Senate Finance Committee Hearing
Good morning Chairman Hatch, Ranking Member Wyden, and members of the Committee. I am
Overview of CHIP
Since its enactment with strong bipartisan support in 1997, CHIP, a joint federal-state program, has played an important role in providing insurance coverage and access to health care for millions of low-income children with incomes just above Medicaid eligibility levels. Over this period, the share of uninsured children in the typical CHIP income range (those with family income above 100 percent but below 200 percent of the federal poverty level (FPL)) has fallen dramatically--from 22.8 percent in 1997 to 6.7 percent in 2015 (
In fiscal year 201answer any questions you may have., 8.9 million children were enrolled in CHIP-funded coverage (CMS 2017a). States have flexibility in designing CHIP. States can operate these programs either as an expansion of Medicaid, an entirely separate program, or a combination of both approaches. States with Medicaid-expansion CHIP must provide the full Medicaid benefit package, including early and periodic screening, diagnostic, and treatment services, and must follow Medicaid cost-sharing rules. States with separate CHIP provide comprehensive health care services subject to the approval of the Secretary of the
Basis for
Under current law, CHIP is funded through FY 2017, and without congressional action, states will not receive any new federal funds for CHIP beyond
Based on this review, the Commission issued a report this past January recommending that federal funding for CHIP be extended for five years. If CHIP funding is not renewed, many of the children covered under separate CHIP will lose their health coverage. While some of these children may be eligible for private coverage, their families would have to pay considerably more than under CHIP, potentially creating barriers to needed health and developmental services. In addition, they would lose access to services covered by CHIP that are not typically covered by other payers. Those covered by Medicaid-expansion CHIP would not lose coverage but there would be a significant shift in the funding obligation for their coverage to the states.
Moreover, the future of publicly financed health coverage markets currently is uncertain. Over the past few months,
In my testimony today, I will present the rationale behind the Commission's recommendations on the future of CHIP funding and children's coverage, as well as the evidence it considered in making its recommendations. I also will address CHIP financing; in particular, how states will be affected if federal CHIP funding ends.
In a
Stabilizing children's health coverage
In making its recommendations for CHIP funding, a key priority for the Commission was to ensure the stability of children's health coverage during this period of uncertainty about other sources of coverage. The Commission recommends that
Rationale. Extending CHIP for a transition period would ensure that low-and moderate-income children would retain access to affordable insurance coverage during a time of uncertainty for coverage markets. The transition period of five years would also provide time to address concerns with affordability and benefits of other coverage sources, which are described in greater detail below. In addition, this period would provide federal and state policymakers time to plan and implement comprehensive children's coverage demonstrations, which the Commission also is recommending.
BOX 1. MACPAC Recommendations for the Future of CHIP and Children's Coverage
Recommendation 1.1
Recommendation 1.2
Recommendation 1.3
In order to provide a stable source of children's coverage while approaches and policies for a system of seamless children's coverage are being developed and tested, and to align key dates in CHIP with the period of the program's funding,
Recommendation 1.4
To reduce complexity and to promote continuity of coverage for children,
Recommendation 1.5
In order to align premium policies in separate CHIP with premium policies in Medicaid,
Recommendation 1.6
Recommendation 1.7
Recommendation 1.8
The Secretary of
Recommendation 1.9
To further stabilize children's coverage and prevent states from rolling back eligibility, the Commission recommends extending the CHIP MOE through FY 2022. The current MOE, which requires states to maintain the CHIP eligibility levels in place on
The Commission's recommendation reflects the view that an extension to the MOE, which it judged important to retaining gains in coverage, should be accompanied by an extension of enhanced funding. The increase to the CHIP matching rate is also thought to have influenced decisions in 2016 in some states to expand children's coverage, within permissible limits. n1 For example,
