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TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

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Page 1: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

TennCare Redetermination

Gordon Bonnyman, Staff AttorneyRachel Clifton, Training Coordinator/Client Advocate

10/21/2015

Page 2: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Agenda• Description (5 min)• Background (5 min)• Process (10 min)• Challenges (10 min) • How to Help (20 min)• Questions & Answers (10 min)

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Page 3: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

What the law requires

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Page 4: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Periodic Redetermination of Medicaid Eligibility

By federal law, all Medicaid (TennCare) enrollees must have their eligibility redetermined every 12 months.

42 CFR 435.916(a) and (b)

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Page 5: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

According to the TennCare Rules:REDETERMINATION shall mean the process by which [DHS] evaluates the ongoing eligibility status of TennCare Medicaid and TennCare Standard enrollees. This is a periodic process that is conducted at specified intervals or when an enrollee’s circumstances change. The process is conducted in accordance with TennCare’s, or its designee’s, policies and procedures.

10/21/2015

TennCare Rule 1200-13-13-.01

Page 6: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

The State is Required to…• Extend coverage for all enrollees whose current

eligibility can be determined by review of records already available to the state. (“Ex parte review”)

• Send to enrollees notices that are pre-populated with any information already available to the state.

• Afford enrollees an opportunity to provide any missing information or documentation.

• Provide assistance – in person & by phone.

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Page 7: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

And…• Assess enrollees’ eligibility in all open

categories of TennCare.• If ineligible for TennCare, determine eligibility

for other insurance affordability programs (CoverKids, PTCs, CSRs).

• Electronically transfer files to the Marketplace for those determined eligible for other insurance affordability programs.

• Notify enrollees of the state’s determination.10/21/2015

Page 8: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

The Enrollee is Required to…• Keep TennCare informed of any changes in

contact information.• Report changes in income &/or household

composition.• Respond to redetermination notices within 30

days.• Provide supporting documentation, as

requested by the state.

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Page 9: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Background

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Page 10: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

TennCare Redeterminations have been delayed for up to 3 years.

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Page 11: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Process

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Page 12: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Changes in the Process• This year’s redetermination process will look

different than in previous years.• DHS is no longer involved.• Enrollees do not have a case worker they can

contact.• A separate form must be sent back for every

household member.

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Page 13: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Three Phases

• Phase 1: SNAP Match• Phase 2: Confirmation Mailing• Phase 3: Renewal Packet

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Page 14: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Phase 1• In May & September the state redetermined

eligibility for approximately 720,000 individuals.• TennCare used SNAP (Supplemental Nutrition

Assistance Program a.k.a food stamps) data gathered by DHS to redetermine eligibility.

• No one lost eligibility as part of Phase 1.• Enrollees for whom there was a SNAP match

should have received a notice that their TennCare will continue.

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Page 15: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Phase 2• Starting in October, TennCare sent notices to

an additional group of 100,000 enrollees.– Letters will go to 200k more in November & December.

• The notice asks individuals to sign & return the forms if their circumstances have not changed since their last eligibility review.

• Based on self-attestation.• No immediate loss of eligibility in Phase 2.

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Page 16: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Phase 2• Enrollees can complete the form & fax or mail

it to TennCare to complete the redetermination process.

• Every enrollee in a family will receive his/her own form to fill out & send back in.

• It is especially important that all notices are returned to the address &/or fax number noted on the notice.

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Page 17: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Page 1

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Page 18: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Page 2

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Page 19: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Attachment TN A299a

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Page 20: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Phase 3• Phase 3 will start on December 1. • This step will require enrollees to respond to

extensive requests for information.• It will affect individuals due for

redetermination, whose eligibility was not redetermined in Phase 1 or 2.

• Failure to document eligibility or respond to notices will result in termination of TennCare.

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Page 21: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Phase 3MAJOR TAKEAWAY: Phase 3 will be extremely challenging. It has enormous risk of loss of coverage.

For the sake of both the state and enrollees, it is important to make sure everyone who can qualify for redetermination in Phase 2 be identified and have their coverage renewed.

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Page 22: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Challenges in Completing Phase 2

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Page 23: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

These Challenges Are:

• Enrollees may not receive the notice.• Enrollees may not understand the notice.• Enrollees may fail to take timely action.

