Health Highlights

Achieving Continuity of Insurance Coverage for Lower-Income New Yorkers in 2014

Authors: Patricia M. Boozang | Alice J. Lam

On the heels of Governor Cuomo’s Executive Order establishing a New York Health Insurance Exchange, a new report prepared by Manatt Health Solutions for the Coalition of New York State Public Health Plans with the support of the New York State Health Foundation, recommends strategies for New York to maximize coverage continuity for low-income New Yorkers with the implementation of its exchange.

The Patient Protection and Affordable Care Act (ACA) provides new or expanded affordable coverage options to New Yorkers with incomes below 400% of the Federal Poverty Level. These coverage options, “Insurance Affordability Programs” (IAPs), include Medicaid, the Children’s Health Insurance Program (CHIP, which in New York State is called Child Health Plus or CHPlus), advance payments of premium tax credits and cost-sharing reductions, and a Basic Health Program (BHP), should the State establish one. In 2014 consumers will be connected to these programs through a streamlined, standardized, consumer-oriented, and technology-enabled eligibility process available through its Medicaid/CHIP programs and new Health Benefit Exchange.

After creating an exchange and designing a new eligibility determination system, New York will face the task of enrolling its residents in the affordable coverage option for which they are eligible. In addition, New York faces a major secondary challenge: preventing interruptions of enrollment or coverage as incomes fluctuate (and, thus, eligibility for IAPs potentially changes).

Prepared through the support of the New York State Health Foundation, the report, authored by Patricia Boozang and Alice Lam, explores the challenges New York State policymakers will confront as they seek to implement healthcare reform in a manner that maximizes continuity of insurance coverage for lower-income New Yorkers. Income fluctuation among lower-income families is well documented, and these fluctuations can cause changes in eligibility and result in significant loss of coverage due to existing administrative barriers. The policy brief analyzes these variations, examines barriers to coverage continuity and offers recommendations to minimize coverage losses when changes in eligibility do occur. 

Some of the key recommendations in the policy brief include:

IAP Eligibility and Enrollment Rules. To address misalignment in eligibility and enrollment rules across the public market (Medicaid/CHIP) and private market programs, the State can design an income reporting and verification system that accounts for predictable changes at initial application and can maintain 12-month continuous coverage for adults and children in Medicaid/CHPlus.

Plan Participation in Medicaid Managed Care (MMC) and the Exchange. To align plan participation in the public and private markets for lower-income New Yorkers, the State can further assess and design a New York State BHP and address Prepaid Health Services Plan licensure, tax-exemption and accreditation issues.

Covered Benefits and Provider Networks in Medicaid and Qualified Health Plans (QHP). As covered benefits and provider networks may differ across New York’s IAPs in 2014, the State can ensure benefit and network alignment by completing the study on benefit standardization in Q2 2012 and evaluating QHP certification and MMC contracting strategies to drive provider network alignment.

Administration of MMC and QHP Products. Recognizing that administrative practices of the exchange, MMC program and health plans offering MMC and QHP products will have implications for the continuity of coverage as consumers’ eligibility changes, the State can avoid potential barriers by creating a health plan shopping functionality to serve consumers across all IAPs and provide targeted decision support for lower-income families, as well as centralize premium billing through New York’s exchange.

New York State has made clear that continuity of care is an essential goal of its coverage strategy as it plans for implementation of the Medicaid expansion, its exchange and ACA eligibility and enrollment requirements. The recommendations in the policy brief demonstrate that the State has many tools at its disposal to achieve these objectives.

The full report is available on the New York State Health Foundation Web site.

This report is the latest addition to Manatt Health Solutions’ growing library of thought leadership relating to the opportunities and challenges that exist for states in implementing federal healthcare reform and addressing issues relating to cost, quality and access to care.



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