Policy recommendations to flatten the coronavirus curve

On March 15, The Center for Community Solutions released a memo outlining steps the State of Ohio and the federal government could take to help flatten the coronavirus curve and to boost Ohio’s economy. Since then, Ohio and the federal government have adopted some of our policy suggestions. This is meant to be a status update of where actions have already been taken and where they have not yet. One caution, policies are changing rapidly so we will update this information regularly.

Policy ProposalsFlattens CurveBoosts EconomyFederal (F), State (S), Local (L)Action TakenExplanation   
HEALTH CARE
Use 1135 waiver to expand Medicaid coverage to higher income levels.XXF, SNo Action TakenImprove health care access, boost federal funds into state, reduce uncompensated care
Make COVID19 cause a “special enrollment” in Marketplace plans.XXFNo Action Taken; Federal government hasn’t yet announced a COVID19 special enrollment periodImprove health care access, boost federal funds into state, reduce uncompensated care
Suspend program participation and licensure renewal requirements for providers.XS, FNo Action TakenReduces compliance costs for health care, allows more focus on patient care
Suspend or eliminate facility requirements that inhibit maximum ability to test and screen.XS, FApproved, also allowed under 1135 waiverReduces compliance costs for health care providers, allows more focus on patient care
Allow for “license equivalency” i.e. licensed providers from other states can practice in Ohio. XS, FNot clear, telemedicine rule may allow for this, also allowed under 1135 waiver Improves health care access
Decrease or eliminate benefit limits which can inhibit social distancing (i.e. increase number of meals able to be delivered under waivers). XS, FNo Action TakenIncreases ability to social distance, boosts federal funds into state
Remove current restrictions on presumptive eligibility.XS, FNo Action TakenImprove health care access, boost federal funds into state, reduces uncompensated care
Suspend all Medicaid redeterminations.XXS FApproved Improve health care access, boost federal funds into state, reduces uncompensated care
Suspend all Medicaid prior authorizations for pharmacy, services, durable medical equipment for fee for service and managed care populations. XS, FNo Action TakenReduces compliance costs for health care, provides patients with quicker access to needed care, allows more focus on patient care
Draft Medicaid state plan amendment requesting all copays be eliminated, but especially for those services covered under the pharmacy benefit and non-emergency services obtained in a hospital or emergency room. XSNo Action TakenReduces compliance costs for health care, provides patients with quicker access to needed care
Eliminate barriers to telemedicine.XS, FApprovedProvides patients with quicker access to needed care, increases ability to social distance
Provide presumptive eligibility for justice-involved individuals.XS, FNo Action TakenProvides high-risk patients with quicker access to care, reduces uncompensated care
Allow telemedicine for justice-involved individuals.XS, FNo Action TakenProvides high-risk patients with quicker access to needed care, increases ability to social distance
Minimum Medicaid benefits should include COVID-19 testing as a mandatory lab testing benefit.XS, FNo Action TakenProvides high-risk patients with quicker access to needed care, reduces uncompensated care
Medicaid should extend these benefits to tests that do not meet the standard of having the service provided in an office or similar facility. In particular, determine if mobile health units can be deployed to provide tests, based on actionable information, and allow them to be eligible for technical fees or to be considered for a federally qualified health center payment.XXS, FNo Action TakenProvides high-risk patients with quicker access to needed care, reduces uncompensated care and increases ability to social distance
Declare any payments and eligibility determinations made during emergency ineligible for Medicaid program integrity audits for the period of the emergency.XFNo Action TakenState and local governments should be held financially harmless in any follow-up auditing or program reviews in the event that benefits, and services are provided to an ineligible person.
Suspend public charge policies for Medicaid.XFNo Action TakenPolicies that drive people away from health coverage and care will increase the risk of COVID19 infection.
Temporarily delay any state fair hearing requests and appeal deadlines.XXS, FNo Action TakenReduced administrative burden on the state and individuals applying for Medicaid
Temporary payment (reimbursement) increases to provide enhanced care, including additional nursing assistance to deal with intensive patients’ needs for Medicaid patients in long-term care nursing facilities and other institutional settings including home and community-based careXXS, FNo Action TakenImprove health care access, boost federal funds into state, and reduce uncompensated care
Create centralized website explaining Medicaid changes made due to COVID-19. Include how benefits and eligibility have changed, and copies of any documents submitted to Centers for Medicaid and Medicare Services.XSCompleted.
Click Here to Learn More
Can reduce compliance costs for health care providers, and provides patients with information on what care is available
Support additional increases to the Federal Medical Assistance percentage and include a trigger for automatic increases during national emergencies.XXFNo action taken.Improve health care access, boost federal funds into state, reduce uncompensated care
NUTRITION
Suspend all Supplemental Nutrition Assistance Program (SNAP) redeterminations, interim reports and case closures.XXS, FApproved, state received waiver extending certification periods by six months.Policies that provide SNAP benefits to all those eligible can improve health, increase social distancing and boost local economy.
Eliminate SNAP interview requirements.XXS, LState is considering postponing the interview requirement but hasn’t yet asked for federal approval.Policies that provide SNAP benefits to all those eligible can improve health, increase social distancing and boost local economy.
Accept SNAP application as self-declaration of eligibility without requiring any further documentation when electronic verification sources are not available.XXS, LState is seeking federal approval to reduce verification requirements and using expedited processingPolicies that provide SNAP benefits to all those eligible can improve health, increase social distancing and boost local economy.
Increase SNAP benefit level, and explore using EBT cards as way to deliver cash payments from federal government.XXF SApproved, states can now seek approval to issue supplemental SNAP emergency allotments to households not already receiving maximum benefitsPolicies that provide increased SNAP benefits to all those eligible can improve health and boost local economy.
Temporarily waive 200% federal poverty level (FPL) requirement for The Emergency Food Assistance Program (TEFAP)XXSNo Action TakenThis requirement makes current food distributions less efficient and safe.
Raise SNAP eligibility to 200% FPL from current level of 130% FPL. XXSNo Action TakenThis is a state option under broad-based categorical eligibility. Expansion could be limited in duration (e.g. until the economy improves). 
Ask the federal government to waive federal requirements that SNAP for Women, Infants and Children (WIC) retailers’ stock specific food products in order to be certified by the WIC programXXF SNo Action TakenPolicies that encourage continued use of WIC benefits to all those eligible can improve health and boost local economy.
Ohio should waive the physical presence requirements for WIC until the end of the emergency including deferring anthropomorphic and bloodwork requirements necessary to determine nutritional risk. XSNo Action TakenRequiring a physical presence is contrary to protecting public health.
CASH ASSISTANCE
Suspend mandatory work requirements for applicants and recipients, and do not impose any TANF sanctions or time limits during a time of emergency.XXFODJFS has requested federal permission but it has not yet been granted. Counites that are currently waiving TANF work requirements are doing so under existing “good cause” provisionsRequiring work assignments or sanctioning for failure to comply are contrary to public health.
For the purpose of establishing or maintaining eligibility, disregard any discontinued income from prior months or even if received earlier in the month.XSNo Action TakenIncome from prior months is not a good indicator of current economic status.
Consider creating a new COVID19-specific or disaster-relief specific program to provide temporary cash to familiesXS, FState has transferred additional $10 million in TANF funds into county Prevention, Retention and Contingency fundsIn the past the state has created disaster specific TANF relief programs. Implementing even time- limited COVID19-specific program could provide needed financial assistance to low-income families.
Suspend any requirement to have filed taxes in order to be eligible for unemployment compensation or cash assistance. XXFNo Action TakenRemoves a barrier to needy families who need assistance now because of changed circumstances.