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Published byCaroline Warren Modified over 5 years ago
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AHCCCS Works & Prior Quarter Coverage Overview
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What are Section 1115 Waivers?
Section 1115 of the Social Security Acts –provides states with an avenue to test new approaches in Medicaid and CHIP that differ from federal program rules States must apply for and receive approval from the Centers for Medicare and Medicaid Services (CMS) before making changes to the program
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Arizona’s Section 1115 Waiver Demonstrations
Since the inception of its Medicaid program, Arizona has leveraged its 1115 waiver to implement numerous innovations including: 1982–Statewide mandatory managed care program (with some exceptions) 1989–Arizona Long Term Care System (ALTCS) 2012–Safety Net Care Pool (SNCP) 2013–Integrated CRS Health Plan 2014–Integrated RBHA Health Plans 2017–Targeted Investments (TI) Program 2019–AHCCCS Works
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Timeline and Law Requirement
2015 AZ law amended to include work requirements & 5-year lifetime limit for AHCCCS members January - March 2017 AHCCCS Works Public Comment Period December 19, AHCCCS Works Waiver submitted to CMS
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Timeline and Law Requirement (Cont.)
January 18, CMS approves AHCCCS Works March/April 2019 Presentations No Sooner Than January 2020 AHCCCS Works implementation will happen no sooner than January 2020
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Presentation Overview
AHCCCS Works & Prior Quarter Coverage Background AHCCCS Works Requirements AHCCCS Works Exemptions Community Engagement Orientation Period Reporting Requirements, Suspensions, & Automatic Reinstatement Denied AHCCCS Works Waiver Provisions Waiver of Prior Quarter Coverage Populations Affected by Waiver of Prior Quarter Coverage Next Steps Reaching across Arizona to provide comprehensive quality health care for those in need
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National Landscape: Community Engagement Waivers
As of January 18, 2019, CMS has approved waivers to allow community engagement requirements in seven states: AZ, KY, IN, AR, NH, WI, & MI States with pending waivers: AL, MS, OH, OK, SD, TN, UT, VA, KS
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National Landscape: Community Engagement Waivers
As of January 18, 2019, CMS has approved waivers to allow community engagement requirements in seven states: AZ, KY, IN, AR, NH, WI, MI, & OH States with pending waivers: AL, MS, OK, SD, TN, UT, VA, KS First in the nation to exempt members of federally recognized tribes First in the nation to allow members who are suspended to automatically re-enrolled at the expiration of the Suspension Period as long as they meet all other eligibility criteria
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AHCCCS Works Unique Program Features
First in the nation to exempt members of federally recognized tribes First in the nation to allow members who are suspended to automatically re-enrolled at the expiration of the Suspension Period as long as they meet all other eligibility criteria The AHCCCS Works program is structured differently that other states. Those members who do not meet the monthly requirement are suspended for a 2-month period, not terminated, and automatically reinstated after those 2 months. Additionally, it includes many exemptions for various populations. AHCCCS is developing a comprehensive member and stakeholder communication plan to ensure that the community is aware of the requirements that will be implemented no sooner than Jan. 1, 2020, that members understand the various exemptions, and that everyone who is required to comply can do so successfully. Reaching across Arizona to provide comprehensive quality health care for those in need
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AHCCCS Works Requirements
No sooner than January 1, 2020, able-bodied adults* who do not qualify for an exemption must, for at least 80 hours per month: Be employed (including self-employment); Actively seek employment; Attend school (less than full time); Participate in other employment readiness activities, i.e., job skills training, life skills training & health education; or Engage in Community Service. * Adults = SSA Group VIII expansion population, a.k.a, Adult group Reaching across Arizona to provide comprehensive quality health care for those in need
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Who is Exempt Members of federally recognized tribes
Former Arizona foster youth up to age 26 Members determined to have a serious mental illness (SMI) Members with a disability recognized under federal law and individuals receiving long term disability benefits Individuals who are homeless Individuals who receive assistance through SNAP, Cash Assistance or Unemployment Insurance or who participate in another AHCCCS-approved work program Pregnant women up to the 60th day post- pregnancy Members who are medically frail Caregivers who are responsible for the care of an individual with a disability Members who are in active treatment for a substance use disorder Members who have an acute medical condition Survivors of domestic violence Full-time high school, college, or trade school students Designated caretakers of a child under age 18 Customers will need to claim the following exemptions exclusively in the Portal: Medically Frail Caregivers who are responsible for the care of an individual with a disability Members who are in active treatment for a substance use disorder Members who have an acute medical condition Survivors of domestic violence For some customers, the following exemptions may be identified in HEAplus, but other customers will need to claim the exemption in the Portal: Full-time student Designated caretaker of a child under age 18 Reaching across Arizona to provide comprehensive quality health care for those in need
