Memo To: Interested Parties From: Dr. Lisa Dubay, Johns Hopkins and Center for Children & Families Jocelyn Guyer, Center for Children and Families Michael Odeh, Center for Children and Families Subject: Availability of Federal SCHIP Funding for an SCHIP Expansion to 250% of the Federal Poverty Level in South Carolina Date: February 15, 2008 Overview This memo provides an estimate of the cost of operating an SCHIP program in South Carolina that covers children up to 250 percent of the federal poverty level (FPL) (instead of up to 200 percent of the FPL, as is currently planned). It also assesses whether the state’s federal SCHIP matching funds are adequate to cover the federal cost of such an expansion. The analysis concludes that due to federal SCHIP funding surpluses that South Carolina has built up over the years, the state has abundant federal matching funds with which to operate an SCHIP program up to 250 percent of the FPL. Specifically, in fiscal year 20091, South Carolina can expect to have some $168 million in federal SCHIP matching funds available to it. In comparison, an upper-bound estimate of the cost of operating an SCHIP program to 250 percent of the FPL is $138 million. In other words, South Carolina can expect to have significantly more federal funding in fiscal year 2009 than it needs to operate a program to 250 percent of the FPL. Currently, Congress has extended the SCHIP program through March of 2009 (although it has provided funding for all of fiscal year 2009). The history of congressional action on SCHIP strongly suggests that the program will successfully be extended beyond March of 2009, and with the level of funding that South Carolina and other states need to sustain their SCHIP programs for children. In the decade-long history of SCHIP, Congress has never failed to provide states with the federal matching funds that they need to continue operating their SCHIP programs for children, including in states that have expanded eligibility levels well beyond what South Carolina is considering. 1. Estimating the Cost of Expanding SCHIP to 250% FPL To estimate the cost of operating an SCHIP program in South Carolina to 250 percent of the FPL, this analysis considers the cost of updating the existing SCHIP program (i.e., coverage to 150 percent of the FPL) to reflect inflation and greater take up rates among already-eligible children in the future. It also looks at the likely cost of the state’s Unless otherwise specified, this memo uses “fiscal year” to refer to the federal fiscal year, which runs from October 1st of a year to September 30th of the following year. 1 planned expansion to 200 percent of the FPL and of a further expansion to 250 percent of the FPL. To do so, it examines the number and health insurance status of children in South Carolina with family income between 150 percent and 250 percent of the FPL; applies assumptions about the share of children in this income range that would likely participate in coverage if an expansion were adopted; and multiplies the number of children expected to secure coverage by the estimated per capita cost of serving such children. In conducting the analysis, we relied on the following data sources and assumptions, drawing on extant literature when available. Distribution of Coverage Among Children To determine the number and health insurance status of children between 150 percent and 250 percent of the FPL, the analysis relies on data from the Census Bureau’s 2005-2007 March Current Population Surveys (CPS), representing information on calendar years 2004-2006. Because of the small number of observations at the state level in any one year of CPS data, the analysis pools data across three years to increase the reliability of the estimates. The analysis follows the practice of the Congressional Budget Office in assuming that CPS data on insurance status reflects people’s coverage at a “point in time,” not their coverage over the course of the preceding 12 months. Since no detailed information is available in the CPS on immigration status, the analysis does not take into account that some children in this income range cannot qualify for SCHIP because of their immigration status. This is one reason that the estimate, if anything, overstates the cost of an expansion. Appendix 1 presents the distribution of insurance coverage by income group using the CPS. Unfortunately, cell sizes are small for the uninsured in the relevant income groups and more confidence is placed in the estimates that pool the 150 to 250 percent of the FPL group. In addition, there are a number of individuals with family incomes in the 150 percent of the FPL to 250 of the FPL range who report already having Medicaid or SCHIP coverage even though eligibility for SCHIP currently ends at 150 percent of the FPL (with limited exceptions for children with disabilities). We assume that the significant number of already-covered children between 150 percent to 250 percent of the FPL largely reflects measurement error due to 1) differences between how Medicaid/SCHIP rules define a family (and, thus, the family’s income) versus the Census Bureau’s rules; 2) individuals’ errors in the reporting of their income; and 3) individuals reporting coverage that they no longer receive and for which they are no longer eligible. For our primary analysis, we assume that the cost of these “already-covered” children are embedded in the baseline costs of the current SCHIP program. However, we also conduct a sensitivity analysis that assumes that one quarter of the cost of these “alreadycovered” children would reflect new enrollment in