A recent proposal by the federal government could lead to increased fraud in the Medicaid program. Alaska Policy Forum submitted comments to the Centers for Medicare & Medicaid Services about this harmful proposal. Read more about the proposal here, and read our comments below.
To: CENTERS FOR MEDICARE&MEDICAID SERVICES (CMS)
Document Type: Proposed Rule
Title: Streamlining the Medicaid, Children’s Health Insurance Program, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Processes
Document ID: CMS-2022-0134-0002
This proposed rule would be very detrimental to the state of Alaska, and in particular, to those who have the most need for health care coverage under Medicaid and CHIP. Medicaid in Alaska has grown substantially since it was expanded by executive order. It is now covering well over 30% of our state’s population. As a result, it is seriously straining the capacity for serving the poor and disabled for whom the program was originally designed. The soundness of our state Medicaid and CHIP programs is essential to ensure they can continue to be effective, and this rule puts that in jeopardy.
Alaska is already in a position whereby more periodic and stringent audits of Medicaid and CHIP recipient lists is required. This proposal would do the opposite, by reducing the integrity of the enrollment process. It would require our state, through coercion, to enroll potential beneficiaries without important and essential substantiation of their qualification for the program.
The sustainability of these programs must be paramount, but the rule puts the programs at risk, and thus endangers those who have the most need. The peril of adding non-qualified individuals to the program by fast-tracking their enrollment will inevitably lead to fraud and waste, which is already rampant in the Medicaid program. Rather than attempting to force states to enroll individuals without proper verification of qualification, CMS should focus on cleaning up the existing waste and fraud.
The fiscal implications of the proposed rule are jarring: Alaska cannot afford to absorb the fiscal impact that CMS estimates would occur under this proposal. It’s not realistic to expect our state to bear the estimated costs at the same time that the federal government is preventing it from developing our resources that would bring needed revenue. In summary, this rule is very ill-considered, and we would recommend not moving forward with the proposal.