The Association for Community Affiliated Plans (ACAP) thanks you for providing us the opportunity to respond to your request for information on policies that can help ensure a seamless system of coverage that provides affordable and adequate health care services to children.
ACAP is an association of 58 nonprofit and community-based Safety Net Health Plans. Our member plans, located in 24 states, provide coverage to more than 12 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP), Medicare Special Needs Plans for dually-eligible individuals and Qualified Health Plans (QHPs). ACAP plans currently serve approximately one-third of Medicaid and CHIP enrollees who receive coverage through risk-based managed care. ACAP plans are members of their communities, partnering with states through good times and bad to improve the health and well-being of their members who rely upon the Medicaid and CHIP programs.
Since its bipartisan beginnings in 1997, CHIP has been an essential source of high-quality coverage for children and families whose incomes place them above the Medicaid threshold but who do not have access to employer-sponsored or private insurance. CHIP provides health insurance to over 8 million children nationwide, and has helped reduce the number of uninsured children by more than 50 percent, from 14% in 1997 to just 7% in 2012.
ACAP has a strong record of supporting the expansion of Medicaid and CHIP to ensure that lower-income Americans have access to high-value public insurance. CHIP has played a vital role for children and pregnant women in this country for nearly two decades, and its ongoing funding is crucial to ensure these gains are not lost. ACAP recognizes that it may be appropriate for some aspects of the current CHIP program to be transitioned into the health care marketplace in the future; this is not, however, the time to make such changes. As such, ACAP supports a CHIP funding extension for a minimum of four years. In addition, ACAP supports elimination of waiting periods in CHIP, as they are inconsistent with the goal of universal coverage and are fundamentally illogical in a world where all Americans are expected to easily access continuous health care coverage.
While it may ultimately make sense to move children from CHIP into other coverage options, notably the exchanges, there are multiple reasons that now is not the correct time for that transition to occur:
The marketplaces are far from mature. Many analysts expect that they will not fully stabilize until 2017, when plans are able to price using past experience and the transitional reinsurance and risk corridor programs have expired. To introduce additional uncertainty and pressure on the marketplace at this point would be problematic.
There is insufficient information about how the marketplaces would meet the health care needs of the children and pregnant women currently eligible for CHIP.
Solutions would need to be found to address the fact that, without the CHIP program, many children would become uninsured as a result of no longer having access to affordable coverage.
It is still unclear whether QHP coverage offers appropriate and adequate benefits and costsharing for the lower-income adult population covered by the marketplace, much less for children. ACAP continues to support the establishment of state-developed coverage programs, either the Basic Health Program or other reforms pursued through §1332 waivers available to states beginning in 2017, to address the financial and health care needs of these populations.
It is important to note that, by April 1, 2015, the Secretary of the U.S. Department of Health and Human Services must certify plans that are at least comparable to CHIP programs with respect to benefits and cost sharing. These certifications will provide greater insight into the appropriateness of QHP coverage for children and should address many of the coverage and affordability questions posed by MACPAC (see below). However, we firmly believe that these certifications will come too late for many states and insurers to adequately prepare for a transition away from CHIP that would begin just six months later if funding is not continued.
MACPAC has already identified areas that policymakers must address around affordability and adequacy of children’s coverage options, particularly in qualified health plans in the health insurance marketplaces, before children can be transitioned to such coverage options. The following comments respond to the specific questions posed by MACPAC to stakeholders in its November 12, 2014 letter, as well as expand on several of the comments made above.