LHD Alert #4 -- Operational Changes in Response to the COVID-19 Crisis

Fri 3/27/2020 8:19 AM

CSHCS local colleagues,

The CSHCS Division has been working to identify temporary operational changes in response to the COVID-19 crisis, in order to minimize the impact of the crisis on access to needed health care and pharmaceuticals for CSHCS clients.  We are moving forward with operationalizing the changes described below.  If you have comments, questions, suggestions, or concerns about these changes, please contact Lonnie Barnett.

Wishing all of you and your families good health and safety. 

Lonnie D. Barnett

Director, Children’s Special Health Care Services Division

Michigan Department of Health and Human Services

1. Medical Review Dates:  We are working with our IT Vendor to extend by 12 months the medical review date for any clients who have a medical review date between 2/1/20 – 7/30/20 (with the exception of the newborn diagnosis codes and a limited number of other codes for conditions that could resolve in a year).  Note CSHCS enrollment periods are 12 months in duration, and eligibility and renewal have both a financial component and a medical component.  Financial review occurs annually, and medical review can be either 1,2,3 or 5 year review, depending on the CSHCS diagnosis.  Extending the medical review date by 12 months for those clients that are currently due for a medical review addresses the concern/barrier of not being able to be seen by a pediatric subspecialist for a routine (non-urgent) visit.  This also addresses a concern conveyed by Medicaid Health Plans, which play an active role in obtaining and submitting medical on behalf of their members.  If all goes as planned, this change will be in place prior to the beginning of our April renewal cycle.  We have worked with our Office of Medical Affairs (OMA) pediatric medical consultants to identify the newborn and other codes to not include in the extension of medical review dates.

2. Income audits:  For CSHCS clients with a payment agreement, the payment agreement amount is based on self-reported income and family size.  Approximately 50 clients are randomly selected each month for an income audit.  Those selected for an audit need to provide proof of self-reported income in order for coverage to be established for the client.  Given the COVID-19 emergency, the income audit process could create a barrier to coverage.  In addition, our historical income audit data demonstrates that approximately 96% of families are self-reporting the correct payment agreement amount.  During the state of emergency, we are suspending the income audit process and waiving the income audit for those in the midst of an audit.

3. Temporary eligibility period (TEP):  All CSHCS clients in the lowest payment agreement category ($120 per year) are required to apply for Medicaid coverage.  These clients are placed into a temporary eligibility period for 90 days, and coverage is extended for the full year upon verification of the application for Medicaid coverage.  Supporting families placed in a TEP and assuring that they apply for Medicaid is a primary responsibility of our LHD staff.  Given that MDHHS has suspended the LHD minimum program requirements during the pandemic, and the additional demands being placed on local CSHCS staff, we are suspending TEP until 30 days after the end of the emergency declaration.  Clients in the lowest payment agreement amount will receive an encouragement letter to apply for Medicaid coverage, but this will not be required.

4. Medical reports - date:  CSHCS requires that medical reports submitted for eligibility determination be from within the last 12 months.  Given concerns about access to pediatric subspecialty medical providers during the pandemic, the OMA physicians now have the discretion to review a medical report older than 12 months for eligibility determination.

5. Medical reports – PA and NP:  CSHCS requires medical reports be signed by a pediatric subspecialist.  Many of the reports that we receive are signed by a NP or a PA, and CSHCS will not approve the reports until it is signed by the sub-specialty physician supervising the care.  CSHCS will accept medical reports signed only by a PA or NP at this time and until 30 days after the end of the emergency declaration, as part of our efforts to assure health care access and continuity of care for our clients.

6. Emergency Exceptions:  CSHCS Customer Support Section Analyst staff can provide exceptions on a case by case basis to extend coverage when coverage has lapsed as a result of COVID-19.  For instance, if a client is quarantined and therefore is unable to provide required renewal information, coverage can be extended to assure access to care and needed medications.  Analyst staff will maintain a list of all approved exceptions, which will be periodically reviewed by management.  We are not anticipating a large number of these exception request approvals