Health Update –July 27, 2021
Recording & slides of July 22 Estate Recovery webinar now available.
If you missed the July 22, 2021 Estate Recovery Webinar, the recording is posted here on the masslegalservices youtube channel & the powerpoints are attached. https://youtu.be/
Elderly & Disabled Dual Eligible Members Terminated from MassHealth Standard during the Public Health Emergency (PHE)
Over the 4th of July weekend, MassHealth modified its continuous coverage protections during the PHE to no longer protect dually eligible members from being terminated from MassHealth Standard if they at least still qualify for the Senior Buy-In or Buy-In. Attached is a redacted copy of what one of these “downgrade” notices look like dated July 6, 2021.
On July 21 and 28, 2021 MassHealth presented its updates at the quarterly MTF. It had one slide on this change and all it said was that the MassHealth continuous coverage policy “now aligns with the guidelines of the Interim Final Rule issued by CMS effective Nov 2, 2020.” MTF also sent out an email on July 22 updating MassHealth’s response to COVID, but it too only contained the cryptic reference to federal guidance: “MassHealth will maintain coverage for individuals who have comprehensive coverage, as defined by federal guidance, since March 18, 2020, during the COVID-19 federal public health emergency,” What MassHealth is not explaining is that the Nov 2020 federal rule considers Medicaid payment of a Pt B premium for Medicare beneficiaries to be “comprehensive coverage.”
Please be on the look-out for these downgrades. The first ones we’ve seen got the MSP determination wrong & were based on incorrect income & asset information all compounded by the lack of information. Advise clients to appeal in time for aid pending, and notify us if you have an affected client or patient: email@example.com or firstname.lastname@example.org
See our July 19, 2021 Health Update for more information.
Enrolling with the Health Connector.
Open enrollment ended July 23, 2021 but individuals applying for coverage too late for open enrollment but who are “newly eligible” for ConnectorCare automatically qualify for a special enrollment period (SEP) and can still enroll for 2021 coverage. If someone does not qualify for this automatic SEP, there are many other qualifying events that may apply. This link has more information about enrolling after open enrollment ends. https://www.mahealthconnector.
Health Connector Requests for Information (RFI)
Starting the first week of July, the Health Connector began closing out approximately 90K requests for information (RFIs).
· Individuals with older, outstanding RFIs received a reminder letter in early June, and many individuals received RFIs when the system redetermined their new tax credit amounts under the ARP this spring
· As a reminder, applicants and members have 90 days to respond to an RFI and submit eligibility verifications
· Members can see what documents they owe on the application summary screen in their online account at MAhealthconnector.org
For more information on how to help applicants and members submit RFI’s go to: https://www.
Health Safety Net Changes
· HSN Partial Deductibles are now being charged for dates of service of June 15, 2021 or later. This is the link to a June 2021 HSN Billing Update describing the end of the COVID flexibility that paid HSN claims regardless of a deductible. https://www.mass.gov/doc/
If people with HSN partial now have lower income than they had when their deductible was calculated, they should update their information in order to obtain a lower deductible.
· Options to enroll in ConnectorCare for ConnectorCare eligible but unenrolled people whose HSN recently changed to dental-only. In July and August 2021 HSN ended HSN medical for about 30,000 people who had been eligible but unenrolled in ConnectorCare for more than 90 days. This time limit on HSN medical coverage had been suspended during COVID. People taken by surprise by the end of HSN medical should still be able to enroll in ConnectorCare in 2021 but they will need to call the Health Connector and explain that they did not understand the situation. This should be treated as an administrative qualifying event allowing them to enroll outside of open enrollment (which ended July 23).
People enrolled in PACE will be able to remain eligible despite modest increases in income.
On July 14, 2021 MassHealth released Eligibility Operations Memo 21-13 extending the "Post-Eligibility Treatment of Income" (PETI) rules for determining continuing eligibility to people enrolled in PACE. This is good news. PACE & HCBS waivers both use a "special income standard" that in 2021 is $2382 per month. Once someone is found eligible under this special income standard, a later increase in income may be evaluated under the more generous PETI rules in determining continuing eligibility. Posted here is a memo from MLRI explaining the extension of PETI to HCBS waivers in 2019. Starting July 14, 2021 MassHealth is also applying the PETI rules to PACE. This is a permanent change, it is not tied to the COVID continuous coverage protections during the pandemic.
Helping patients who are homeless or housing unstable
The MEMA-funded isolation and recovery sites set up during the pandemic are no longer operating. However, COVID-19 still poses a risk to shelter guests given the pre-existing health conditions of many homeless individuals and the current vaccination rates across shelters. As a result, EOHHS sent a communication to hospitals telling them not to discharge individuals who have a positive COVID-19 test result and lack a safe space to quarantine or isolate.
EOHHS has resources available for hospital staff in regards to discharge planning for individuals who are homeless or housing unstable. https://www.mass.gov/info-
Redacted Downgrade notice from MassHealth Standard to Buy-In
July 22, 2021 Estate Recovery Webinar Presentation