency Only services be closed?

Answer

No. If the client was eligible on March 18^th, or becomes eligible during the emergency period, keep the case open for emergency only services.  They still only qualify for emergency services, which may include certain COVID related services.

Question

How should the agency deal with reported changes?

Answer

During the emergency period, if the agency receives information about a change in circumstances, the agency should retain the information. The agency cannot act on any change that would cause the Medicaid to end, or result in reduced benefits. The agency may have to manually issue benefits or push out effective dates.

However, if the reported change is that the client is moving out of the state, has died, or a request from the client to close Medicaid, the agency will act on those changes and end Medicaid eligibility.

After the emergency ends, the change information received previously should be verified to update eligibility for future months.

Question

What happens if a client enters a public institution?

Answer

Suspend benefits for the client following policy in 604.

Question

What happens if a client who is supposed to pay a Spenddown, an MWI premium or a Waiver Cost-of-Care contribution does not pay it?

Answer

A spenddown or MWI recipient that has made a payment during the public health emergency, which began March 2020, will have their Medicaid eligibility continue through the end of the emergency period. From the month eligibility is met the client’s eligibility will continue through the end of the emergency period.

*Pending CMS guidance for Waiver programs

Question

Will I receive a refund if I have paid more than one month of Spenddowns or MWI premiums during the public health emergency?

Answer

No. Refunds will be handled according to current policy.

Question

Do Presumptively Eligible clients receive continuous coverage during the emergency period?

Answer

No. If the only coverage someone qualifies for is Presumptive Eligibility, coverage will end at the end of the PE period.  However, if the agency makes a full eligibility decision and find the person is eligible for a Medicaid program, they receive the protection of continuous coverage through the end of the emergency.

Question

What do we do if a client is receiving Continued Benefits pending the outcome of a Fair Hearing?

Answer

If the client was enrolled in Medicaid on March 18, 2020 and is receiving continued benefits pending a Fair Hearing, the agency cannot close their case until the emergency period ends.  [NOTE:  Anyone who becomes eligible after March 18 cannot have their case closed, so they should not be requesting a hearing.]

If the result of the Fair Hearing would result in case closure, that decision cannot be carried out until after the emergency period ends. The client’s eligibility is protected through the end of the emergency period. No overpayment will accrue for such dates, either.

After the emergency ends, the agency needs to reevaluate the situation to determine whether the client is ineligible. Medicaid may be closed if the client is no longer eligible at that time.

Question

Will overpayments be assessed if the agency later finds that someone enrolled on March 18, 2020, or who becomes enrolled during the emergency period, really was not eligible?

Answer

No. However, if there is suspected fraud, the agency may refer the case for criminal investigation.

Question

Will someone receiving UPP or ESI payments remain eligible during the emergency period?

Answer

Yes, as long as they still have health insurance, we will keep sending their payment.

Question

Will someone who remains eligible for Adult Expansion due to the public health emergency be eligible for an ESI reimbursement?

Answer

Yes, if one of the following situations apply

1.    The client is on Adult Expansion and their income increases and puts them over the Adult Expansion income limit, but within the UPP income level.  We will give them Adult Expansion with ESI as long as they have access to insurance that meets QHP.  After the emergency ends we will transition the individual to UPP.  

2.    The client is on Adult Expansion and their income increases and is within the UPP income level.  We will give them Adult Expansion with ESI as long as access to insurance meets QHP.  Before the emergency ends, their income increases and they are now over the UPP income level.  We will keep them on Adult Expansion with ESI and when the emergency ends, we will close the program.  

No, if one of the following situations apply

1.    The client is on Adult Expansion and their income goes over the UPP income level.  We will not give the option of ESI.  We will continue them on Adult Expansion during the emergency period with no ESI option.   

2.    The client is on Adult Expansion and not meeting the Minimum Essential Coverage or an ORS sanction due to duty of support requirements. .

Question

Can a refugee who is receiving RMA be extended beyond the 8-month limit for the program?

Answer

Yes. To aid clients affected by COVID-19, refugees who became eligible for RMA after April 1, 2019, and are not receiving Medicaid under a different program may be extended to September 30, 2020. For clients who became eligible for RMA after February 1, 2020, the eligibility period will remain at eight months.

Question

Will Adult Expansion have the Community Engagement requirement?

Answer

No. All Adult Expansion clients, that have the community engagement participation requirement, will get good cause according to policy 348-2.

Question

Will the COVID 19 Recovery Rebate checks be countable for Medicaid?

Answer

No. See policy 403-4.41 for income exemption.

Question

Will the COVID 19 Recovery Rebate checks be countable as an asset the month after receipt?

