TennCare
Redetermination
Gordon Bonnyman, Staff Attorney
Rachel Clifton, Training Coordinator/Client Advocate
10/21/2015
Agenda
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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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What the law requires
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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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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.
TennCare Rule 1200-13-13-.01
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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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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.
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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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Background
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TennCare Redeterminations have
been delayed for up to 3 years.
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Process
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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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Three Phases
• Phase 1: SNAP Match
• Phase 2: Confirmation Mailing
• Phase 3: Renewal Packet
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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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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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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 1
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Page 2
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Attachment
TN A299a
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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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Phase 3
MAJOR 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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Challenges in Completing
Phase 2
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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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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/americaa-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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Enrollees May Not Understand the
Notice
The notice is ambiguous.
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Intro Is Vague & Potentially Misleading
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Enrollees May Miss the Punchline
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Threat of Jail May Deter Enrollees
from Taking Needed Action
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How to Help
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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/tenncareredetermination/.
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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 305240
Nashville, TN 37230-5240
Keep the delivery receipt.
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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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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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How to Answer Questions –
Family Size
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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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How to Answer Questions –
Income
(Pregnant Women, Children,
Parent/Caretaker Relatives)
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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.
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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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Attachment
TN A299a
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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 rwatkins@tnjustice.org
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To Recap …
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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)
– Email
to TN Health Connection. Keep the delivery receipt.
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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.
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.
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Step 3
3. 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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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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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/tenncareredetermination/.
• We will offer another webinar when we learn
more about Phase 3.
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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.
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10/21/2015