PEDIATRICS Vol. 104 No. 2
August 1999,
pp. 344-347
AMERICAN ACADEMY OF PEDIATRICS:
Medicaid Policy Statement
Committee on Child Health Financing
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ABSTRACT |
This policy statement replaces the 1994 Medicaid
Policy Statement. The new policy statement incorporates federal
legislative changes and policy recommendations related to eligibility,
outreach and enrollment, Medicaid managed care, covered benefits,
access to pediatric care, and quality improvement plans.
The American Academy of Pediatrics (AAP) recognizes the
achievements of the Medicaid program's improvement of access to health care services for low-income newborns, infants, children, adolescents, and young adults, hereinafter referred to as children. In fiscal year
1996, Medicaid insured almost 30% of children nationwide younger than
21 years (approximately 23 million children.)1 This policy
statement includes a brief summary of new federal legislative changes
and policy recommendations related to eligibility, outreach and
enrollment, Medicaid managed care, covered benefits, access to
pediatric care, and quality improvement plans.
Because states are able to expand Medicaid coverage under the State
Children's Health Insurance Program (SCHIP) (Title XXI of the Social
Security Act), a major provision of the Balanced Budget Act of 1997, the proportion of children eligible for Medicaid is likely to increase.
In addition, the outreach and enrollment efforts that accompany SCHIP
are likely to increase the number of eligible children enrolled in
Medicaid. Title XXI of the Social Security Act will make more than $40
billion in federal grants available to states during the next 10 years
to provide uninsured children with health insurance coverage, including
Medicaid. Although Title XXI does not create universal coverage, the
program offers an unprecedented opportunity to expand insurance to a
large portion of uninsured children. A companion AAP statement on Title
XXI is available that addresses Medicaid and non-Medicaid approaches for extending health insurance to SCHIP-eligible
children.2
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ELIGIBILITY |
Provisions in the Balanced Budget Act of 1997 (Public Law 105-33)
allow states to expand Medicaid eligibility with an enhanced federal
match. The Balanced Budget Act of 1997 restores Medicaid to persons who
lost the entitlement after the passage of the Personal Responsibility
and Work Opportunity Reconciliation Act of 1996 (Public Law
104-193) and also grants states greater flexibility when determining
eligibility.
The AAP recommends that states implement the following Medicaid
eligibility expansions and provisions to ensure enrollment of all
children eligible for Medicaid under federal legislation. States
should:
- Immediately extend Medicaid coverage, if they have not
already done so, to all children at or below the federal poverty level who are younger than 19 years to take advantage of the enhanced federal
match offered under Title XXI.
- Ensure that Medicaid-eligible children who lose cash benefits
under the Supplement Security Income (SSI) program as a result of
welfare reform remain enrolled in Medicaid.
- Eliminate asset testing to determine Medicaid eligibility.
- Guarantee 12 months of continuous Medicaid eligibility for
children younger than 19 years.
- Adopt presumptive Medicaid eligibility options for children
younger than 19 years, similar to the option available for pregnant women.
- Ensure that a redetermination of eligibility be made before
disenrolling any children from Medicaid because of changes in their
eligibility for cash assistance under the Temporary Assistance for
Needy Families (TANF) program.
- Ensure that children who are removed from their homes by the
state are immediately enrolled in Medicaid.
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OUTREACH AND ENROLLMENT |
Since Medicaid was delinked from welfare during the mid-1980s,
children have benefited from major eligibility expansions. However,
children's participation in Medicaid is unacceptably low for a variety
of reasons. Enrolling Medicaid-eligible uninsured and underinsured
children is a major priority of the AAP. The AAP estimates that in
1997, approximately 4.5 million uninsured children were eligible for
Medicaid but were not enrolled. Another 4.6 million privately insured
children also were eligible for Medicaid as a supplement to their
private insurance but not enrolled.3 Because
employer-sponsored private coverage for low-wage workers often has gaps
in benefits and high cost-sharing obligations, enrolling these children
in Medicaid would reduce underinsurance for millions of children of
low-wage workers.
Federal and state regulatory and administrative procedures must be
reoriented to make optimal outreach and enrollment a high priority for
states. Ironically, state eligibility procedures have been shaped by
federal rules that penalize states for enrolling ineligible
beneficiaries but are silent about the millions of eligible
beneficiaries who are not enrolled. Pediatricians, other health care
professionals, and child advocates can assist state Medicaid agencies
to provide outreach to families whose children are uninsured or
underinsured. The following steps should be taken to strengthen
national, state, and community outreach and enrollment efforts:
- Federal legislation should be enacted that creates state
enrollment targets and rewards states for exceeding target levels. If
states do not respond to these incentives, penalties should be
considered for consistent substandard performance.