SCHIP under an expansion to 250 percent of the FPL. Assumptions of Take-up and Crowd Out To estimate the number of children in the newly eligible group who would enroll under the SCHIP expansion, we assume that 15 percent of children with private non-group 2 coverage, 10 percent of children with CHAMPUS or employer-sponsored coverage, and 66 percent of the uninsured will enroll. In addition, we assume that outreach efforts associated with an expansion to 250 percent of the FPL will also encourage additional enrollment of children already eligible for SCHIP (i.e., those with income between Medicaid eligibility levels and 150 percent of the FPL). To address this issue in our estimates, we assume that the same shares of already eligible SCHIP children with private non-group coverage, with CHAMPUS or employer-sponsored coverage, or who are uninsured will enroll as those newly eligible. Including this “woodwork effect” in the analysis is another reason that, if anything, it produces an upper-bound estimate of the cost of operating a program to 250 percent of the FPL. Per Capita Cost of Enrolling Children in SCHIP To estimate the annual per capita cost of enrolling children in SCHIP, data on the per child per month SCHIP program cost in fiscal year 2006 were obtained from the Centers for Medicare and Medicaid Services (CMS) and adjusted for health inflation (as measured by CMS’s projections of per capita growth in national health expenditures2) to reflect FY 2009 dollars. Annual per child costs in FY 2009 are estimated to be $1,840. With South Carolina’s SCHIP matching rate of 79 percent, this translates into a per capita cost of $1,455 for the federal government and $386 for the state. Estimating Baseline Costs of the SCHIP Program Data on federal spending in South Carolina for FY 2004-2006 are used to estimate baseline federal spending under SCHIP. Using the methodology for inflating costs mentioned above, a three-year average of costs inflated to 2009 dollars was estimated. Specifically, in FY 2009 we estimate that the baseline costs of the SCHIP program would be $66.3 million if no expansion were implemented. We opted to average the cost of the program over these three years because the state experienced a sharp drop off in enrollment and spending in 2007 that may not be representative of the future of the program. The reasons for the drop off are unclear, but it may be due to the impact of a new federally-mandated requirement for applicants to document their citizenship status using a paperwork-intensive set of procedures that can cause eligible children to miss out on coverage. If the citizenship documentation requirement continues to depress enrollment and cause spending to remain at or near the 2007 level, the cost of operating a program to 250 percent of the FPL will be lower than presented here. Cost Estimates for Expanding Coverage up to 250 percent of the FPL for FY 2009 Based on the methods and assumptions described above, we estimate that 19,623 children in the 150 to 200 percent of the FPL group and 18,103 children in the 200 to 250 percent of the FPL group would enroll in SCHIP if the state operated a program to 250 percent of the FPL. In addition, we assume that an expansion to 250 percent of the FPL would increase enrollment among already-eligible children by 11,824. In total, 49,550 children 2 See http://www.cms.hhs.gov/NationalHealthExpendData/downloads/proj2006.pdf 3 would gain SCHIP coverage. The total, federal and state cost estimates can be found in Table 1. Table 1: Upper Bound Estimated Cost of Expanding SCHIP to 250% FPL, FY2009 Total Cost ($1,000s) Number Federal Cost ($1,000s) State Cost ($1,000) Increased Take-up Among Already SCHIP Eligible 11824 $21,756 $17,204 $4,564 150-199% FPL 19623 $36,107 $28,552 $7,575 200-249% FPL 18103 $33,310 $26,340 $6,988 TOTAL 49550 $91,173 $72,096 $19,126 Specifically, total costs associated with an expansion between 150 and 199 percent of the FPL are $36.1 million, with federal costs of $28.5 million and state costs of $7.6 million. Covering children with incomes from 200 to 249 percent of the FPL would cost $33.3 million in total, with $26.3 coming from the federal government and $7.0 million coming from the state. In addition, we estimate the total costs of the “spillover effect” to be $21.8 million with a federal share of $17.2 million and a state share of $4.6 million. Expanding coverage for children with incomes between 150 and 250 percent of the FPL would therefore cost $91.2 million in total with $72.1 million attributable to the federal government and $19.1 million attributable to the state. When baseline SCHIP costs of $66.3 million are considered (i.e., the cost of operating the current program to 150 percent of the FPL in fiscal year 2009), estimated SCHIP spending would be $138.4 million. Note that $138.4 million should be considered an upper bound estimate for a number of reasons, including: 1) it assumes that the cost of operating the state’s existing SCHIP program to 150 percent of the FPL will largely revert to the higher levels in place before 2007; 2) it additionally assumes significant new take up among uninsured children already eligible for SCHIP with income up to 150 percent of the FPL; 3) it does not exclude undocumented children from the analysis for data reasons even though they clearly will not be eligible for or allowed to enroll in SCHIP; 4) and it assumes that the state is able to achieve fully-phased in enrollment levels of the first day of fiscal year 2009 when, in practice, enrollment can be expected to phase up over time. Sensitivity Analysis We also