Answer

No. These checks are a type of advance tax credit and as such they do not count as income. See policy 521-46 for asset exemption.

Question

Will the COVID 19 Unemployment extra benefit checks be countable for Medicaid?

Answer

No. While unemployment remains countable, the $600 a week stimulus payment is excluded. DWS must identify and exclude this UI stimulus payment as countable income. See policy 403-4.21.

Question

Will the COVID 19 Unemployment extra benefit checks be countable as an asset the month after receipt?

Answer

No. See policy 521-46.

Question

Do we continue eligibility for an otherwise eligible client who needs to provide evidence of citizenship or satisfactory immigration status if they do not provide such evidence by the end of the 90 day reasonable opportunity period?

Answer

Yes.  Otherwise eligible individuals for whom the agency is unable to receive electronic verification of citizenship or satisfactory immigration status will continue to receive medical assistance through the end of the emergency period. After the emergency period ends, if the client has received the full reasonable opportunity period, the agency will terminate coverage. 

Do not end benefits during the emergency period. However, if the agency receives verification that proves the individual is neither a citizen nor a qualified immigrant, the agency will change eligibility to the emergency services Medicaid program for the duration of the emergency period.

Question

Is there a program available to cover COVID-19 Testing?

Answer

Yes. Uninsured individuals may qualify to receive coverage for COVID-19 testing.  To qualify, an individual must meet residency, citizenship/alien status requirements, and must meet the definition of an uninsured individual. An uninsured individual is an individual who is not enrolled in Medicaid, any health care program funded by the federal government, or any group health plan or health insurance coverage offered by a health insurance issuer. There are no income, asset or age limits. Eligibility is determined by current HPE providers and designated UDOH staff. Decisions are based on client’s self-attestation, including self-attestation of citizenship or alien residency. Benefits include COVID-19 testing and additional, limited testing related services. 

Question

Can I accept a ‘testing site’ location as a ‘signature’ for Medicaid?

Answer

Starting on June 22, 2020, COVID-19 testing sites will sign applications for Medicaid and the COVID-19 testing group with verbal consent from the client.

The testing site will be acting as an authorized representative with limited scope to sign on behalf of the applicant for this coverage only during the PHE.

The testing site must be noted in the case record.

Once approved, a form 40 and a 61Med will be generated. DWS receives and follows established process (enters enters/ongoing application).  When the emergency period ends, a signature must be obtained by the client to maintain ongoing Medicaid coverage.

Question

When a client is unable to sign an application (paper/online/in person), what options do they have?

Answer

There are two ways. See policy 703-1.  

    1.   Complete a telephone application with a telephonic signature.

2.    The authorized representative will complete an application and form 114COVID. The form 114COVID allows a limited role for an authorized representative to sign and complete an application on the client’s behalf. This option will only be available during the PHE period. 

Question

Answer

Program

If Still Eligible, Allowed Changes

If No Longer Eligible, Required Actions

Changes Not Allowed

PCR

First PCR, then TR, then Adult Expansion or Aged

Force Adult Expansion for the remainder of the emergency

Close Adult Expansion or Aged

12 Month TR

First TR, then PCR, child (if applicable), then Adult Expansion 

For adults -Force Adult Expansion for the remainder of the emergency. 

For child - Force child for the remainder of the emergency.

Remove the client from some type of continued coverage.

4 Month Extended

May move to PCR, Adult Expansion, Child

For adults-Force Adult Expansion for the remainder of the emergency.

For child - Force Child for remainder of the emergency

Close Adult Expansion or Child Medicaid

Adult Expansion w/ children

• May move to PCR or remain on Adult Expansion
• If over age 65 move to Aged
• Has a disability and receives Medicare move to Disabled

Force Adult Expansion for the remainder of the emergency. Force Aged or Disabled if the client has Medicare.

Close Adult Expansion (may end ESI if no longer enrolled in health insurance or the plan is no longer a qualified plan)

Adult Expansion w/o children 

• May move to Pregnant woman or remain on Adult Expansion
• If over age 65 move to Aged
• Has a disability and receives Medicare move to Disabled

Force Adult Expansion for the remainder of the emergency. Force Aged or Disabled if the client has Medicare.

Move these clients to PCR or Adult Expansion w/ children (may end ESI if no longer enrolled in health insurance or the plan is no longer a qualified plan)

Aged, Blind or Disabled with no spenddown

May still move disabled individual from Aged to Disabled

Force the same program they were on for the remainder of the emergency

- Move a client to MWI or Spenddown.

- Move DM (under 100% FPL) to AM.