- New outreach efforts should be initiated to reach children who
are potentially eligible for Medicaid but not enrolled, including but
not limited to:
- legal immigrants;
- those who lost welfare or SSI eligibility as a result of the Personal
Responsibility and Work Opportunity Reconciliation Act of 1996, but who
may still qualify for Medicaid benefits;
- SCHIP-eligible children whose family income has changed; and
- underinsured children.
3. State Medicaid agencies should be encouraged to accept
mail-in and phone-in applications.
4. States should expand the use of alternative enrollment sites,
including health care centers, child care centers, Head Start programs,
Special Supplemental Nutrition Program for Women, Infants, and Children
(WIC), schools, child care resources and referral agencies, and
religious centers.
5. States should expand the use of electronic information systems
(eg, fax for documentation and electronic application forms).
6. New eligibility determination for TANF should be linked to
Medicaid so children in families deemed eligible for TANF will be
enrolled automatically in Medicaid.
7. States should coordinate Medicaid and SCHIP outreach and
enrollment, including the use of common application forms. Forms should
be short and written in language that is manageable to the average
Medicaid applicant.
8. Federal policy should be established to prevent denial of
citizenship attributable to prior receipt of Medicaid and all other
health care-related services.
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MEDICAID MANAGED CARE |
States are increasingly turning to managed care in the hope of
curtailing rising health care costs, increasing Medicaid
beneficiaries' access to health care services, enhancing the
coordination of services, and improving the continuum of care. The
following are precautions that states must take to ensure that Medicaid
managed care initiatives meet the health care needs of Medicaid
beneficiaries:
- At the time of Medicaid enrollment, if applicable, families
should receive easily understood information about their choices of
managed care plans, primary care physicians, and voluntary enrollment
of children with special health care needs. Also, they should receive
education on how managed care arrangements work, including the
importance of primary and preventive care and the need to obtain most
health services directly from or by referrals from their primary care
pediatricians (PCPs). Educational materials for families should be
culturally sensitive aimed at appropriate literacy levels and available
in languages used by Medicaid recipients in each state.
- States should ensure that every effort is made for
Medicaid beneficiaries to make an informed choice when choosing a
managed care plan. Such efforts should include the use of face-to-face counselors. When participants do not choose and must be assigned to a
plan, the criteria used to assign them should include current and
previous relationships with primary care and specialty clinicians, location of clinicians, assignment of other family or household members, choices by other members in the service area, and capacity of
managed care organizations to provide special care or services appropriate for the participants. Pediatricians should be considered primary care practitioners in all default enrollment systems and state-based enrollment broker options. Random assignment, without such
criteria, should not be allowed. In addition, states should allow
individuals to switch plans with reasonable cause at any time.
- States should implement special planning and oversight of the
use of managed care for children with special health care needs and all
children who are TANF-, SSI-, or foster care-eligible. This can include
examination of benefit specifications for specialty or chronic care
services, composition of pediatric provider networks, policies for
flexible service authorization, quality performance measures for
children with various types of chronic conditions, family
participation, innovative plan practices, pediatric risk adjustment
mechanisms, and other financial incentives for high quality care.
- State Medicaid agencies should select managed care plans
based on the plan's ability and/or demonstrated readiness to provide evidence that Medicaid beneficiaries have received quality
cost-effective care that meets expected process and outcome goals.
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COVERED BENEFITS |
Through the Early and Periodic Screening, Diagnosis, and Treatment
(EPSDT) program, states are required to offer the full scope of
mandatory and optional Medicaid benefits to children. Given the
comprehensiveness of Medicaid's benefits for children and the
financial incentives inherent in managed care to restrain the use of
specialty or high-cost services, it is critical to ensure that plans
and health professionals fully understand the benefits they are
responsible to provide under Medicaid. The following recommendations
are intended to help ensure that children enrolled in Medicaid receive
all their entitled benefits:
- The full scope of pediatric Medicaid benefits distinct from
those for adults, including EPSDT, should be clearly specified in all
managed care contracts. The EPSDT benefit should include developmental
assessment, anticipatory guidance, vision and hearing testing,
behavioral health assessment, and age-appropriate laboratory tests, as
well as all diagnostic and treatment services that are medically
necessary to follow-up on a condition identified during a screening
visit.
- The EPSDT expanded benefit policies in combination with
other mandatory and optional benefits should cover, at a minimum, the
benefits outlined in the AAP's policy statement "Scope of Health
Care Benefits for Newborns, Infants, Children, Adolescents, and Young
Adults Through Age 21 Years."4
- The EPSDT periodicity schedule should be consistent with
the AAP's periodicity schedule "Recommendations for Preventive
Pediatric Health Care."5
- The EPSDT services should be provided by a pediatric PCP
who serves as the child's medical home.
- State Medicaid agencies and the Health Care Financing
Administration should closely monitor access, treatment, and provision of Medicaid benefits, especially expanded coverage of diagnostic and
treatment services under EPSDT.
