Medicaid Enrollees aren’t Wasted: Stopping the Eligibility Rule and Enrollment Rule will steal health care from eligible people
The House Republican reconciliation bill would cut Medicaid by at least $715 billion over the next decade. The proposal has grave implications, including a moratorium imposed on the implementation, enforcement, and administration of the Eligibility and Enrollment Rule. The rule simplifies, and improves, the eligibility and enrollment procedures of Medicaid and Children’s Health Insurance Programs (CHIP). The regulations took effect on June 3, 2024. States across the country are already implementing portions of the rule. The Eligibility and Enrollment rule will harm vulnerable populations.
Older people and people with disabilities may lose access to health care.
The Affordable Care Act created a simplified and streamlined Medicaid enrollment and renewal system. The Eligibility and enrollment rule for 2024 will only benefit MAGI-eligible applicants and enrolledees. The Eligibility and Enrollment Rule allows states to no longer enforce the burdensome enrollment and eligibility requirements that were permitted even after enactment. Non-MAGI eligibles will no longer be more likely to be denied coverage or lose it despite being Medicaid eligible than other Medicaid applicants and enrolledees. The states will be able to again erect damaging and pointless barriers to coverage. These groups will again be more likely to lose or be denied coverage for procedural reasons. Individuals in these groups will again become more likely to lose or be denied coverage for procedural reasons.
People with disabilities will be at greater risk of institutionalization
The Eligibility and Enrollment Rule facilitates access to coverage for people with disabilities and chronic health conditions by allowing states the option to consider more types of projected expenses toward the required “medically needy” spend-down than were previously allowed. Eligible individuals are able to enroll in coverage earlier and remain on coverage. They are also more likely to be able to access community services and are less likely to need to be institutionalized for care. Individuals with disabilities will then have to spend much more money in order to meet this amount. For example, an individual who was meeting their spend-down amount by including projected home- and community-based services expenses of $500 per month would now have to spend at least $500 extra per month ($1,000 total) on qualifying expenses before being eligible for Medicaid through the medically needy pathway.
Without the expanded options provided by the Eligibility and Enrollment Rule, individuals risk losing Medicaid eligibility repeatedly throughout the year as their expenses fluctuate. Churning is the process of a person cycling on and off Medicaid or CHIP in a short period of time, usually due to procedural issues. This prevents them from having consistent access to health care, and can have negative health outcomes for those with chronic conditions and disabilities. The continued disruptions to coverage may substantially increase their risk of institutionalization.
Children will lose access to coverage that supports their health and development
Prior to the Eligibility and Enrollment Rule, states were able to impose barriers to their CHIP programs not allowed in any other insurance affordability program. States could, for example, impose waiting periods, annual and lifetime limits, and lockout periods if premiums were not paid. The Eligibility and Enrollment Rule ended these methods of blocking access for eligible children.
Without the protections of the Eligibility and Enrollment Rule, states will very likely begin blocking enrollment of eligible children again. Nine states had waiting periods in their CHIP programs as recently as February 2024, 12 states had premium lockout periods as of October 2023, and 13 states still had lifetime limits on CHIP services at the time the rule was implemented.
Allowing states to again impose such barriers to access would harm the health and development of CHIP-eligible children. Early coverage is associated with a lower risk of chronic diseases in adulthood. Conversely, a lack of access to health care in childhood is associated with worse health outcomes later in life, as well as more missed school, decreased educational attainment, and increased economic insecurity.
“Churn” on and off Medicaid and CHIP will increase, worsening health outcomes
The Eligibility and Enrollment Rule fosters continued enrollment for non-MAGI eligible individuals. Promoting continued enrollment reduces churn. Churn can lead to gaps in coverage and disrupted care. It is also associated with poorer health outcomes. Individuals who are unable to access preventive health care due to a cyclical coverage pattern may end up in the emergency room or hospitalized. Without the protections in the Eligibility and Enrollment Rule, Medicaid and CHIP enrollees will likely experience disrupted care and worse health outcomes.
Conclusion
Blocking the improvements that the Eligibility and Enrollment Rule made to Medicaid and CHIP will harm all who participate in those programs. The Republican-led effort in the reconciliation bill to halt the implementation and oversight of Eligibility and Enrollment rule weaponizes redtape to take away health insurance from eligible people. Children, blind people, and individuals with disabilities will be affected, as well as older adults and those who rely on Medicaid or CHIP coverage.
