At the May 16th HFMA-EMC Member Meeting, Jackie Prokop, Director Program Policy Division for the MDCH, presented an update on the Healthy Michigan Plan (HMP) which received approval from the Centers for Medicare and Medicaid Services on December 30, 2013 and was launched April 1, 2014. The Healthy Michigan Plan is a new category of eligibility authorized under the Patient Protection and Affordable Care Act and Michigan Public Act 107 of 2013 that makes health care benefits available to low-income Michigan residents at a low cost while promoting the adoption of healthy behaviors. How prepared is your organization for Healthy MI Plan? Below are some highlights and key takeaways from Jackie’s presentation that all providers should be aware of.
The HMP is aimed at improving the health and wellbeing of Michigan residents by providing affordable health care coverage to residents who are age 19 to 64 years of age and have a Modified Adjusted Gross Income (MAGI) at or below 133 percent of the federal poverty level. The HMP covers essential health benefits including inpatient hospitalization, outpatient and emergency services, maternity care, behavioral health and substance abuse services, prescription drugs, rehabilitative services and devices, laboratory and x-ray services, preventive and wellness services, chronic disease management, dental services, pediatric care, and family planning. Behavioral Health Services will be provided through the current Prepaid Inpatient Health Plan (PIHP) system. All currently enrolled Medicaid providers are automatically providers for the Healthy Michigan Plan. As of May, over 250,000 Michigan residents have enrolled with HMP, with another 250,000 anticipated eligible statewide.
Application is Fast and Easy
Michigan residents can apply for HMP online, via telephone, or in person. A single, streamlined application process has been implemented (all states utilize the same application process) that relies on electronic data matching to the greatest extent possible and standardizes the calculation of income using a consistent formula. Through streamlining and standardizing the process, the result is an application process that is fast, averaging 15 minutes to complete and receive immediate eligibility determination, and requires no asset test. Upon completion of the enrollment process, beneficiaries will receive their HMP card in the mail within 2-3 days, with coverage retroactive to the 1st day of the month. Enrollees may request up to 90 days retroactive coverage by completing an additional form; however retroactive coverage cannot precede the April 1, 2014 launch of HMP.
Eligibility for HMP will be determined using the new MAGI eligibility methodology required under the ACA. All criteria for MAGI eligibility, including citizen/alien status, social security numbers, child support, and spousal support, must be met for an individual to be eligible for the HMP. To apply, individuals must be between the ages of 19 and 64 years, have a MAGI at or below 133% of the FPL, not qualify for or be enrolled in Medicare or other Medicaid programs, and may not be pregnant at the time of application. Eligibility is based on annual income (approximately $16,000 per individual or $33,000 per family of four). HMP beneficiaries will be required to enroll in a Medicaid health plan as well as contact their primary care physician within 60 days of enrollment to schedule an appointment.
Beneficiaries will receive a mihealth card through the mail when they become eligible for the Healthy Michigan Plan as well as an additional health plan identification card when they enroll in a health plan. The mihealth card does not contain eligibility information and does not guarantee eligibility. Prior to rendering services, providers must verify beneficiary HMP coverage using the mihealth card to access a beneficiary's eligibility information using the Community Health Automated Medicaid Processing System (CHAMPS) eligibility inquiry. The following new benefit plans have been established to identify beneficiaries with HMP coverage:
• MA-HMP (Healthy Michigan Plan)
• MA-HMP-MC (Healthy Michigan Plan Managed Care)
• MA-HMP-ESO (Healthy Michigan Plan Emergency Services Only)
• MA-HMP-INC (Healthy Michigan Plan Incarceration)
Individuals will be enrolled in health plans for one year, after which there will be a yearly open enrollment period. Providers need be aware that should an HMP enrollee be pregnant at the time of re-application they no longer meet the eligibility requirements of HMP and will revert to Medicaid FFS coverage.
Beneficiary Cost Sharing Requirements
Healthy Michigan Plan enrollees will have some cost-sharing responsibilities. Individuals earning between 100 - 133% of the federal poverty level will be required to pay 2% of their annual income toward their HMP coverage. Co-pays will also be utilized for all HMP participants. Total cost sharing requirements, including co-pays, cannot exceed 5% of the annual household income and will be paid through the use of a dedicated health account called the MI Health Account. Cost sharing requirements will begin after the beneficiary has been enrolled in a health plan for six months and will be monitored through the MI Health Account by the health plan. While beneficiaries have an obligation to contribute to their MI Health Account, they are not obligated to fully fund the account in order to receive needed healthcare services. Should beneficiaries default on their payment of co-pays and cost sharing requirements they will not lose their HMP coverage, however the State is considering use of a garnishment tax process via the Federal Government to recoup unpaid amounts.
Providers do not need to collect copays at the time of service as long as the provided service is covered by the health plan. These costs will be tracked and collected from the beneficiary by the health plan on a monthly basis and applied to the beneficiary’s MI Health Account. The total co-pay experience for the initial six months of services will be calculated and the average amount will be the beneficiary’s monthly payment obligation. Average co-pay amount will be recalculated every six months. If the amount contributed by the beneficiary is less than the amount due for a rendered service, the provider will still be paid in full for the services provided. Providers may want to review and revise their participation agreements with HMP health plans as necessary to ensure language indicates that collection of copays for HMP enrollees is the plan’s responsibility and providers will receive full payment for services rendered. Services not covered by the beneficiary’s health plan will be subject to the following co-pays and must be collected at the point of service.
Similar to programs implemented by HMOs and other managed care plans, HMP enrollees will have the opportunity to reduce and/or eliminate their cost sharing responsibilities by engaging in various healthy behavior activities. Such activities include completing the annual health risk assessment and changing unhealthy activities, i.e. smoking cessation. The more health behaviors a beneficiary engages in, the greater the opportunity to reduce cost-sharing responsibility, up to and including 100% elimination of cost sharing.
Transition of Current Adult Benefits Waiver Beneficiaries into the Healthy Michigan Plan
Current Adult Benefits Waiver (ABW) beneficiaries were automatically transitioned into the Healthy Michigan Plan effective April 1, 2014. A key change for these patients is that inpatient care will now be a covered benefit under their HMP coverage where it was not a benefit under ABW.
New cost report requirements
Did you know that for FYEs after March 31, 2014 providers must separately identify Healthy Michigan Plan on cost reports? It’s true, according to information shared by Brian Keisling & Jason Jorkasky of the MDCH at the May 16th HFMA-EMC Member Meeting. It was also stated that the MDCH surveyed Michigan Medicaid plans and while most indicated they have not yet finalized plans for identifying a traditional Medicaid fee-for-service patient from a HMP patient, they acknowledge additional work on this is needed. What does this mean for providers? Providers will need to have a means to capture and track HMP patient data separate from traditional Medicaid FFS and Medicaid Managed Care. While the health plans may not yet have finalized a means of identifying HMP enrollees, providers are encouraged to begin implementing policies and procedures for capturing and tracking HMP patient data for cost reporting purposes, whether that is through the creation of separate insurance plan codes for each HMP health plan or some other means. Providers will be able to access the Community Health Automated Medicaid Processing System (CHAMPS) to verify beneficiary HMP coverage and identify which health plan beneficiaries are enrolled in. Providers must also ensure Patient Access and Eligibility/Verficiation staffs are educated in the need to separately capture/track HMP patient data.
For more information on the Healthy Plan Michigan visit michigan.gov
Written by Cheryl Comeau