- Pediatric medical necessity definitions, consistent with
EPSDT policy, should be included in all Medicaid managed care
contracts. When making any determination about the medical necessity of
any item or service to be provided to a person 0 through 21 years of
age, state Medicaid agencies and managed care plans should consider
whether an item or service: 1) is appropriate for the age and health
status of the person; 2) will prevent or ameliorate the effects of a
condition, illness, injury, or disability; 3) will aid the overall
physical and mental growth and development of the person; 4) will
assist to achieve or maintain maximum functional capacity for
performing daily activities; and 5) relies on medical practice
guidelines that are endorsed or approved by appropriate medical
professional societies or governmental public health
agencies.6
- States should inform families about Medicaid benefits not
included in managed care plan contracts and how to access these carved-out services. Although these services may not be the
responsibility of managed care plans, they are still entitlements of
the Medicaid program.
- States that have received or are considering section
1115a demonstration waivers should
maintain all Medicaid benefits for children 0 through 21 years.
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ACCESS TO PEDIATRIC SERVICES |
Increasingly, Medicaid beneficiaries are required to enroll in
capitated managed care plans, including children who are eligible under
foster care and SSI categories. Ensuring a smooth transition into
managed care is a major concern of the AAP, particularly in the light
of stringent utilization review
procedures.b The following
recommendations are intended to encourage access to appropriate
pediatric care:
- To comply with the Omnibus Budget Reconciliation Act of
1989, all states must set reimbursement rates at a level "sufficient to enlist enough providers so that care and services are available under the plan at least to the extent that such care and services are
available to the general population in the geographic
area."7 Strong evidence demonstrates that adequate
reimbursement is a prerequisite for states to comply with federal law.
- All forms of Medicaid reimbursement (eg, capitation,
fee-for-service) should be structured to ensure that pediatric services and procedures are available to Medicaid beneficiaries at least to the
extent that such services are available to the general population in
the same geographic area.
- Medicaid reimbursement, including capitation arrangements, must
account for advances in pediatric care, such as, but not limited to,
new vaccines and new technologies. Adjustments to capitation rates
reflecting these medical advances should be included in all state
managed care contracts.
- Medicaid physician fees for pediatric care should be at least
90% of the usual, customary, or reasonable rates or equivalent to those in Medicare, whichever is higher.
- The AAP supports the concept and use of the Medicare
Resource-based Relative Value Scale (RBRVS) physician fee
schedule as the basis for physician reimbursement. However, the AAP
recognizes that the current and proposed methods of implementation
still contain inequities as they pertain to pediatrics. A process to modify the Resource-based Relative Value Scale physician fee
schedule for children should be initiated. In particular, a system for the ongoing evaluation of expenses for practice overhead, including expenses specific to pediatrics, must be implemented, and universal adoption of a single conversion factor by payers is
mandatory.8
- If state Medicaid agencies adopt a capitated system, that
system should be adjusted for case-mix differences based on age, modifiers for children with special health care needs, outlier risk-adjusted methods, more rate cells/groups, a pediatric
diagnostic classification system, or a combination of these. Because
pediatric risk-adjustment techniques are not well-developed, contract
provisions about carved-out services, outlier payment, reinsurance or
shared-risk arrangements for individual children and aggregate plan
loss or profits should be included.
- State Medicaid agencies should explore innovative methods to
establish trust funds to support graduate medical education relevant to
the provision of care for Medicaid participants and the assurance of a
qualified pediatric workforce.
- The choice of health care clinicians for children must include
pediatricians, to the extent that they are available. Efforts should be
made by state Medicaid agencies and managed care plans to maintain
established relationships of children with their general and specialty
pediatricians to avoid disruptions in the continuity of care.
- The provider network of any managed care plan should
include sufficient numbers of appropriately trained and board-eligible or board-certified providers of pediatric care, including primary, medical subspecialty, and surgical specialty pediatric care. These physicians should be accessible or available by referral from the PCP
to provide medically necessary services without restraint from the
managed care organization. In addition, pediatric providers of
health-related services should include children's mental health services, social work services, developmental evaluation services, occupational therapy services, physical therapy services, speech therapy and language services, school-linked clinic services, and other
public health services.
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QUALITY IMPROVEMENT PLANS |
State Medicaid agencies are required to have quality
improvement plans for managed care organizations. Most of these
requirements address preventive and primary care. Few focus on
specialty care or children with special health care needs. The
following recommendations are directed at ways to enhance the
development and use of comprehensive pediatric quality care measures:
- Quality improvement plans should include the following:
pediatricians in its development, appropriate peer review with
pediatric cases reviewed by pediatricians, provider credentialing,
random reviews, medical record reviews, focused studies, pediatrician participation in quality improvement committees, and reporting and
analysis of health outcome measures.
