The COVID-19 public health emergency (PHE), initiated on January 27, 2020, and repeatedly extended, has significantly impacted healthcare access across the United States, including Florida’s Medicaid program. This article provides an updated overview of how the PHE has influenced Medicaid eligibility, services, and access in Florida, ensuring residents are well-informed about their healthcare options during these times.
Continuous Medicaid Coverage and the Public Health Emergency
A critical provision during the PHE has been the continuous coverage requirement. Since March 2020, and throughout the extensions of the federal public health emergency, Florida, in alignment with the Families First Coronavirus Response Act, has ensured that Medicaid recipients enrolled as of March 18, 2020, would not lose their eligibility. This critical measure provides stability for individuals and families relying on Medicaid for essential healthcare services during the uncertain times of the pandemic. The only exceptions to this continuous coverage are if an individual ceases to be a Florida resident or voluntarily requests termination of their benefits. This protection was put in place to maintain healthcare coverage during the crisis, offering peace of mind to vulnerable populations.
Initially, there were concerns regarding termination notices sent out in March 2020. However, the Agency for Health Care Administration (AHCA) acted swiftly to rectify this, ensuring that benefits were reinstated for those affected, reinforcing the state’s commitment to continuous coverage throughout the PHE.
It’s important to note that while continuous coverage is in place, certain adjustments to Medicaid benefits have been permitted under federal guidelines issued in October 2020. These adjustments primarily affect optional benefits and cost-sharing, but in Florida, such changes necessitating amendments to state Medicaid law would require legislative action. As of now, the core continuous coverage provision remains a central tenet of Florida Medicaid during the PHE.
Redetermination and Recertification Processes
While Medicaid coverage has been continuous, the processes for redetermination and recertification have been reinstated. Starting October 1, 2020, the Department of Children and Families (DCF) resumed sending letters for case reviews to assess ongoing eligibility for Medicaid and Medically Needy programs. Recipients receiving these letters are urged by AHCA to take prompt action to re-apply and complete the necessary reviews to confirm their continued eligibility once the PHE concludes and normal operations resume.
In January 2021, DCF conducted automated renewals for specific populations – individuals whose sole income was Social Security and SSI and who were enrolled in SSI-related Medicaid programs. However, it is important to note that those receiving VA income were not included in this automated renewal process, highlighting the need for all recipients to be attentive to any communication from DCF regarding their case reviews.
Changes to Application Timeframes
There have been temporary changes to the timeframe for submitting documentation for Medicaid applications. For applications submitted in February 2020, an extended 120-day period was granted for submitting required documentation, with eligibility backdated to the month of application. However, this extended timeframe was rescinded effective July 1, 2021. For applications submitted on or after this date, the standard processing deadlines apply, meaning applications can be denied if verification information is not provided within 30 days. Applications submitted before July 1, 2021, retained the 120-day window. This change underscores the importance of submitting all required documentation promptly when applying for Medicaid.
Unemployment Payments and Medicaid Eligibility
The economic impact of the pandemic, including unemployment, has been considered in Medicaid eligibility determinations. Significantly, the additional $600 per week unemployment insurance payments provided under the CARES Act are not counted as income when determining Medicaid eligibility. This provision ensured that individuals receiving this critical unemployment assistance would not have it negatively impact their Medicaid eligibility, recognizing the financial hardships faced during the pandemic. It is worth noting that while these payments are excluded from Medicaid income calculations, they are considered for marketplace subsidy calculations under the Affordable Care Act (ACA).
Expanded Coverage of Medicaid Services During the State of Emergency
Florida Medicaid has broadened its service coverage during the state of emergency to address the unique healthcare needs arising from the pandemic. This expanded coverage includes:
- Comprehensive COVID-19 Services: Coverage for all medically necessary services related to COVID-19 testing and treatment.
- Service Limit Waivers: Flexibility in service limits to ensure recipients with COVID-19, or those needing to maintain their health and safety at home, receive the necessary care.
- Copayment Waivers: Elimination of copayments for all Medicaid services, removing a potential financial barrier to accessing care.
- Prescription Flexibility: Waivers on early prescription refill limits (excluding controlled substances) and coverage for 90-day supplies of maintenance prescriptions when available.
- Out-of-State Provider Reimbursement: Reimbursement for out-of-state providers offering medically necessary services to Florida Medicaid beneficiaries (provisional enrollment for out-of-state providers ended July 1, 2021).