The Commission has long held that coverage under separate CHIP authority should not be maintained indefinitely (
Implications if federal CHIP funding is not renewed
If CHIP funding ends and states exhaust available federal funds, the implications for states depend on whether they operate CHIP as a Medicaid expansion or a separate program. As of
Increase in uninsurance. Although the MOE generally requires states to maintain their children's coverage eligibility levels in place when the ACA was enacted, states face different scenarios for separate CHIP and Medicaid-expansion if federal CHIP funds run out. States with Medicaid-expansion CHIP must continue that coverage for children, but instead of receiving the enhanced CHIP match, states will receive the lower Medicaid matching rate. Of the 8.4 million children enrolled in CHIP-funded coverage in 2015, 4.7 million were in Medicaid-expansion CHIP (
States with separate CHIP are permitted to terminate that coverage if federal CHIP funds run out. In this case, the ACA requires states to develop procedures to automatically transition children from separate CHIP to exchange coverage that has been certified as "at least comparable to" CHIP programs with respect to benefits and cost sharing ([Sec.]2105(d)(3)(B) of the Social Security Act (the Act)). If the Secretary finds that no exchange plans are comparable to CHIP, states are not required facilitate the transition to exchange coverage, although families may obtain subsidized exchange coverage on their own. In
We recently updated our analysis of how an end to separate CHIP would affect children's coverage, finding that in the absence of CHIP, 1.2 million children enrolled in separate CHIP would become uninsured because the cost of other sources of coverage would be unaffordable. n2 We estimate that 1.1 million would enroll in employer-sponsored coverage, and almost 700,000 would enroll in subsidized exchange coverage.
This analysis also found that of the children losing separate CHIP and who would become uninsured:
* 44 percent will be eligible for exchange subsidies;
* 40 percent are eligible for exchange subsidies because their parents do not have an offer of employer coverage or the available employer-sponsored coverage excludes dependent coverage; and
* 56 percent will have an offer of employer-sponsored coverage in the household.
However, the average additional premium to obtain family coverage would be 8 percent of income, making the total cost of family coverage equal to 11 percent of family income.
We also previously noted that the majority of separate-CHIP-enrolled children who would become uninsured if CHIP funding is exhausted have family income below 200 percent FPL (61.3 percent) and are non-white (53.9 percent). In addition, 89.6 percent have a full-time worker in the family (
Affordability of coverage. For children in the CHIP income-eligibility range, CHIP coverage is considerably less costly to families with respect to both premiums and out-of-pocket cost sharing than exchange or employer-sponsored coverage (
If these same children were enrolled in employer-sponsored insurance, they would have faced an estimated
Adequacy of benefits.
Differences are pronounced for dental care, an EPSDT service. Like Medicaid, separate CHIP covers pediatric dental services. However in most exchanges and employer-sponsored coverage, dental benefits are offered as a separate, stand-alone insurance product for which families pay separate premiums and cover cost sharing expenses. More than half of all employer-sponsored plans (54 percent) do not include pediatric dental coverage. Of the employers that offer separate dental coverage, many require an additional premium.
CHIP also covers many services important to children's healthy development that are not always available in exchange plans. For example, all separate CHIP and Medicaid programs cover audiology exams, and 95 percent of separate CHIP programs cover hearing aids. However, only 37 percent of exchange plan essential health benefit benchmarks cover audiology exams, and only 54 percent cover hearing aids (
Provider networks. The Commission also looked at how CHIP provider networks compare to those of other sources of coverage. Under federal law, CHIP managed care is subject to the same federal provisions that establish standards for Medicaid managed care ([Sec.] 2103(f)(3) of the Act). These provisions require states to establish "standards for access to care so that covered services are available within reasonable timeframes and in a manner that ensures continuity of care and adequate primary care and specialized services capacity" ([Sec.] 1932(c)(1)(A)(i) of the Act). CHIP regulations also specify that a state must ensure "access to out-of-network providers when the network is not adequate for the enrollee's medical condition" (42 CFR 457.495).
