COVID 19 Questions and Answers

Effective Date: December 16, 2020 - January 31, 2021

On March 18, 2020, Public Law 116-127 passed. This law provides an increase in the federal funds a state may receive during the COVID-19 Health Emergency. In response to this health emergency, Utah intends to keep CHIP recipients enrolled in coverage during the emergency period, and not impose more restrictive eligibility standards, methodologies or procedures than what were in place on 1/1/2020.

The following Q & As are designed to help the Medicaid Eligibility Agency assure eligible individuals receive continued coverage during the emergency period.

*Policy Reference*	703 & 704

*General*	Follow all normal eligibility policy, unless making any change makes the person ineligible, or reduces coverage. See resource below.

*Question*	During the COVID-19 Health Emergency, can CHIP eligibility end?
*Answer*	No. For anyone who was eligible for CHIP on March 18, 2020, or who becomes eligible during the Health Emergency, the Eligibility agency cannot terminate their CHIP eligibility. This requirement lasts through the last day of the month in which the Health Emergency ends. After that, the agency must decide if the client is no longer eligible and provide 10-day notice. There are a few exceptions: If a client dies, moves out of the state permanently, asks the agency to end their CHIP coverage, or CHIP is approved in error, the agency will then end eligibility. The Eligibility Agency will give proper notice.
*Question*	What do we do when a child ages off of CHIP?
*Answer*	As of August 1st close CHIP. Help the 19 year old who is aging off CHIP apply for Medicaid.
*Question*	Do we continue coverage for a lawfully present child during the emergency?
*Answer*	Yes. If the child is under age 19, follow the same process as for any other CHIP child as described in this Q&A. If a change would cause the child to lose CHIP eligibility, we must continue their eligibility through the end of the emergency. However, if the child turns age 19 during the emergency period, move the child to emergency only Adult Expansion Medicaid. The agency may have to force eligibility.
*Question*	What happens if someone has a review due during the emergency period?
*Answer*	Follow normal review policy in section 704. If the agency can renew eligibility through an ex-parte review without making any changes that make the person ineligible, or reduces coverage then renew eligibility. CHIP premiums will be suspended during the emergency. If a prepopulated review needs to be sent out but the client does not provide all required verification, then the agency will need to add a due process month until the review is completed or until the emergency ends. If a review is due for a different program, like food stamps, and verification are requested, the CHIP program cannot end due to failure to provide the verification, or due to changes that affect the other program (like a change in income.)
*Question*	How should the agency deal with reported changes?
*Answer*	During the emergency period, if the agency receives information about a change in circumstances, the agency should retain the information. The agency cannot act on any change that would cause the CHIP to end or increase cost sharing. The agency may have to manually issue benefits or push out effective dates. However, if the reported change is that the client is moving out of the state, has died, or a request from the client to close CHIP, the agency will act on those changes and end CHIP eligibility. After the emergency ends, the change information received previously should be verified to update eligibility for future months.
*Question*	What if the child becomes enrolled in a health insurance plan?
*Answer*	The CHIP case will close if it is private health insurance or a Federally Facilitated Marketplace insurance plan.
*Question*	If a reported change would make a child eligible for Medicaid, do we move them from CHIP to Medicaid?
*Answer*	Yes. Medicaid without a spenddown is a better benefit. A child can be moved from CHIP to Child Medicaid during the emergency. Once on Medicaid, do not end eligibility for the child through the end of the emergency.
*Question*	What happens if a client enters a public institution?
*Answer*	The child’s CHIP will close and will reopen if the child leaves the facility during the emergency period.
