Trump Administration Expands Short-Term Plans

CMS finalized rules Wednesday morning expanding the availability of short-term plans. The administration will allow those plans to remain in place for up to a year and let people renew the coverage for up to three years, reversing the current three-month limit imposed by the Obama administration.

It’s just the latest effort by the Trump administration to make it easier to enroll in cheaper, skinnier coverage that doesn’t adhere to the ACA’s requirements. In June, the administration finalized rules making it easier for small businesses and independent contractors to band together to purchase coverage. Critics worry that consumers will unwittingly purchase coverage that doesn’t cover pre-existing conditions or provide significant financial protection, and that they’ll only discover that when they’re hit with big medical bills.

Just how skinny are these plans? In 2017, insurers that sold short-term plans spent an average of 65 percent of premium revenues on medical costs, according to the National Association of Insurance Commissioners, far below the 80 percent threshold that Obamacare plans must meet. Critics also argue that the proliferation of skinny plans will further destabilize the exchanges, sapping enrollment and driving up premiums.

Is Michigan Imposing Medicaid Work Requirements Without Exempting People Living with HIV?

Michigan submitted an application to Centers for Medicare and Medicaid Services (CMS) last December to extend its Medicaid expansion program, “Healthy Michigan,” which was due to expire on 12/31/18. Michigan plans to amend its 1115 waiver extension request by proposing to add work requirements to its Medicaid program. Like the four states that have obtained permission so far to implement work requirements, Michigan’s new plan includes a provision to exempt Medicaid recipients from work requirements who are defined as “medically frail”. Unlike the other four, however, Michigan appears NOT to automatically categorize people living with HIV as being medically frail. Further, Medicaid eligible people who are presumed to be able to meet the work requirements but fail to do so can lose their Medicaid coverage for a year.

Michigan’s new waiver application and attachments refers to “medically frail” individuals without defining the designation as applicable to people living with HIV. The application also stipulates (in Attachment L) that “Medicaid enrolled providers will be able to recommend that an individual be considered medically frail through clinical judgement in cases where individuals may have not self-identified or had a claim indicating medical frailty. Health care providers whose scope of practice qualifies them to assess an individual as medically frail will be able to complete a Medical Exemption Request form on behalf of an individual”.

While it is not clearly stated, Michigan’s application strongly implies that individuals living with HIV and relying on Medicaid coverage will have to enlist a doctor’s help in asserting that she or he is medically frail and, therefore, ineligible for work requirements. This status will have to be re-affirmed annually.

Public Comments on this application will be accepted until August 12, 2018. Complete instructions for submitting comments are available at https://www.michigan.gov/mdhhs/0,5885,7-339-71547_2943_66797-472387–,00.html. Go to Attachment K, Page 4. To submit them electronically, please send them to healthymichiganplan@michigan.gov and enter in the Subject line “Demonstration Extension Application Amendment”.




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