Advocates have suggested that separate CHIP networks are better than Medicaid or exchange plan networks because they are similar to private plan networks or because they are designed specifically for pediatric needs (Hensley-Quinn and
Implications for states
Exhaustion of federal funds. Federal funding for CHIP is capped and allotted to states annually. States have two years to spend their allotments, and unspent allotments are available for redistribution to other states experiencing CHIP funding shortfalls. n4 Under current law, new CHIP allotments are not available after FY 2017 and unspent FY 2017 CHIP allotments that remain available for expenditures in FY 2018 are reduced by one-third ([Sec.] 2104(m)(2)(B)(iv) of the Act). n5
Under current law, in FY 2018, states may continue to spend unspent FY 2017 allotments and redistribution funds from prior years (an estimated
TABLE 1. Projected Exhaustion of Federal CHIP Funds in Fiscal Year 2018
Quarter of fiscal year Number of states States
First quarter (October-
Second quarter (January-
Third quarter (April-
Fourth quarter (July-
Note: CHIP is the State Children's Health Insurance Program.
Source:
Medicare & Medicaid Services, including quarterly projections provided by states in
State policies may also affect when states exhaust their federal CHIP funding. For example, while the ACA's maintenance of effort (MOE) requirement generally prohibits reducing children's eligibility for CHIP, states are permitted to impose enrollment limits "in order to limit expenditures . . . to those for which Federal financial participation is available" ([Sec.]2105(d)(3)(A)(iii) of the Act). States may also take other actions to reduce CHIP spending such as allowing CHIP waivers to expire and cutting payments to plans and providers.
State budgets. Most states have fiscal years that begin
Operational considerations and timelines. Although states can continue to use FY 2017 funds into FY 2018, they cannot do so indefinitely. Moreover, they have legal obligations to notify families, plans, and providers about future plans, which may include freezing enrollment, transitioning children to other sources of coverage, and making eligibility and enrollment systems changes (NASHP 2017). In some states (e.g.,
Although we are hearing from state officials that they do not wish to unnecessarily alarm beneficiaries and other stakeholders, others are planning to send notices this month with freezes beginning in October and November.
Companion Recommendations to Promote Seamless Children's Coverage
In addition to the recommendations pertaining to federal CHIP funding, the Commission made a number of companion recommendations for moving toward a more seamless system of children's coverage. These recommendations include:
* creating and funding a children's coverage demonstration grant program to support state efforts to develop, test, and implement approaches to providing CHIP-eligible children with seamless health coverage that is as comprehensive and affordable as CHIP;
* eliminating waiting periods in CHIP, aligning separate CHIP premium policies with those of Medicaid, and permanently extending authority for states to use Express Lane Eligibility; and
* extending funding to support outreach and enrollment of Medicaid-and CHIP-eligible children, the Childhood Obesity Research Demonstration projects, and the Pediatric Quality Measures Program. Demonstration grants. State innovation will be a key driver in improving the system of coverage for low-and moderate-income children; federal support of such efforts would ease financial barriers to states that aspire to transform their children's coverage systems.
To encourage and support child-focused efforts, the Commission recommends providing planning and implementation demonstration grants to develop and test models for transforming coverage systems for children. Such models could be developed using existing state plan and waiver authorities, such as those available under Sections 1115 and 1332 of the Act. Developing options for a seamless system of affordable and comprehensive coverage for children across available coverage sources will require resources for research and analysis of markets, needs assessments, stakeholder and expert engagement, as well as legal, regulatory, policy, and cost analyses. These activities are typically not eligible for federal match under state plan authority, and in past efforts to develop and implement health delivery system changes, states have used waiver authority or other grant funding such as the Real Choice Systems Change grant program to finance these planning activities. Historically, state demonstrations have been an effective way to gain experience from which learning and strategies can be gleaned for broader take up by states.
Eliminate CHIP waiting periods and premiums for children under 150 percent FPL. While CHIP has been an enormously successful in reducing uninsurance, steps can be taken to promote greater continuity and seamlessness of coverage within the existing program.