*Question*	What do we do if a client is receiving Continued Benefits pending the outcome of a Fair Hearing?
*Answer*	If the client was enrolled in CHIP on March 18, 2020 and is receiving continued benefits pending a Fair Hearing, the agency cannot close their case until the emergency period ends. If the result of the Fair Hearing would result in case closure, that decision cannot be carried out until after the emergency period ends. The client’s eligibility is protected through the end of the emergency period. No overpayment will accrue for such dates, either. After the emergency ends, the agency needs to reevaluate the situation to determine whether the client is ineligible. Medicaid may be closed if the client is no longer eligible at that time.
*Question*	Will overpayments be assessed if the agency later finds that someone enrolled on March 18, 2020, or who becomes enrolled during the emergency period, really was not eligible?
*Answer*	No. However, if there is suspected fraud, the agency may refer the case for criminal investigation.
*Question*	What happens if a client fails to pay their quarterly CHIP premiums?
*Answer*	Premiums for CHIP households will be suspended during the emergency period. In addition, any premiums the agency has collected since March 1, 2020 must be refunded to the household.
*Question*	What will happen to CHIP late fees during the emergency period?
*Answer*	Fees for making a late premium payment will be suspended during the emergency period. Any fees already collected since March 1, 2020 must be refunded to the household.
*Question*	Do we continue eligibility for an otherwise eligible CHIP child who needs to provide evidence of citizenship or satisfactory immigration status if they do not provide such evidence by the end of the 90 day reasonable opportunity period?
*Answer*	Yes. Otherwise eligible individuals for whom the agency is unable to receive electronic verification of citizenship or satisfactory immigration status will continue to receive CHIP assistance through the end of the emergency period. After the emergency period ends, if the client has received the full reasonable opportunity period to provide evidence of citizenship or immigration status, the agency will terminate coverage. Do not end benefits during the emergency period. However, if the agency receives verification that proves the individual is neither a citizen nor a qualified immigrant, the agency will change eligibility to the emergency services Medicaid program for the duration of the emergency period.
*Question*	Can I accept a ‘testing site’ location as a ‘signature’ for Medicaid?
*Answer*	Starting on June 22, 2020, COVID-19 testing sites will sign applications for Medicaid and the COVID-19 testing group with verbal consent from the client. The testing site will be acting as an authorized representative with limited scope to sign on behalf of the applicant for this coverage only during the PHE. The testing site must be noted in the case record. Once approved, a form 40 and a 61Med will be generated. DWS receives and follows established process (enters enters/ongoing application). When the emergency period ends, a signature must be obtained by the client to maintain ongoing Medicaid coverage.
*Question*	When a client is unable to sign an application (paper/online/in person), what options do they have?
*Answer*	There are two ways. See policy 701. 1. Complete a telephone application with a telephonic signature. 2. The authorized representative will complete an application and form 114COVID. The form 114COVID allows a limited role for an authorized representative to sign and complete an application on the client’s behalf. This option will only be available during the PHE period.
*Question*	Does eligibility continue for a household member on CHIP that leaves the home and remains in Utah during the emergency period?
*Answer*	Yes with an exception for adoption. Exception for Adoption: · The birth mother has given up parental control (adopted), close the child’s case as customer request. Examples of when a child on CHIP leaves the home that require opening a new case: · If a child on CHIP leaves the home with a known address, open the client on their own case with the updated address. · If a child on CHIP leaves the home for any domestic violence issues, open the client on their own case with an address of general delivery.