conducted a sensitivity analysis that assumed that a quarter of the individuals in the 150 to 250 percent of FPL range who currently report Medicaid or SCHIP coverage but do not appear to be eligible would be new SCHIP enrollees. These estimates put federal costs at $156 million in fiscal year 2009 for a program that covers children to 250 percent of the FPL. 4 2. Available Federal Funding Fiscal Year 2008 After it became clear that Congress would not conduct a full reauthorization of SCHIP in 2007, it, instead, extended the existing SCHIP program through the first half of fiscal year 2009 (i.e., through March of 2009) and added significant new funding for the program to sustain it through that point. As a result of this recent congressional action, CMS reports that South Carolina will have $193.5 million in federal SCHIP funds available to it in fiscal year 2008, including $122.5 million in unspent funds from its fiscal year 2006 and 2007 allotments and $71 million in a new allotment for fiscal year 2008. (Note that states have three years in which to spend their annual SCHIP allotments before unspent funds are sent to other states. South Carolina, for example, can use its fiscal year 2006 allotment in fiscal year 2006, 2007, and 2008.) Fiscal Year 2009 In fiscal year 2009, South Carolina will receive an additional allotment and can also draw on unspent funds from earlier years. To estimate the unspent funds or “surplus” from earlier years available for FY 2009, we must first make assumptions about spending in FY 2008. We assume that the expansion up to 250 percent of the FPL is in place for six months in FY 2008 at fully implemented levels of enrollment; which is an optimistic assessment. Under this scenario, we would expect FY 2008 spending to have been $96 million including $62.3 million in baseline costs and $33.7 million in expansion costs.3 If, as estimated above, South Carolina requires federal SCHIP matching funds of some $96 million to operate an SCHIP program up to 250 percent of the FPL in fiscal year 2008, it will continue to have an enormous “surplus” of unspent funds from earlier years when entering fiscal year 2009. Specifically, it can anticipating having a “surplus” of unspent funds from earlier years of $97.5 million. In fiscal year 2009, South Carolina also will receive an additional, estimated $71 million in federal SCHIP matching funds from the federal government. Thus, in total, the state can expect to have some $168.5 million in federal SCHIP matching funds available for fiscal year 2009. Although it is unlikely to be relevant to South Carolina given its large surplus of federal SCHIP matching funds, Congress has set aside special “supplemental” SCHIP funding for fiscal year 2008 and fiscal year 2009. This supplemental funding allows CMS to distribute additional allotments to states whose need for funds would otherwise exceed their available resources. If, for some reason, South Carolina were to find itself in need of more resources, the supplemental allotments represent a potential “safety valve” for the state. Beyond Fiscal Year 2009 3 This is likely an overestimate of the costs of the new expansion as take-up among those made newly eligible is unlikely to be immediate. 5 The future of SCHIP beyond March of 2009 will be determined by Congress later this year, or, in early 2009. Given the remarkable success of the program and the fact that Congress has stepped in each and every time that states have needed more resources to sustain their SCHIP programs for children, it can be assumed that it will do so again. There is close to zero chance that the program will not be extended beyond March of 2009, and it is highly likely that Congress will continue its pattern of providing states with the level of federal matching dollars that are needed to allow them to continue operating and strengthening their existing SCHIP programs for children. Conclusion This analysis suggests that South Carolina has more than enough SCHIP funding to proceed with its expansion of coverage to 200 percent of the FPL this year, as well as more than enough to expand coverage to 250 percent of the FPL in fiscal year 2009. Specifically, for fiscal year 2009, South Carolina can expect to have some $168 million in federal SCHIP matching funds available to it. In comparison, the analysis suggests that, at most, some $138 million in federal SCHIP matching funds would be needed to operate a program that covers children to 250 percent of the FPL. In other words, South Carolina is estimated to have significantly more federal matching SCHIP funds than would be required to cover children up to 250 percent of the FPL in fiscal year 2009. For now, the SCHIP program is slated to expire in March of 2009. However, the history of congressional action on SCHIP strongly suggests that the program will be extended beyond the first half of 2009 and with the level of funding that South Carolina and other states need to continue their SCHIP programs for children as in effect when congressional action is taken. 6 Appendix 1: Distribution of Insurance Coverage for South Carolina Children, 18 and Under , 2004-2006 Other Private 0-149% FPL 150-199% FPL 200-249% FPL 250+% FPL Total 16,871 7,008 10,506 24,204 58,589 Medicare 3,912 834 1,404 0 6,150 CHAMPUS 657 6,253 4,453 7,554 18,917 Employersponsored 48,140 47,388 63,305 385,125 543,958 Medicaid/SCHIP Source: Center for Children and Families analysis of March 2005-2007 Current Population Survey. 7 235,619 49,723 24,676 32,157 342,175 Uninsured 43,258 20,012 14,775 27,773 105,818 Total 348,457 131,218 119,119 476,813 1,075,607