District of Columbia Justice Involved Medicaid Suspension Presentation

Presentation Outline Snap Shot of District of Columbia Medicaid Suspension Practices for Incarcerated Individuals Reinstatement of Benefits & Re-entry Planning Questions

Snap Shot of the District of Columbia Population-672,228 Approximately 250,000 residents are enrolled in D.C. Medicaid Childless Adults covered up to 210% FPL The District of Columbia is comprised of 8 sections called “Wards”. Department of Corrections Information DC Dept. of Corrections (DOC) operates a detention center. DC does not have a prison system. The average length of stay is 29 days. For FY 16, the average daily population at the detention center was 1,747.

Collaborative Effort Between Department of Healthcare Finance (DHCF), Department of Corrections (DOC), and the Department of Human Services (DHS)

Medicaid Policy Goals for Justice-Involved Individuals Preserve Medicaid eligibility by suspending Medicaid enrollment for incarcerated beneficiaries. Ensure that newly incarcerated residents are screened for eligibility and placed in suspended enrollment if eligible during incarceration through enrollment assistance supports. Allow Medicaid to claim for inpatient hospital services for incarcerated individuals admitted for over 24 hours (Inpatient Exception). Ensure reinstatement of full Medicaid coverage upon release and provide continuity of prescriptions during any coverage gaps. Terminate Medicaid enrollment for released individuals who are no longer eligible for coverage.

District’s Initiative to Change Medicaid Policy for Justice-Involved Individuals Tri-Agency Workgroup Created Spring 2014: Department of Health Care Finance (DHCF) , D.C. Department of Corrections (DOC), Department of Human Services. Workgroup Established Goals and New Policies/Procedures: Managed Care vs Fee for For Service DC Residents in Federal Custody Residency and Temporary Absence Policy Initiated February 2015: Implementation began in February 2015 and has been refined over time.

Implementation Efforts In an effort to establish new suspension policy and the streamline application process, the following steps were taken: Leadership Buy In In Spring 2014, The Tri-Agency Workgroup was created Strategy Development Weekly Meetings were held to develop strategies to exchange data and opportunities for incarcerated individuals to apply for Medicaid Policy and MOA Development A Memorandum of Agreement was authored to define the responsibilities of each agency DHCF developed policy detailing its application and suspension process for justice involved citizens System Development DHCF’s operations team programed MMIS to allow for the suspension/ reinstatement process Coordinated with System Developer to create automated application questions and enroll suspended beneficiaries online Implementation February 2015, DOC and DHS began sharing information to suspend inmates and reinstate returning citizens. We continue weekly meetings to monitor and improve the processes

Opportunities for Incarcerated Individuals to Apply for Medicaid Enrolling the DC Jail Population At Intake (Booking) At the Hospital, in the case of an inpatient stay During Jail Stay Before Reentry to the Community

Medicaid Suspension Practices: Changes in Medicaid eligibility determinations for incarcerated individuals DOC provides incarceration data to ESA ESA cross-references DOC/ACEDS information ESA updates program code DHCF disenrolls beneficiary from MCO Beneficiary notified

Suspension Process for New Applicants Individual applies for Medicaid while incarcerated Individual indicates current incarcerated status in DCHL application Once approved, system will assigned an “I” program code Once released, “I” suffix will be dropped from the program code

Suspension Medicaid Coverage Process The communication tool used to initiate suspension and reinstatement of Medicaid coverage consist of three reports to inform agencies an action is needed. Weekly report sent from DOC to DHS DHS identifies individuals who should have Medicaid suspended Incarceration Report DHS identifies individuals who should have Medicaid reinstated Release Report Weekly Report Sent from DOC to DHS Identifies Individuals sent to Federal Custody Transfer Report

Reinstatement of Benefits When a beneficiary is released, full Medicaid coverage and MCO enrollment, if applicable, will be reinstated. Inmates released to halfway houses under government control are still considered to be inmates, and their Medicaid benefits will remain in suspended status. District in the process of changing halfway inmate policy to provide coverage, system update required before implementation.

Returning Residents Residents returning to the District from federal prison may apply for Medicaid coverage up to 45 days prior to returning to the District. Returning residents applying for coverage must indicate their intent to return to the District on the DC Health Link application.

Data From October 1, 2015 to February 29, 2016: DOC released 1,363 inmates from its custody. Of these inmates, 641were remanded to federal custody and sent to federal prisons in other states. Their Medicaid was terminated because they no longer met residency requirements for D.C. Medicaid. Of the remaining 722 inmates, 58% (421) were enrolled upon release into full Medicaid coverage and 42% (301) were not enrolled. All had the opportunity to apply, either at intake, during their incarceration, or prior to release. A total of 363 Medicaid applications were submitted on behalf of incarcerated individuals between October 1, 2015 and February 29, 2016 (292 by caseworkers; 71 by FQHC assisters). The District has also promoted continuity of coverage, by providing inmates with ongoing prescriptions with 7 days of prescription drugs upon release to fill a coverage gap.

Lessons Learned Effective, on-going communication with sister agencies and other stakeholders is critical. Creation and sharing of regular reports was necessary to ensure returning citizens had immediate access to vital health care and did not experience a gap in coverage. Creation of multiple ways for individuals to apply for Medicaid coverage. Creation of seamless transitions from MCO to FFS to MCO.

Next Steps Create interface between DC Automated Eligibility and Enrollment System (DCAS) and DOC, to streamline the suspension process and eliminate the manual process. The result will be a faster, more efficient suspension/reinstatement process. Collaborate with the FBOP halfway house to exchange data so that returning residents can be enrolled in Medicaid, either through application or reinstatement. Engage Federal Qualified Health Centers (FQHCs) and Managed Care Plans to understand the health needs of returning residents and connect them to the appropriate care. Enroll returning citizens with qualifying conditions into Health Homes.

Questions?