COVID 19 Questions and Answers

Effective Date: October 14, 2020 - December 15, 2020

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.

*Date*	October 14, 2020
*Policy Reference*	703 & 704
*Topic*	COVID 19 Response
*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*	Will the COVID 19 Recovery Rebate checks be countable for CHIP?
*Answer*	No. See policy 402-13.
*Question*	Will the COVID 19 Unemployment extra benefit checks be countable for CHIP?
*Answer*	No. While unemployment remains countable, the $600 a week COVID related stimulus payment is excluded. DWS must identify and exclude this UI COVID related stimulus payment as countable income. See policy 402-13.
*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, cannot have their eligibility or coverage end.

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

Other changes may occur that would normally cause a client to move to a different Medicaid program, this is acceptable as long as it is an equal or positive change. If a change occurs during the emergency, the following program movement is allowed.

Note - If “normal” program movement is not happening, each client must be tracked so that they can be moved to the correct program when the emergency period ends. For situations not mentioned in this document, consult with a policy specialist from the Department of Health for guidance.

Program	If Still Eligible, Allowed Changes	If No Longer Eligible, Required Actions	Changes Not Allowed
PCR	First PCR, then TR, then Adult Expansion or Aged	Force Adult Expansion for the remainder of the emergency	Close Adult Expansion or Aged
12 Month TR	First TR, then PCR, child (if applicable), then Adult Expansion	For adults -Force Adult Expansion for the remainder of the emergency. For child - Force child for the remainder of the emergency.	Remove the client from some type of continued coverage.
4 Month Extended	May move to PCR, Adult Expansion, Child	For adults-Force Adult Expansion for the remainder of the emergency. For child - Force Child for remainder of the emergency	Close Adult Expansion or Child Medicaid
Adult Expansion w/ children	May move to PCR or remain on Adult Expansion If over age 65 move to Aged Has a disability and receives Medicare move to Disabled	Force Adult Expansion for the remainder of the emergency. Force Aged or Disabled if the client has Medicare.	Close Adult Expansion (may end ESI if no longer enrolled in health insurance or the plan is no longer a qualified plan)
Adult Expansion w/o children	May move to Pregnant woman or remain on Adult Expansion If over age 65 move to Aged Has a disability and receives Medicare move to Disabled	Force Adult Expansion for the remainder of the emergency. Force Aged or Disabled if the client has Medicare.	Move these clients to PCR or Adult Expansion w/ children (may end ESI if no longer enrolled in health insurance or the plan is no longer a qualified plan)
Aged, Blind or Disabled with no spenddown	May still move disabled individual from Aged to Disabled	Force the same program they were on for the remainder of the emergency	- Move a client to MWI or Spenddown. - Move DM (under 100% FPL) to AM.
MWI	ABD w/o premium or spenddown Move to spenddown program only if the spenddown is less than the premium and the client is no longer working	Force MWI for the remainder of the emergency; do not increase premium	Move to Adult Expansion or Disabled with a spenddown that is higher than the MWI premium
TAM	TAM, can move to pregnant woman if pregnant, if at review and eligible for Adult Expansion they can move	Force TAM	Move clients to another program not listed in the “allowed column”
Pregnant Woman	Force Pregnant woman coverage	Force Pregnant woman coverage for the remainder of the emergency.	Move a former PW to another program.
Child 6-18	Child 6-18, or if aging out move to Adult Expansion	Force 6-18 or Adult Expansion for the remainder of the emergency. (If the 19 year old has a child, do not issue PCR.)	Move to CHIP or PCR
Child 0-5	Child 0-5 or if aging out move to Child 6-18	Force Child 0-5 or Child 6-18	Move to CHIP
Child 1yr	Child 0-5	Force Child 0-5	Move to CHIP
Lawfully Present Medicaid child	Child program, or if aging out move to emergency only Adult Expansion	Force Child program, or Adult Expansion for the 19 year old for emergency only services	Close coverage
CHIP (age 19)		Close CHIP coverage	Open Adult Expansion without a Medicaid application.
CHIP (under 19) Premiums will be suspended	First CHIP, may request Medicaid	Force CHIP for the remainder of the emergency	Close CHIP (We will close if they are enrolled in other health insurance)
Spenddown (Medically Needy (MN)) or MWI with premium	Any non-MN If disabled, can move to MWI if working and the premium is less than the spenddown was	Force spenddown or MWI recipients from the month eligibility is met through the end of the emergency period.	Move any non-MN client to MN. Increase the spenddown or MWI premium. Do not refund any spenddown or MWI premiums collected. Refunds will be handled according to current policy.
Foster Care	Foster care; or Former Foster Care if aging out of Foster Care	Force FC for the remainder of the emergency	Close FC if they stop receiving a payment.
Former Foster Care (age 26)		Force Adult Expansion without dependents for the remainder of the emergency	Close Adult Expansion without dependents.
Sub Adopt	Sub Adopt	Force SA for the remainder of the emergency. If the Sub-adopt agreement cannot be extended then force Child Medicaid. (coordinate with DCFS)	Close SA if they stop receiving payment.
Breast or Cervical Cancer (BCC)	BCC	Force BCC for the remainder of the emergency	Close BCC
Refugee (not Medicaid)	Any Medicaid program, or CHIP	Force Refugee medical until September 30, 2020
QMB	QMB	Force QMB for remainder of the emergency Close if no longer eligible for Medicare	Close QMB (Can close if no longer eligible for Medicare)
SLMB or QI	SLMB then QI if not receiving Medicaid	Force SLMB if individual is eligible for Medicaid. Force QI if not eligible for Medicaid, for remainder of the emergency Close if no longer eligible for Medicare	Close SLMB/QI (Can close if no longer eligible for Medicare)
Nursing Home	NH	Force NH
Home and Community Based Waivers	Waiver	Force Waiver
UPP	UPP; may request Medicaid if income has gone down	Force UPP (May close if no health insurance.)	Close UPP (May close if no health insurance or the plan is no longer a qualified plan)
Individual who does not provide evidence of citizenship or lawful immigration status after reasonable opportunity period	Retain individual on the same program through the end of the emergency. If evidence received that proves person is neither a citizen nor a qualified alien, move them to emergency only coverage.	Force eligibility if needed.	Close coverage

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.