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Page 24: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Enrollees May Not Receive the Notice

• At least one third are likely to have moved since their eligibility was last determined. http://blogs.census.gov/2012/12/10/america-a-nation-on-the-move/

• Even if they reported a change in address, they can’t be sure the new address made its way into the system.

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Page 25: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Enrollees May Not Understand the Notice

The notice is ambiguous.

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Page 26: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Intro Is Vague & Potentially Misleading

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Page 27: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Enrollees May Miss the Punchline

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Page 28: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Threat of Jail May Deter Enrollees from Taking Needed Action

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Page 29: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

How to Help

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Page 30: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Step One: Getting the Notice• Encourage all enrollees to update their contact

information with TennCare.• Make sure to list all the household members.• Include – email address– phone number– text message contacts.

• Distribute the Legal Aid Society flier on our website: https://www.tnjustice.org/tenncare-redetermination/.

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Page 31: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Updating Contact Info• Fax new contact information to Tennessee Health

Connection at 1-855-315-0669. Keep the fax receipt.

OR

• Mail by certified mail, return receipt requested to: Tennessee Health Connection

P.O. Box 305240Nashville, TN 37230-5240

Keep the delivery receipt.10/21/2015

Page 32: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Updating Contact Info

• Even if enrollees don’t receive a Phase 2 notice, they will want to get a Phase 3 notice.

• Enrollees may need to show they provided updated contact information on appeal if they lose coverage in Phase 3.

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Page 33: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Step Two: Understanding the Notice

• Encourage all enrollees to carefully read all notices to the end.

• Answer enrollees’ questions on household composition and income.

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Page 34: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

How to Answer Questions – Family Size

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Page 35: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Family Changes Can Affect Eligibility

Changes to family size include:– Birth or adoption of child– Marriage, divorce, or legal separation– Death of family member– Family member no longer lives with you

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Page 36: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

How to Answer Questions – Income

(Pregnant Women, Children, Parent/Caretaker Relatives)

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Page 37: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

What Income Counts?• Alimony/child support– Alimony counts.– Child support does not count.

• Exclude government benefits based on need.– (SNAP (food stamps), Families First, SSI, housing &

energy assistance, veterans’ benefits) • Exclude gifts, inheritances, and Worker’s Comp.• In most cases, children’s Social Security

benefits do not count.10/21/2015

Page 38: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Even If Circumstances Changed, Sign & Send In the Form IF:

Countable income is below the amount specified for the family’s size in TennCare Form TN A299a that accompanies the redetermination notice.

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Page 39: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Attachment TN A299a

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Page 40: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

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Page 41: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Outreach Opportunity

Have a large number of TennCare patients or serve a large number of TennCare enrollees?

Consider telling them about redetermination.

We can help you with the message content!

If interested, please send an email to:

Rob Watkins at [email protected]

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Page 42: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

To Recap …

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Page 43: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Step 1

1. Make sure TennCare has your clients’ current contact information. Fax or mail (delivery receipt requested) the change of: – Address– phone number(s)– Emailto TN Health Connection. Keep the delivery receipt.

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Page 44: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Step 2

2. If your client does get a notice, read the notice all the way through with each individual client. Don’t assume “a dime a dozen.” Make sure you know what TennCare is asking the person to do. Then help the client comply.

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Note: The address & fax number for Phase 2 forms is different than the address & fax number for TN Health Connection. Make sure you send Phase 2 forms to the address on TN 299VR.

Page 45: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Step 33. If the enrollee:

(A) has not had a change in family size or income, OR(B) has had a change, but his income is less than the amount listed in the notice for his family size,

sign the form for each member of the family and send it in NOW. Save fax or mail receipt.

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Page 46: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Step 4

4. Consider reaching out during Phase 2 to the TennCare enrollees you serve. An ounce of prevention is worth a pound of cure.

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Page 47: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Stay tuned…

For more info in future months on what to do to help people through Phase 3.• We will post information as we get it:

https://www.tnjustice.org/tenncare-redetermination/.

• We will offer another webinar when we learn more about Phase 3.10/21/2015

Page 48: TennCare Redetermination Gordon Bonnyman, Staff Attorney Rachel Clifton, Training Coordinator/Client Advocate 10/21/2015

Thank you for joining us today!“Of all the forms of inequality, injustice in health care is the most shocking and inhumane.”

-Martin Luther King, Jr.

www.facebook.com/tnjusticewww.twitter.com/tnjusticecenter

[email protected]

10/21/2015