ALTCS Members Need to Prepare for the End of the Public Health Emergency (PHE) – April 1, 2023

Due to a provision in the December omnibus spending plan, the Public Health Emergency (PHE) that went into effect in March 2020, which prevented states from terminating Medicaid benefits- including Long Term Care- expired on April 1, 2023.  What does this mean for persons receiving Arizona Long Term Care System (ALTCS) benefits? This means that as the PHE unwinds Arizona Health Care Cost Containment System (AHCCCS) will go back to regular operations.

When the PHE unwinds, all States must complete a full renewal or, in limited circumstances redetermine eligibility based on a change in circumstances.  States will be allowed and in some cases are mandated to process eligibility “renewals” ex parte by accessing electronic data sources and other information available to the state in order to determine if a beneficiary’s financial eligibility can be successfully renewed without contacting the beneficiary. In Arizona, if AHCCCS cannot auto-renew a member’s coverage using available and approved data sources, the member will receive a renewal packet by mail or a notification by email, depending on their selected preference. AHCCCS health plans will also use texts, email, and social media when available to reach members.

On January 4, 2023, AHCCCS published notice confirming that it will complete a full eligibility renewal for all 2.4 million enrolled members over the course of 12 months, beginning April 1, 2023. Members will be notified of their eligibility renewal prior to their month of renewal. This will represent the first time in three years the Medicaid and CHIP members will go through the renewal process.

All Medicaid recipients must be notified before their benefits are terminated.  States must attempt to ensure that it has up-to-date contact information using the National Change of Address Database Maintained by the United State Postal Service, other public program information, or other reliable sources of contact information. Additionally, the state may not disenroll anyone based upon returned mail until the state has made a good faith effort to contact the individual using more than one communication mode (e.g., mail, phone, text, email).

Preparation Tips:

1. It is imperative that all Medicaid recipients make sure that AHCCCS has their current contact information. AHCCCS members should verify their contact information is correct online with Health-e-Arizona Plus (healthearizonaplus.gov) or by calling 1-855-432-7587, Monday through Friday 7:00 a.m. – 6:00 p.m.
2. AHCCCS recipients must respond to all AHCCCS communication in a timely manner.
3. All Medicaid recipients should know their specific financial eligibility criteria and be in compliance immediately.
4. Anyone who is concerned that their ALTCS benefits could be terminated should consult with an experienced elder law attorney well before termination of the PHE to obtain legal advice in order meet financial eligibility criteria to avoid or minimize termination of ALTCS benefits.
5. Anyone who receives a Request for Information as part of the post-PHE unwinding process and needs help in responding or receives a Notice of Termination of benefits should immediately contact an experienced elder law attorney as there are prescribed time limits for response and/or appeal.

Like everything else with the Covid-19 pandemic, this is all new. The expiration of the continuous coverage requirement authorized by the Families First Coronavirus Response Act (FFCRA) presents the single largest health coverage transition event since the first open enrollment period of the Affordable Care Act.  We expect many families will have questions and want to ensure their loved one will continue to be eligible for vital Arizona Long Term Care System (ALTCS) benefits.

We are here to help. Call our office at 480-922-1010 or email info@bivenslaw.com to schedule your consultation today.

-Stephanie A. Bivens, Esq., CELA