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Community Engagement Orientation Period
Those who are newly subject to the requirements will receive a 3-month Community Engagement Orientation Period Applies to everyone when requirements first go into effect Applies to members newly enrolled in the eligibility category Applies when a longstanding exemption is lost Does not apply when reinstated following suspension 3 month period begins on the first day of the month after AHCCCS Works orientation packet is sent to the member Compliance is required immediately following the Community Engagement Orientation Period
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Reporting Requirement, Suspension & Automatic Reinstatement
Must complete at least 80 hours of qualifying activities each month and report these hours by the 10th day of the following month Failure to comply for any month triggers a Notice of Suspension sent to the member on the 11th day of the following month 2-month suspension will occur on the first day of the month after the Notice of Suspension was sent – unless, prior to the suspension’s effective date: Member reports and verifies a good cause for noncompliance; Member indicates intent to appeal the suspension; or Member reports and verifies that she/he is no longer subject to the requirements (this can also end the suspension period). Member is automatically reinstated immediately following the 2 month suspension period
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Good Cause Exemptions The recognized circumstances giving rise to good cause include the following verified circumstances: The AW member has a disability federal law and was unable to meet the requirement for reasons related to that disability The AW member resides with an immediate family member who has a disability under federal law and was unable to meet the requirement for reasons related to the disability of that family member Illness of a household or family member requiring the care of the AW member Illness of the AW member Severe inclement weather (including a natural disaster) A family emergency or other life changing event (e.g., divorce, homelessness, domestic violence, birth or adoption, or death)
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In this example, January represents the first month any new AHCCCS member is required to comply
Those who are newly subject to the requirements will receive a 3-month Community Engagement Orientation Period Applies to everyone when requirements first go into effect Applies to members newly enrolled in the eligibility category Applies when a longstanding exemption is lost Does not apply when reinstated following suspension 3 month period begins on the first day of the month after AHCCCS Works orientation packet is sent to the member Compliance is required immediately following the Community Engagement Orientation Period Must complete at least 80 hours of qualifying activities each month and report these hours by the 10th day of the following month Failure to comply for any month triggers a Notice of Suspension sent to the member on the 11th day of the following month 2-month suspension will occur on the first day of the month after the Notice of Suspension was sent – unless, prior to the suspension’s effective date: Member reports and verifies a good cause for noncompliance; Member indicates intent to appeal the suspension; or Member reports and verifies that she/he is no longer subject to the requirements (this can also end the suspension period). Member is automatically reinstated immediately following the 2 month suspension period DENIED WAIVER PROVISIONS CMS denied AZ’s waiver request for expenditure authority at the medical assistance matching rate for the costs associated with the design, development, installation, operation, and administration of systems necessary to implement AHCCCS Works community engagement programs and activities
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Waiver of Prior Quarter Coverage
CMS has approved Arizona’s waiver request to limits retroactive coverage to the month application for all AHCCCS members except for children under the age of 19 and women who are pregnant (including post-partum) once they become eligible The waiver of Prior Quarter Coverage is effective July 1, 2019 Reaching across Arizona to provide comprehensive quality health care for those in need
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Next Steps: AHCCCS Works
February 18, 2019 Waiver Acceptance Letter and Technical Corrections June 17, 2019 Implementation Plan July 17, Waiver Evaluation Design Plan August 16, 2019 Monitoring Protocol No sooner than January 1, 2020 AHCCCS Works program begins Reaching across Arizona to provide comprehensive quality health care for those in need
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