Express Lane Eligibility. The Commission recommends that
ELE processes are associated with positive enrollment gains (both new enrollment and renewals), and administrative savings in some states (OIG 2016, Hoag et al. 2013). A federal evaluation indicated that, as of
The Commission also recommends that the HHS Secretary, in consultation with the Secretaries of the
Renewal of other programs. The Commission recommends extending funding for three programs that focus on improving aspects of coverage or care for children enrolled in Medicaid or CHIP for five years through FY 2022: Medicaid and CHIP outreach and enrollment grants, the Childhood Obesity Research Demonstration (CORD) projects, and the Pediatric Quality Measures Program. In past years, funding for these programs has been renewed alongside CHIP funding.
* Outreach and enrollment grants created in 2009 have helped to support states, tribes, and community-based organizations in a variety of proactive outreach and enrollment activities. Funds have also supported a national outreach and enrollment campaign (CMS 2016). These grants are needed to maintain the historic successes in finding and enrolling eligible children and in helping them retain coverage at renewal. Absent such grants, state spending on outreach and enrollment would be limited by federal law to the 10 percent cap on CHIP administrative spending. CHIPRA established this program, appropriating
* CHIPRA also established the Childhood Obesity Research Demonstration (CORD) to identify and evaluate health care and community strategies to combat childhood obesity in children age 2-12 enrolled in or eligible for Medicaid or CHIP (Dooyema et al. 2013). CORD project grantees are evaluating whether multi-level, multi-setting approaches that integrate primary care with public health strategies can improve health behaviors and reduce childhood obesity. The second phase of CORD grants focuses on preventive services to individual children and families in
* In 2009, the
An extension of PQMP funding will allow the Secretary to continue to develop, test, validate, and disseminate new child health quality measures, and to continue revising existing measures for children enrolled in Medicaid and CHIP. In a
Federal Budget Implications
The
Conclusion
CHIP has clearly played an important role in providing access to health care coverage to low-to moderate-income children who otherwise would have been uninsured. In addition, CHIP has provided a platform for state innovations to improve take-up of public coverage among eligible but uninsured children, remove enrollment barriers, and focus on the quality of children's care. For example, outreach and enrollment techniques that often began as experiments in CHIP in individual states were subsequently identified as best practices and, in some cases, are now required in all states for both CHIP and Medicaid.
When the Commission made its recommendations in January, it noted the urgent need for congressional action. With the end of the fiscal year in sight, the Commission must underscore the need for
The Commission's longer-term vision looks to state innovations that would create a more seamless system of children's coverage, provide comprehensive and affordable coverage for low-and moderate-income children, and remove the potential for gaps in coverage and care as children transition between different sources of publicly and privately financed health insurance. Such a system would promote greater alignment between Medicaid, CHIP, and other insurance sources and would smooth out transitions between them. The recommendations of the Commission reflect these goals and take steps to provide states and their federal partners the tools to transform children's coverage.
Thank you, members of the Committee. I would be happy to answer any questions you may have.
Endnotes
n1 The definition of targeted low-income child at section 2110(b) created a CHIP upper income-eligibility limit of no greater than 50 points above the state pre-CHIP Medicaid income levels.
n2
n3 Premiums and cost sharing are permitted for children in separate CHIP (capped at 5 percent of family income), but they generally are prohibited for children in Medicaid.
n4
n5 States experiencing CHIP funding shortfalls can also receive contingency fund payments if their CHIP enrollment exceeds target levels specified in Section 2105(n) of the Act. However, contingency fund payments are not available for FY 2018 and subsequent years.
n6 The projected FY 2018 federal CHIP spending of
n7 Savings were the result of reduced staff time to complete eligibility determinations due to simplified enrollment processes, according to state reports (OIG 2016).
n8 As of
n9 Specifically, the report should describe the legislative and regulatory changes necessary to allow designated programs to use publicly subsidized health program findings to determine eligibility for other programs. The report should also assess the operational challenges and technical feasibility of this policy, and evaluate the implications of broadening ELE authority.
n10 The
Read this original document at: https://www.finance.senate.gov/download/09072017-schwartz-testimony&download=1



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