Author: Whitney Griggs
Background: In 2019, Georgia submitted a plan to the Centers Medicare and Medicaid Services (CMS) to expand Medicaid to a certain subset of Georgians. Under the plan, called the Georgia Pathways waiver, the state planned to allow individuals aged 19-64 making up to 100% of the federal poverty line (FPL) ($12,880 for an individual and $17,420 for a family of 2) to apply for Medicaid coverage. The Georgia Pathways plan also required these newly eligible adults to complete and document 80 hours of work or other “qualifying activities” each month to enroll in and maintain coverage. The plan further required some enrollees (those making 50-100% FPL) to pay a monthly premium to maintain their coverage, which is not required for traditional Medicaid.
In late 2020, the Trump Administration approved the Georgia Pathways plan and implementation was slated for the following July. In spring 2021, the Biden Administration changed the status of Georgia’s plan from “approved” to “pending” and stated they needed to review the plan, specifically the work and premium requirements, to ensure they were in keeping with the spirit, goals, and intent of the Medicaid program. You can learn more about the Georgia Pathways program and the approval timeline here.
On December 23rd, 2021, CMS approved the Georgia Pathways plan and will allow Georgia to extend Medicaid coverage to Georgians making up to the poverty line (or 100% FPL). However, CMS denied the state’s request to include work requirements and premium payments as a condition of enrolling in and maintaining Medicaid coverage. CMS cited concerns about the devastating impact the COVID-19 pandemic has had on both the health and economic security of Georgians as the reason for denying these provisions.
Now that CMS has issued its decision, Governor Kemp and the Georgia legislature must decide how to proceed, choosing one of these four options:
- Do nothing. Even though CMS approved a modified version of the Georgia Pathways waiver, Georgia is under no obligation to implement it. This action would mean the coverage gap remains in place and vulnerable low-income Georgians would largely remain uninsured.
- Appeal CMS’s decision on the work and premium requirements. On Jan. 22, 2022, Gov. Kemp initiated an appeal beginning a lengthy process with CMS (a process made even slower by the pandemic). While the state pursues the appeal, thousands of Georgians will remain without coverage. State leaders can move forward with the following two options even while the appeal is in process.
- Move forward with the Georgia Pathways plan as approved. Under this option, Georgians making less than 100% FPL would be eligible for Medicaid. An estimated 269,000 uninsured Georgians would gain coverage. This plan would cost the state 2.5 times more to implement than the following option.
- Expand Medicaid to cover more people at a lower cost. Under a full Medicaid expansion, individuals and families making up to (138% FPL) would be eligible for coverage. As many as 500,000 Georgians would be covered and the state would qualify for a 90% cost match from the federal government. Georgia would save millions of dollars annually over the Pathways waiver and earn a $1.3 billion bonus in the first two years.
With CMS’s approval of the Georgia Pathways program, the state is at a crossroads. Our state leaders can choose to meet the pressing health care needs of the state through Medicaid expansion, or they can choose to help fewer Georgians at a higher cost under the Pathways program.
Our state leaders cannot and should not choose to do nothing because Georgians can’t wait. Too many Georgians are without health coverage and the positive effects that come with coverage. It is far past time to act and the onus lies with our state leaders to decide the way forward. Click HERE to take action!
Reposted from Georgians for a Healthy Future: https://healthyfuturega.org/2021/06/16/cms-requests-more-information-about-georgias-proposed-changes-to-private-insurance/
On June 3rd, 2021, the Centers for Medicaid and Medicare Services (CMS) sent a letter to Governor Kemp requesting additional data on the potential impacts of the Georgia Access Model. The Georgia Access Model was put forward by Kemp in his 1332 private insurance waiver, and the model would end access to healthcare.gov for Georgia consumers.
CMS is requesting additional data from the state because they believe recent changes made by President Biden’s administration to the Affordable Care Act’s health insurance marketplace have made the state’s previous analysis outdated or inaccurate. The Biden administration’s changes include:
- The COVID Special Enrollment Period (SEP)—through August 15, 2021, almost any American who does not have health insurance through their job can enroll in health coverage at healthcare.gov or by phone at 1-800-318-2596;
- More generous and expanded eligibility for Premium Tax Credits (PTCs)—almost anyone who qualifies for coverage through the ACA is now eligible for a discount on their monthly premium; and
- Increased funding for outreach and marketing for the ACA marketplace and enrollment opportunities.
These actions have led to more Americans, and Georgians, enrolling in Marketplace coverage. In addition, CMS believes that ACA enrollment would likely remain higher through 2023, when the Georgia Access Model is slated to begin.
In the letter, CMS also reasons the increase in enrollment could change insurance market dynamics enough to reduce the private sector’s incentive to enroll consumers. CMS believes with fewer uninsured people to enroll, the private sector may be less motivated to reach uninsured individuals. The idea that the private sector will be incentivized to enroll consumers once the competition of healthcare.gov is gone is a crucial assumption of Kemp’s waiver.
Georgia must now respond with updated data that takes into account the new federal changes. The new data will allow CMS to ensure the Georgia Access Model meets the protections specified in Section 1332 of the Affordable Care Act. These protections are:
- Coverage must be at least as comprehensive as Marketplace coverage;
- Coverage and protections against high costs must be as affordable as Marketplace coverage;
- A similar number of people must have coverage under the waiver as without it; and
- The waiver can’t add to the federal deficit.
The state may also request to adjust the Georgia Access Model, as needed, to meet waiver requirements in light of the new federal policies.
Once Georgia submits the new data about the Georgia Access Model, Georgia consumers, health advocates, and other stakeholders will have a chance to comment on the proposal again. CMS announced in their letter that they will hold a 30-day comment period after they receive Georgia’s new data. GHF expects the comment period will begin in early July. We will be working with our Cover Georgia partners to help Georgia individuals, organizations, and advocates comment. Stay tuned for your opportunity to weigh in again!