- State Medicaid agencies, in consultation with representatives
of their respective AAP chapter, should develop appropriate procedures
to oversee and ensure the quality of preventive, primary, acute, and
chronic care provided to all children served in state-approved managed
care plans.
- State Medicaid agencies should work with all plans and all
forms of Medicaid funding to ensure uniform EPSDT and other pediatric service reporting that imposes a minimum paperwork burden on providers, as well as peer review of EPSDT services for utilization and quality by
persons specifically trained and practicing in pediatrics. Educational
and nonpunitive programs should be implemented to ensure effective and
uniform EPSDT. Other pediatric service reporting and payment should be
contingent on substantial compliance with graduated quality review
processes to ensure completion of all categories of screening as
required by the state's Medicaid plan.
- Quality performance measures for all children should include
compliance with the AAP's preventive care and immunization standards and other current pediatric AAP practice parameters.
- Special performance measures for all children should be
adopted, including measures related to risk assessment, early
identification, provider capacity and organization (including the use
of multidisciplinary teams), specialty referrals, service utilization,
care coordination, family satisfaction, and health and functional
outcomes.
- States should incorporate Consumer Assessment of Health
Plans survey questions, especially questions for parents of
children with special health care needs.
- States should monitor enrollment patterns and reasons for
enrollment changes to ensure that managed care organizations do not
encourage "high-cost" persons to switch to other plans or do not
underserve Medicaid beneficiaries.
- Plans should create incentives to promote the early
identification of children with special health care needs to provide
ongoing links between care coordinators and PCPs.
- State Medicaid agencies should implement comprehensive
administrative review processes to ensure that managed care
organizations are prepared to serve children and reimburse providers
before Medicaid managed care programs are implemented on annual
contract renewals.
COMMITTEE ON CHILD HEALTH FINANCING, 1998-1999
Richard P. Nelson, MD, Chairperson
Jeffrey Brown, MD, MPH
John S. Curran, MD
Neal Halfon, MD, MPH
Beverly L. Koops, MD
Thomas K. McInerny, MD
John R. Meurer, MD, MM
Maria E. Minon, MD
Jean A. Wright, MD, MBA
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FOOTNOTES |
The recommendations in this statement do not indicate an exclusive course of treatment or serve as a standard of medical care. Variations, taking into account individual circumstances, may be appropriate.
a
Section 1115 of the Social Security Act
allows states to waive compliance with any provision of Medicaid, in
addition to other federal programs authorized by the Act, for any
experimental, pilot, or demonstration project that would promote the
objectives of the Medicaid program.
b
Certain groups of children with special health
care needs, however, are now exempt from mandatory enrollment if they
reside in states that are not operating 1115 or 1915(b) waiver
programs. These are children younger than 19 years who are eligible for SSI, children with special health care needs eligible for Maternal and
Children Health (Title V) services, children who are eligible under the
Katie Beckett option, and children receiving foster care otherwise in
an out-of-home placement.
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ABBREVIATIONS |
AAP, American Academy of Pediatrics;
SCHIP, State
Children's Health Insurance Program;
SSI, Supplement Security Income
program;
TANF, Temporary Assistance for Needy Families program;
PCP, primary care pediatrician;
EPSDT, Early and Periodic Screening,
Diagnosis, and Treatment program.
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REFERENCES |
-
American Academy of Pediatrics. Medicaid State Reports
Fiscal Year 1996. Elk Grove Village, IL: American Academy of Pediatrics; 1998 -
American Academy of Pediatrics, Committee on Child Health Financing
Implementation principles and strategies for Title XXI (State Children's Health Insurance Program).
Pediatrics
1998;
101:944-948 [Abstract/Free Full Text]
-
American Academy of Pediatrics, Division of Health Policy Research. Analysis of March 1998 Current Population Survey
-
American Academy of Pediatrics, Committee on Child Health Financing
Scope of health care benefits for newborns, infants, children, adolescents, and young adults through age 21 years.
Pediatrics.
1997;
100:1040-1041 [Abstract/Free Full Text]
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American Academy of Pediatrics, Committee on Practice and Ambulatory Medicine
Recommendations for preventive pediatric health care.
Pediatrics.
1995;
96:373-374 [Abstract/Free Full Text]
-
Berman S
A pediatric perspective on medical necessity. Arch
Pediatr Adolesc Med.
1997;
51:858-859
-
Section 6402 of the Omnibus Budget Reconciliation Act of 1989 (OBRA-89)
-
American Academy of Pediatrics, Resource-based Relative Value Scale Project Advisory Committee
Issues in the application of the Resource-based Relative Value Scale system to pediatrics.
Pediatrics.
1998;
102:996-998 [Abstract/Free Full Text]
Pediatrics (ISSN 0031 4005). Copyright ©1999 by the American Academy of Pediatrics