Dive Brief:
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CMS' process for periodic data matching (PDM) has uncovered consumers who are enrolled with both Medicaid or CHIP coverage, as well as a federal marketplace plan with tax credits or cost-sharing reductions. The issue only affects states using the federal marketplace, not state-based exchanges.
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As a result, the agency has mailed letters to those Medicaid consumers, directing them to cancel their marketplace plan and repay the credit they received to help pay for the plan.
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A notice from CMS does not indicate how many consumers are affected, but a CMS spokeswoman described it to Modern Healthcare as “a small number.”
Dive Insight:
The situation reveals an issue with the way consumers can inadvertently end up enrolled in both forms of coverage, and places the burden to resolve it on individuals who may not understand it.
“The CMS letter may lead to considerable confusion,” Kip Piper, a consultant and former CMS official, told Modern Healthcare. “Many people will not understand what they need to do. Low income families tend to move often, so many addresses may be inaccurate.”
Adding to the confusion is numerous states put their own brand on Medicaid and CHIP programs, so many of those enrolled may not understand that the CMS letter applies to them.
The issue of dual enrollment typically arises when an ACA-insured individual then qualifies for Medicaid or CHIP, and they don't know to terminate their marketplace coverage, CMS says.
Additional complicating factors are low-income families frequently have fluctuations in income that impact what options they qualify for. They may not understand their reponsibility to report these changes, experts tell Modern Healthcare.