Coverage-for-Immigrants-Under-HCR-10-22-13-V2

Report
COVERAGE FOR
IMMIGRANTS UNDER
HEALTH CARE REFORM
October 22, 2013
County Welfare Directors Association of California
•
Cathy Senderling-McDonald
Los Angeles County
•
Isabelle Maggio
California Pan-Ethnic Health Network
•
Ellen Wu
OVERVIEW OF TRAINING
• Glossary of Terms
• Immigrant Categories
• Undocumented Immigrants
• Eligibility and Verification Systems
2
GLOSSARY OF TERMS
• Utilize the glossary (Attachment I)
to become familiarized with
terms used throughout this
presentation.
• Make the glossary a part of your
individual trainings and provide
as a desk reference.
• Add additional terms that will
assist staff as you implement
training in your counties.
3
QUICK NOTE
For the purpose of this presentation, you will hear us use:
• The federal term “Lawfully Present”, when referring to Federal
rules and the rules used by Covered California.
Note: For a complete list of “Lawfully Present” individuals
under the Affordable Care Act (ACA), please refer to
Attachment II.
• The state term “Qualified Immigrants”, when referring to
Medi-Cal.
Note: “Lawfully Present” describes a broader category
that includes “Qualified Immigrants”.
4
IMMIGRATION
CATEGORIES
Lawful Permanent Residents
Permanent Residence Under Color of Law
Refugee Medical Assistance
Undocumented Immigrants
Immigrants with Temporary Status
5
IMMIGRANT POPULATIONS ELIGIBLE TO FULL-SCOPE MEDI-CAL
Lawful Permanent Residents (LPRs)
Permanent Residence Under Color of Law (PRUCOL)
Asylees
Refugees
Cuban and Haitian Entrants
Certain Battered Spouses and Children
Victims of Trafficking
Individuals Granted Conditional Entry
Individuals Granted Witholding of Deportation/Removal
Individuals Paroled into the U.S. for at Least One Year
6
ELIGIBLE NON-CITIZENS UNDER 5 YEARS
• Current Federal regulations establish a “5 year bar” for lawfully
present immigrants in order to be eligible for Federal Medicaid.
• However, in California, qualified immigrants who have not satisfied
the “5 year bar” are eligible to receive state-only full-scope
Medi-Cal.
• The state-only programs have been transparent to county staff,
because there have never been separate aid codes to identify this
population.
• With the implementation of Health Care Reform (HCR), the state has
decided to continue with the same methodology, i.e., no separate
aid codes for this group.
7
PERMANENT RESIDENCE UNDER COLOR OF LAW
Permanent Residence Under
Color of Law (PRUCOL):
• Immigrants who are PRUCOL are eligible
for full-scope Medi-Cal as long as they
are otherwise eligible.
• Under PRUCOL category #16 of
question 5 of the MC 13, the immigrant
is declaring that federal immigration
authorities are aware of the immigrant’s
presence, but do not plan to remove
him or her from the country.
• The Deferred Action for Childhood
Arrivals (DACA), is PRUCOL category#12
found under question 5 of the MC 13.
• Medi-Cal benefits for immigrants who
are PRUCOL will not change with the
implementation of Health Care Reform.
8
MEDI-CAL ELIGIBILITY
• The following qualified immigrants and PRUCOLs are eligible for full-scope
Medi-Cal benefits:
 Individuals up to 21 years of age
 Pregnant women with income up to 60% of the Federal Poverty Level (FPL)
 Children in families with income up to 266% of the FPL
 Parents, seniors, and persons with disabilities
• Qualified immigrants who are pregnant with income above 60% and up to
213% of the FPL are eligible for pregnancy-only Medi-Cal.
 Depending on reported income, pregnant individuals may also be eligible
to full-scope Medi-Cal benefits with a Share-of-Cost (SOC) and/or an
Advanced Premium Tax Credit (APTC) through the Exchange, in addition
to pregnancy related services.
• Medi-Cal expansion covers eligible immigrants who are childless adults with
income up to 138% of the FPL.
• As with all applicants, Medi-Cal expansion eliminates the linkage, deprivation,
and assets requirements. It requires that qualified immigrants only meet the
income and state residency requirements.
9
ELIGIBILITY FOR THE LAWFULLY PRESENT IMMIGRANT
As of January 2014, the following will apply to lawfully present
immigrants:
• Subject to the individual mandate and related tax penalty.
• May enroll in a health plan from the state insurance
exchange.
• Eligible for premium tax credits and subsidies.
• No waiting periods for enrolling in state insurance exchanges
or premium tax credits.
10
REFUGEE MEDICAL ASSISTANCE
Refugee Medical Assistance (RMA) Program
• The RMA Program will continue as usual until, December
31, 2013:
The RMA Program will sunset.
State Department of Health Care Services (DHCS) to
issue instructions.
• Immigrants who would have been eligible to benefits
under the RMA program will become part of the new
Medicaid Expansion population – MAGI Medi-Cal –
beginning January 2014.
11
UNDOCUMENTED IMMIGRANTS
• Undocumented immigrants include non-citizens without a lawful
immigration status.
