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Questions and Answers on HIP 2.0, Direct from FSSA

GNIAHU member Brian Liechty recently sent some questions to FSSA regarding the Healthy Indiana Plan.  We thought that other ISAHU Members would find this information useful.  If you have other HIP questions, you can submit them to FSSA online: http://www.in.gov/fssa/hip/2331.htm

Q1:  APTC determination on the FFM is made primarily on “estimated income” for 2015.  Based on available information, it appears HIP does not use exactly the same determining factors.  How should people plan ahead using these disparate measures? 

HIP uses Modified Adjusted Gross Income (MAGI) standards put in place with the Affordable Care Act. Income must be verified through the State’s electronic databases or through paper documentation provided by the client. Income is determined on a monthly basis. The State does not use electronic IRS data to verify income as the State believes the IRS income information is not timely and only captures income annually.

Q2:  What criteria was used to send the letters to current Marketplace enrollees?  I know personally of people whose income ranged from zero to nearly 300% who have received them, yet others who I know are <150% have not.

Q2 addendum:  If someone at, say, 110% FPL has a Marketplace policy, is received tax credit help, but does not receive a letter . . . how will that be handled next year at tax time?  If they would be penalized, whose responsibility is this?

The State sent letters to current Marketplace enrollees based on the information that was given to the state by the Marketplace. The State would have no other way to gather this information. As you know individuals under 138% receiving tax credits may be forced to pay those back however this will be a determination made by the federal government, not the State.

Q3:  If someone gets the letter, but KNOWS that they will not be eligible for HIP, are they still required to subject themselves to the re-determination process?  What happens if they don’t?  I know of one whose initial estimates were about 125% FPL but will most probably get a raise to about 150% FPL—way too small to bother with the arcane redetermination process prescribed under ACA rules, but he has a letter.  Can he just ignore it?

If an individual is certain they are not eligible for HIP, than they should maintain their coverage on the Marketplace. Please note that the State will verify income monthly and thus will make a much more accurate determination of eligibility based on income than the marketplace.

Q4:  In the documentation, it says for current FFM enrollees to update incomes on the Marketplace & to continue with their Marketplace plan until they hear from HIP.  Assuming that they are found eligible for HIP, will HIP be retroactively activated on 2/1?  If so, will the FFM plan be automatically canceled and they’ll be reimbursed for the contributions they’ve made to the current plan? And will any claims automatically reprocessed?  And the current FFM insurance company billings balanced with the changes?

HIP does not include any retroactivity. Individuals will become eligible the first of the month in which they make their initial POWER account contribution. The State is required to make a determination of other possible categories of Medicaid in the three retroactive months.

Q5:  Let’s say someone reasonably EXPECTS their income to be, say, 200% of FPL for the year, and enrolls in an FFM plan based on that expectation . . . then at tax time discovers an income at, say, 110% FPL.  What will happen? 

This is a question for the Marketplace. At that point in time when they realize they are at 110% FPL we would encourage the member to apply for HIP. For Medicaid, including HIP, the State needs to know the verified income, not an expected income or estimate.

Q6:  What happens to someone who mid-year loses their job:  Their YTD income puts them above HIP eligibility, but their now-current income is close to zero.  Since annual income is the determinant, with they enroll HIP or FFM for this year? 

An individual with zero income would be encouraged to enroll in HIP. They would need to take the appropriate actions for their Marketplace plan that the Marketplace plan requires. The State does not use annual income but converts all income into a monthly amount and determines eligibility on a monthly basis.  If income is lost or gained, then the individual would be required to report and verify that change and the change would be applied to “redetermine” the individual’s eligibility.

Q7:  Once enrolled in HIP, can someone expect that to remain stable until Dec 31—regardless of income or situational changes?

If an individual begins earning income over 138% FPL they will no longer be eligible for HIP. See #6

Q8:  Will HIP accept any and all determinations from Marketplace as valid?  Or will there be additional criteria post-FFM that may affect a successful HIP enrollment?

Marketplace enrollment is not HIP enrollment. Individuals will need to be found eligible for HIP by the State’s Division of Family Resources and will need to make their POWER account contribution to be enrolled in HIP Plus. If they are under 100% FPL, and do not make their POWER account contribution, they will be defaulted to HIP Basic and be required to make copayments for services received at the Point of Service. The marketplace only makes an “assessment” of eligibility for the State for Medicaid eligibility purposes, not a determination.

