Georgetown Center for Children and Families (CCF) Say Ahhh! Blog published a post regarding the U.S. Department of Health and Human Services’ (HHS) final rule on Medicaid, the Children’s Health Insurance Program (CHIP), and Exchanges
. The blog notes that four of the eight priority issues identified in CCF’s comments on the proposed rule were addressed in the final rule. CCF was pleased to see HHS is working with states to identify alternative strategies if states are not ready to implement a single streamlined application by open enrollment on October 1st
CCF also was glad that the final rule formalized a new certification application counselor program for Medicaid and CHIP, strengthened the cost-effective test, and reaffirmed that participation in premium assistance is voluntary
. However, CCF noted that HHS missed an opportunity to eliminate CHIP waiting periods
and hopes that HHS will release additional final regulations on this and other issues not addressed in the final rule, including: first year coverage for infants, coverage for former foster children up to age 26, simplification of paper based-documentation of citizenship verification, and a more comprehensive definition of “lawfully present.”
CCF also published a blog post explaining the final rule’s income verification language
that was misinterpreted by the media. CCF confirmed that all Exchanges will be required to verify applicants’ reported income to confirm their eligibility for insurance affordability programs. However, if the applicant’s reported income is significantly lower than what is reported in their tax return and if no additional electronic sources of income data are available to confirm the reported amount, State-based Exchanges have the option in 2014 to accept the income level reported by the applicant. If the State-based Exchange elects to use this option it must implement random sampling of applicants to ensure that relying on applicant’s attested income is reliable.