• Undocumented immigrants who meet all other program requirements
for Medi-Cal will be eligible to receive restricted/limited scope benefits.
 Undocumented immigrant childless adults will be included in the
MAGI Medicaid Expansion population for restricted benefits.
 Undocumented immigrant children will be eligible for
restricted-scope benefits via the coverage groups that exist for
children’s coverage under the Affordable Care Act, including but
not limited to the general children’s coverage group. Please refer
to the aid code chart (Attachment III) to see the programs that
will have restricted-scope aid codes associated with them.
12
UNDOCUMENTED IMMIGRANTS
Medi-Cal for undocumented immigrants:
• Not eligible for Medicare or full-scope Medi-Cal.
• If all eligibility requirements are met, undocumented immigrants will
continue to receive:
 Emergency-related services.
 Pregnancy-related services:
 Prenatal care.
 Labor and delivery.
 Up to 60 days of post-partum care.
 Family planning services.
 State funded Long-Term Care (LTC).
• May seek non-emergency health services at community health centers or
safety-net hospitals.
• For aid code information, refer to Attachment III.
13
UNDOCUMENTED IMMIGRANTS
APTC and Health Benefit Exchange coverage for undocumented
immigrants:
• Exempt from the individual mandate.
• Not allowed to purchase private health insurance through the
state insurance exchange(s), even if paying full cost.
• Not eligible for premium tax credits or subsidies.
Citizen or lawfully present children of undocumented
parent may be eligible (see next slide regarding mixed
households).
14
MIXED IMMIGRATION STATUS HOUSEHOLDS
Undocumented parents of citizen or lawfully present
children are eligible:
• To purchase from the state insurance exchange on
behalf of their children, but not for themselves.
• For premium tax credits and subsidies on behalf of their
children, but not for themselves, if they file taxes.
Citizen or lawfully present children of undocumented
parents are eligible:
• For full-scope Medi-Cal, if otherwise eligible.
15
IMMIGRANTS WITH TEMPORARY STATUS
• Individuals with temporary visas or those who do not
intend to stay permanently in the United States,
such as foreign visitors and students, are not
typically eligible, unless they can establish that they
intend to permanently reside in the state, and
meet all other eligibility requirements.
• If eligible to Medi-Cal, they receive the same
restricted-scope benefits as undocumented
individuals.
16
ELIGIBILITY AND
VERIFICATION SYSTEMS
CalHEERS
Systematic Alien Verification for
Entitlement (SAVE)
17
DETERMINING ELIGIBILITY IN CalHEERS
• CalHEERS is programmed to determine eligibility for
each individual regardless of citizenship status.
It is imperative that Eligibility Workers enter
accurate information in CalHEERS to assign the
correct program and aid code.
• The Notice of Action sent to customers will inform
them of their approval to MAGI Medi-Cal with either
limited-scope or restricted-scope benefits.
18
SYSTEMATIC ALIEN VERIFICATION FOR ENTITLEMENT
Systematic Alien Verification for Entitlement (SAVE) use:
• During the Pre-Enrollment period from October to December 2013, cases entered directly
into CalHEERS will have citizenship and immigration status information reported by the
customer verified against the Federal Data Hub.
 The United States Department of Homeland Security will be one of the entities
providing information to the Federal Data Hub.
 If a discrepancy occurs, staff will need to request verification of the lawfully present
status. If secondary verification is required, counties are to use the same process as
used today by sending a G-845 to USCIS and following-up accordingly once a
response is received.
 Benefits are not to be delayed pending this secondary verification process.
Per existing Medi-Cal regulations, if acceptable evidence of lawful
permanent residence is provided by the applicant,
full-scope benefits are to be issued while the G-845 is pending with USCIS.
• Once the SAWS and CalHEERS interface is implemented, counties will process SAVE
documents in the same manner they do today in SAWS. Note: if secondary verification is
instituted when the case is processed in CalHEERS, this process does not need to be
completed again in SAWS if a new SAVE is generated due to the case migration.
19
ADDITIONAL
INFORMATION
Pending Future Guidance
20
PENDING FUTURE GUIDANCE
• Wrap Around Program:
 A Wrap Around Program is being established by the Department of
Health Care Services (DHCS) and Covered California for qualified
immigrants who are childless adults (21 years of age and older), under
the “5 year bar," earning up to 138% of the FPL.
 This program will allow these adults to enroll in coverage in Covered
California with APTC applied towards their premium. DHCS will
provide payments to reduce the premium and out-of-pocket
expenses to zero.
 DHCS will also provide these adults benefits that are available in
Medi-Cal, but not included in Covered California.
 Details of the program policy are still in development.
 The program is expected to be implemented no earlier than
April 2014.
21
PENDING FUTURE GUIDANCE
• MC 13 for Medi-Cal:
At this time, counties are to continue using the
MC 13 for customers requesting Medi-Cal
consistent with current requirements.
Future guidance has been requested for the
use of the MC 13 for customers requesting
Medi-Cal later, and all customers after
January 01, 2014.
DHCS is currently reviewing the requirement.
22
QUESTIONS?
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