Q9:  Are income/family size the only determinants for eligibility?  Let’s say a person is enrolled in their company’s health plan.  Although available, they cannot afford to enroll their spouse.  Their total family income falls within HIP income guidelines.  Can that spouse enroll in HIP?  Could the employee waive the ER plan and enroll too?

Income and family size are two determinants for eligibility. They must be Hoosier resident, cannot be a Medicare recipient, etc. For additional information regarding eligibility for the program please refer to HIP.in.gov.

Having separate insurance or access to other health coverage is not a barrier to eligibility.

Q10:  Since medical is no longer an issue, why are there a number of medical questions on the HIP application forms?

Part of the HIP program includes a category called “Medically Frail”. These are individuals that may need additional health services. Individuals found to be “medically” frail will receive the same benefits as those in the traditional Medicaid program.  The questions on the application will not preclude eligibility to HIP but may determine if an individual is entitled to additional benefits.

Q11:  What happens to someone who does not enroll in FFM before 2/15 because they think they’ll be in HIP and then is turned down for HIP.  Is this an SEP for FFM?

The State is not capable of making policy determinations for the FFM. However, the Federal Government recently announced an additional SEP during tax season. If they are discontinued for HIP, there will be a special enrollment period but not if they are denied (never had coverage and the application is denied).

Q12:  Does someone enrolling in HIP mid-year have a full-year account deposit and a full-year deductible even though covered for only part of the year?

The individual begins a 12 month benefit period once they become eligible. Is not based on calendar years.

Q13:  Can someone stay in HIP if they get a new job with benefits?

Yes if they remain eligible. A new job with benefits does not solely prevent HIP eligibility. The new job and new income amount must be reported and verified.  If the individuals exceeds the income limit, the individual will be discontinued from HIP.

Q14:  The FFM requests for self-employed income have nearly no connection to the real world:  In particular, self-employed people do not know from one month to another what their income is, or will be, or even if they will make a profit or loss.  Yet that is the measure FFM wishes reported.  How does HIP test/record/estimate expect incomes to be estimated for self-employed persons?

Q14 Addendum:  Does HIP use only “provable” income, and if so, by what measure is it proven?

All income must be verified and the income will be converted to a monthly amount based on “current income”.  If an individual is self-employed, the most current federal tax return may be used for verification of income that amount does not differ significantly from the current income.  Also, business records can be supplied if that information is more up to date and more accurate than the most recent federal tax return.  Annual self-employment income is converted to a monthly amount.

Q15:  Will agents ever be “officially” part of this process, where we can be paid and help our people?

This policy decision is currently under consideration by the State.

Q16:  For someone new to the system completely, is the “method of choice” that they enroll through the Marketplace and simply let Marketplace handle the process completely? 

If an individual believes they are eligible for HIP coverage they should complete and Indiana Application for Health Coverage through the Division of Family Resources.  Please refer to the website at: https://www.ifcem.com/CitizenPortal/application.do. To apply for the Marketplace they must be do so during an enrollment period as you know.

Q17:  Will whatever the rules are right now be stable going forward?  One of the worst disasters created by ACA is the constantly moving regulations.  People can adapt and use most anything, but not if it’s unstable and unpredictable—then they learn not to trust it.

That is the intent.

Q18: Is there a requirement for how long an individual must live in the State of Indiana before they are able to apply for HIP?

Once an individual has moved to the state of Indiana they can immediately apply for assistance in the state of Indiana whether it be medical coverage (HIP) or food assistance.  The individual would first need to file an application.  This can be done in the local office or online at www/in.gov/fssa.  Once the application is filed an interview will be scheduled if necessary.  At the interview the individual would be pended for all necessary verifications.  If no interview is necessary a mailer would be mailed out requesting all necessary verifications.  Once verifications are turned in and processed the individual would either be determined eligible or non-eligible.  If determined eligible the case would be authorized.  For HIP, the case would be authorized for conditional status.  HIP would then require a power account payment be made before the coverage becomes active.  If the power account payment is made immediately the individual could possibly be eligible for health coverage in the same month that the application was filed.

There is no time frame on how long someone needs to be in the state of Indiana before applying for and receiving benefits.  The only thing that could potentially delay an individual from receiving benefits in the state of Indiana is if their benefits from another state have not yet closed out.

Healthy Indiana Plan
Office of Medicaid Policy & Planning
Family & Social Services Administration
402 W. Washington Street, W374
Indianapolis, IN 46204-2739

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Indiana State Association of Health Underwriters

Indiana State Association of Health Underwriters