MWI

ABD w/o premium or spenddown

Move to spenddown program only if the spenddown is less than the premium and the client is no longer working

Force MWI for the remainder of the emergency; do not increase premium

Move to Adult Expansion or Disabled with a spenddown that is higher than the MWI premium

TAM

TAM, can move to pregnant woman if pregnant, if at review and eligible for Adult Expansion they can move

Force TAM

Move clients to another program not listed in the “allowed column”

Pregnant Woman

Force Pregnant woman coverage

Force Pregnant woman coverage for the remainder of the emergency.

Move a former PW to another program.

Child 6-18 

Child 6-18, or if aging out move to Adult Expansion

Force 6-18 or Adult Expansion for the remainder of the emergency.  (If the 19 year old has a child, do not issue PCR.)

Move to CHIP or PCR

Child 0-5

Child 0-5 or if aging out move to Child 6-18

Force Child 0-5 or Child 6-18

Move to CHIP

Child 1yr

Child 0-5

Force Child 0-5

Move to CHIP

Lawfully Present Medicaid child

Child program, or if aging out move to emergency only Adult Expansion

Force Child program, or Adult Expansion for the 19 year old for emergency only services

Close coverage

CHIP 

(age 19)

Close CHIP coverage

Open Adult Expansion without a Medicaid Application.

CHIP

(under 19)

Premiums will be suspended

First CHIP, may request Medicaid

Force CHIP for the remainder of the emergency

Close CHIP (We will close if they are enrolled in other health insurance)

Spenddown (Medically Needy (MN)) or MWI with premium

Any non-MN

If disabled, can move to MWI if working and the premium is less than the spenddown was

Force spenddown or MWI recipients from the month eligibility is met through the end of the emergency.

Move any non-MN client to MN. Increase the spenddown or MWI premium. Do not refund any spenddown or MWI premiums collected. Refunds will be handled according to current policy.  

Foster Care

Foster care; or Former Foster Care if aging out of Foster Care

Force FC for the remainder of the emergency

Close FC if they stop receiving a payment.

Former Foster Care (age 26)

Force Adult Expansion without dependents for the remainder of the emergency

Close Adult Expansion without dependents.

Sub Adopt

Sub Adopt 

Force SA for the remainder of the emergency.

If the Sub-adopt agreement cannot be extended then force Child Medicaid. (coordinate with DCFS)

Close SA if they stop receiving payment. 

Breast or Cervical Cancer (BCC)

BCC

Force BCC for the remainder of the emergency

Close BCC

Refugee (not Medicaid)

Any Medicaid program, or CHIP

Force Refugee medical until September 30, 2020

QMB 

QMB

Force QMB for remainder of the emergency

Close if no longer eligible for Medicare

Close QMB (Can close if no longer eligible for Medicare)

SLMB or QI

SLMB then QI if not receiving Medicaid

Force SLMB if individual is eligible for Medicaid. Force QI if not eligible for Medicaid, for remainder of the emergency

Close if no longer eligible for Medicare

Close SLMB/QI (Can close if no longer eligible for Medicare)

Nursing Home

NH

Force NH

Home and Community Based Waivers

Waiver

Force Waiver

UPP

UPP; may request Medicaid if income has gone down

Force UPP (May close if no health insurance.)

Close UPP (May close if no health insurance or the plan is no longer a qualified plan)

Individual who does not provide evidence of citizenship or lawful immigration status after reasonable opportunity period

Retain individual on the same program through the end of the emergency.

If evidence received that proves person is neither a citizen nor a qualified alien, move them to emergency only coverage.

Force eligibility if needed.

Close coverage

Type

Preferred

Allowable

Citizenship & ID

Electronic

Client Statement (CS) if electronic verification is not available and the reasonable time period has expired. (Good faith)

Income (termination)

Electronic verif, Collateral contact

CS if employer is not available or client is in quarantine or self isolation.

Income (new employment)

Electronic verif, collateral contact

CS if employer is not available or client is in quarantine or self isolation.

Income (change)

Electronic verif, pay stubs, employer statement, collateral contact

CS if employer is not available or client is in quarantine or self isolation.

116M

Limit the use of the 116M form to those situations where the health insurance information is required.  (Example - Do not send the 116M for health insurance termination.)

·        CS if the individual is losing insurance.  

·        CS on access to health insurance (5% test) for UPP and CHIP.

·        CS is not allowed if the individual is gaining access to health insurance 

·        CS is not allowed to verify the ESI or UPP payment amount.

Medical bills

Recent copies of billing statements, printouts from medical provider, collateral contact with provider

Collateral Contact (CC) is acceptable.

Applications

Allowable application modalities from policy 703-1

COVID-19 testing sites signed applications for Medicaid and the COVID-19 testing group with verbal consent from the client.