- Fair Hearing Delays: Delays in fair hearings in specific cases where recipients continue to receive services pending the hearing outcome.
These expanded services demonstrate Florida Medicaid’s commitment to ensuring access to necessary healthcare during the public health emergency, addressing both COVID-19 specific needs and broader healthcare maintenance.
COVID-19 Vaccines for Medicaid Enrollees
Access to COVID-19 vaccines has been a priority, and Florida Medicaid enrollees are fully included in the vaccine distribution efforts. Following Governor DeSantis’ executive orders in March 2021, vaccine eligibility expanded to lower age groups and eventually to all Floridians. Medicaid enrollees can find vaccine locations and schedule appointments through myvaccine.fl.gov.
Recognizing transportation as a potential barrier, Florida Medicaid provides transportation assistance to vaccine appointments at no cost to enrollees. Individuals need to schedule their vaccine appointment and then contact their Medicaid plan to arrange transportation. For those not enrolled in a plan, the Medicaid Helpline (1-877-254-1055) can provide information on transportation services. Furthermore, for homebound seniors, a dedicated email system ([email protected]) was launched to bring vaccines directly to them, ensuring even the most vulnerable populations have access.
Behavioral Health Services and Telemedicine
Recognizing the increased need for mental health and substance use disorder services, AHCA has loosened coverage restrictions for behavioral health services. From May 5, 2020, prior authorization requirements for mental health or substance use disorder treatment were waived, and service limitations were lifted. For behavioral analysis services, existing authorizations were extended. While service limits and prior authorization requirements have been reinstated as of July 2021, the temporary waivers significantly expanded access to crucial behavioral health support during a stressful period. Additionally, telemedicine for well-child visits for children older than 24 months has been reimbursed during the state of emergency, ensuring continuity of care while minimizing in-person contact.
Home and Community-Based Services (HCBS) Waivers
For individuals relying on Home and Community-Based Services (HCBS) waivers, including Long Term Care and Developmental Disabilities programs, Florida obtained federal approval for program modifications effective retroactively from January 27, 2020, to January 26, 2021. These changes included:
- Virtual evaluations and assessments.
- Lifting service limits to address health and welfare needs.
- Adjusting service prior authorization requirements.
- Expanding settings for service provision.
- Payments for support services in hospitals or short-term institutional settings.
- Visitor restrictions in residential settings to minimize infection spread.
These adjustments ensured continued access to essential HCBS services while adapting to the constraints of the public health emergency.
Resources for the Uninsured
It is important to note that while Florida Medicaid has expanded coverage for its enrollees, the state has not opted for 100% federal funding for COVID-19 testing, treatment, and vaccines for the uninsured. This means uninsured Floridians must rely on a network of resources, including county health departments and federally qualified health centers, for free testing. AHCA advises uninsured individuals to inquire about costs before testing at any site and provides links to testing site locators. Information on free treatment options for the uninsured can be found through resources like Florida Health Justice.
Residency Proof and Vaccine Access
In a significant policy change, Florida has eased residency requirements at some vaccine sites. A public health advisory issued in April 2021 specifies that vaccines are available to anyone “present in Florida for the purpose of providing goods or services for the benefits of residents and visitors of the State of Florida,” in addition to Florida residents. This change broadened vaccine access, particularly for migrant populations and those temporarily in Florida.
ACA Marketplace and Unemployment Benefits for Health Insurance
Finally, for those who experienced unemployment in 2021, the ACA marketplace offered a special enrollment period with enhanced subsidies through the American Rescue Plan. Individuals who received or were approved for unemployment compensation in 2021 could access free or reduced-cost health insurance plans through the ACA marketplace until August 15, 2021. This initiative provided another avenue for healthcare access for those impacted by unemployment during the pandemic.
In Conclusion
The COVID-19 public health emergency has brought significant changes to Florida Medicaid, primarily focused on maintaining continuous coverage, expanding access to COVID-19 related services, and adapting service delivery through measures like telemedicine and HCBS waivers. While certain temporary expansions and waivers have evolved or been reinstated, the core commitment to providing healthcare access for vulnerable Floridians through Medicaid during the PHE remains steadfast. For the most up-to-date information and any changes, it is always recommended to consult official sources like AHCA and DCF websites.
