In response to COVID-19, the Families First Coronavirus Response Act (FFCRA) was authorized in in March 2020.  This resulted in an increase in available matching funds for states.  As a condition of receipt of this increase, states are not permitted to discontinue Medicaid coverage for individuals enrolled in the program on March 18, 2020, or who become enrolled during the emergency period, unless the individual voluntarily requests a discontinuance of eligibility, is no longer a resident of the state, or is deceased.  States are also not permitted to reduce benefits for any individual enrolled in Medicaid on or after March 18, 2020 through the end of the month in which the emergency period ends.  This continuous coverage requirement is in effect through the end of the month in which the public health emergency ends.

In April, the Ohio Department of Medicaid (ODM) issued a Medicaid Eligibility Procedure Letter (MEPL) to all Ohio counties, including Cuyahoga County Job and Family Services (CJFS), providing guidance for how to comply with the conditions of the FFCRA and ensure that individuals in receipt of Medicaid retain coverage during the public health emergency by taking the following actions:

• Suspending the processing of all Medicaid renewals and redeterminations as these actions could result in the discontinuance of coverage for beneficiaries;
• Processing Medicaid renewals for individuals whose coverage was discontinued prior to March 18, 2020, and who have submitted renewals during the 90-day reinstatement;
• Processing only those changes in circumstances that individuals are required to report. All other changes will not be processed;
• Processing alerts that result in positive changes to an individual’s coverage; and
• Exploring presumptive eligibility (PE) in circumstances where an individual has provided enough information for PE determination, but not a full determination of Medicaid eligibility.

The order also resulted in CJFS taking the following actions for individuals who are unable to obtain or submit verification of eligibility criteria:

• Processing pending and newly submitted Medicaid applications using the self-declared statements of the individual as verification of all eligibility criteria except for citizenship and immigration status;
• Using electronic data sources including the Federal Data Services Hub, the Asset Verification System (AVS), The Work Number, and others, to confirm applicable eligibility criteria; and
• Independent verification of these self-declared statements is not required.

On May 27, 2020, ODM issued another MEPL instructing CJFS to begin processing eligibility renewals, redeterminations, and the processing of certain changes in circumstances, including the processing of alerts effective May 28, 2020.  However, the limitations on discontinuances and reductions in benefits as described in the original order remained in place.  Medicaid could only be discontinued for individuals who were deceased, no longer a resident of Ohio, or who requested a voluntary discontinuance of eligibility to ensure that individuals in receipt of Medicaid retain coverage during the public health emergency.  The new order also maintained the relaxed verification requirements and allowed self-attestation for all eligibility requirements except for citizenship and immigration status.

Finally, On November 30, 2020, ODM issued another MEPL instructing CJFS to continue processing eligibility renewals, redeterminations, and the processing of certain changes in circumstances, including the processing of alerts and maintained the limitations on discontinuances.  However, the limitations on reduction in benefits was changed and as of December 1, 2020 certain reduction in benefits were made permissible through the end of the month in which the public health emergency ends.  The MEPL maintained that Medicaid could only be discontinued for individuals who were deceased, no longer a resident of Ohio, or who requested a voluntary discontinuance of eligibility to ensure that individuals in receipt of Medicaid retain coverage during the public health emergency. 

DJFS has experienced a 9.86% increase in Medicaid enrollment from March 2020 through December 2020 due to the orders detailed above.  As of December 31, 2020, 33.63% of Cuyahoga County residents were enrolled in Medicaid.  Through Medicaid enrollment, DJFS continues to ensure citizens of Cuyahoga County have access to health care during this health emergency.