Resource

During the national public health emergency period, clients who were enrolled in Medicaid or CHIP on March 18, 2020, and those who become eligible during the emergency, may not have their eligibility or coverage end.

In all cases where the member dies, loses residency, was approved due to agency error or requests to have their case closed, the eligibility should end.

We have three tiers of programs. Changes may occur that would normally cause a client to move to a different Medicaid program, any movement between same tier programs is allowed.

A client may request that their case be changed from a higher (Tier 1 or Tier 2) to a lower tier (Tier 2 or Tier 3).

Note - For situations not mentioned in this document, consult with a policy specialist from the Department of Health for guidance.

This is in alphabetical order. Not in hierarchical order.

Tier 1 Programs
Program	Program to force when not eligible for any other Tier 1
Adult Expansion	Force Adult expansion with or w/o kids as proper. If the client has Medicare and not eligible for MCSP, then force Aged, or Disabled 100% FPL.
Aged, Blind or Disabled with no spenddown	Force Aged or Disabled 100% FPL
Breast or Cervical Cancer (BCC)	Force Aged or Disabled 100% FPL
Child 6-18	Force Child 6-18. When the client turns 19, force Adult Expansion.
Child 0-5	Force Child 0-5. When the client turns 6, force 6-18.
Child 1yr	When the client turns 1, force 0-5.
Lawfully Present Medicaid child	Force Child Medical. When client turns 19, force Adult Expansion emergency. Move to Tier 3.
Former Foster Care (age 26)	When the client turns 26, force Adult Expansion.
Foster Care	Force Foster Care
Foster Care Independent Living	Force Foster Care Independent Living Client turns age 21 - force Adult Expansion.
Home and Community Based Waivers	Force Aged or Disabled 100% FPL.
Medicaid Work Incentive (MWI)	Force MWI if they still have earnings. Force Aged or Disabled 100% FPL if they do not have earnings.
Medicare Cost Sharing Program only (MCSP) - QMB	Force QMB, SLMB or QI
MCSP only - SLMB or QI	Force SLMB or QI
Nursing Home	Force NH, sanctions do apply (Question came up about forcing ABD)
PCR	Force Adult Expansion
Pregnant Woman	Force Adult expansion when the post partum period ends
Refugee (not Medicaid)	If not eligible for another program, close Refugee.
Sub Adopt	Force SA for the remainder of the emergency. DCFS will extend the adoption agreement end date on the program evidence for SA IV-E Medicaid. If the Sub-adopt agreement cannot be extended then force Child Medicaid. (coordinate with DCFS) FEAR evidence must be added for the SA Non IV-E Medicaid, to extend coverage beyond age 18.
TAM	Force Adult Expansion If the client has Medicare and not eligible for MCSP, then force Aged or Disabled 100% FPL.
4 Month Extended	Force Adult Expansion
12 month TR	Force Adult expansion
Tier 2 Programs Note - Tier 1 clients may request to be moved to this tier.
Spenddown (Medically Needy (MN)) or MWI with premium	Force MN or MWI with premium.
Tier 3 Programs Note - Tier 1 and Tier 2 clients may request to be moved to this tier.
COVID-19	Force COVID-19
Emergency Programs	Force emergency
Presumptive Eligibility	Close at end of PE period, or Medicaid decision
Tuberculosis	Force TB
UPP	Keep open with $0 payment.
Other programs
CHIP	May move to Medicaid. May not decrease CHIP benefits (Plan B to Plan C.). May not move from Medicaid to CHIP.

Temporary COVID-19 Verification Changes

Follow policy 705, if verification is required from the client per policy, the following temporary exceptions are allowed during the National Health emergency COVID-19 period. The intent is to help people in quarantine or self isolation as information may be difficult to obtain during the emergency period.

Type	Preferred	Allowable
Citizenship & ID	Electronic	Client Statement (CS) if electronic verification is not available and the reasonable time period has expired. (Good faith)
Income (termination)	Electronic verif, Collateral contact	CS if employer is not available or client is in quarantine or self isolation.
Income (new employment)	Electronic verif, collateral contact	CS if employer is not available or client is in quarantine or self isolation.
Income (change)	Electronic verif, pay stubs, employer statement, collateral contact	CS if employer is not available or client is in quarantine or self isolation.
116M	Limit the use of the 116M form to those situations where the health insurance information is required. (Example - Do not send the 116M for health insurance termination.)	· CS if the individual is losing insurance. · CS on access to health insurance (5% test) for UPP and CHIP. · CS is not allowed if the individual is gaining access to health insurance · CS is not allowed to verify the ESI or UPP payment amount.
Medical bills	Recent copies of billing statements, printouts from medical provider, collateral contact with provider	Collateral Contact (CC) is acceptable.
Applications	Allowable application modalities from policy 701	COVID-19 testing sites signed applications for Medicaid and the COVID-19 testing group with verbal consent from the client.