Dec. 1, 2023

County Connections

This Department of Health Care Policy & Financing (HCPF) newsletter is designed to inform county directors, management and staff about high-impact updates, important changes, county performance, new guidance, and program changes.

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High-Impact Updates

Message from the Executive Director

HCPF’s FY 2024-25 Budget, Public Health Emergency Update, Community Engagement


On Nov. 1, the Governor released the proposed budget for FY 2024-25, which takes important steps toward bold goals, builds on the successful work of these last five years, and reflects the voices of Coloradans from across our state with important investments in housing, public safety, education, workforce development, saving people money on health care, and achieving our renewable energy goals. 


HCPF’s proposed budget for FY 2024-25 is $16.4B Total Fund and $5.0B General Fund, assuming an average of 1.6M covered lives over the fiscal year. This represents about 38% of the state’s Total Fund operating budget and about 31% of the state’s General Fund operating budget. 


Our budget proposal includes a 1% across the board (ATB) provider reimbursement rate increase (representing about $29M in General Fund investment). This is on top of the 3%, 2% and 2.5% ATB increases in the three previous fiscal years during the period of unprecedented distribution of federal stimulus dollars; this year’s ATB increase is more than double the less than 0.5% normative or average ATB increase between FY 2010-11 and FY 2020-21 (shown in the table below). 

The budget also includes $103M Total Fund and $25.9M General Fund in targeted rate increases. Recall that HCPF and the Joint Budget Committee (JBC) collaborated last year to increase the frequency of these targeted provider rate increases, including the access analysis, rate comparison to benchmarks, and related stakeholder engagement that occurs as part of the Medicaid Provider Rate Review Advisory Committee (MPRRAC) process. The frequency of the reviews has now moved from every five years to every three, meaning more provider types are going through the process each year. 


This FY 2024-25 budget reflects the first increase in the number of provider types moving through the MPRRAC process based on the 3-year cycle and includes Pediatric Behavioral Therapies, ambulatory surgical centers (ASCs), surgical, behavioral health, maternal health, dental services and anesthesiology. Visit our legislator resource center to review the entire MPRRAC report. In addition, HCPF’s budget also includes an off-cycle investment of $53.9M Total Fund and $13.6M General Fund in base wages to the direct care workforce, who serve Health First Colorado members through Home and Community-Based Services (HCBS). It further includes a $5M General Fund one-time investment to support eligibility processing and health care information technology and innovation advances within the state’s largest safety net provider, Denver Health, as well as an investment in the primary care fund.


HCPF’s budget also seeks to modernize our eligibility and claims systems, advance provider tools to improve whole-person health (sometimes called the social health information exchange or Phase II of the Prescriber Tool), improve access to services for members with complex needs, and maintain the compliance and support needed to effectively run our programs. 


Our proposed budget makes significant investments to continue transforming the behavioral health system, including working with the legislature on unprecedented commitments to support the families of youth with high-acuity behavioral health needs. Overall, HCPF’s budget includes about $1.2B Total Funds allocated to behavioral health. 


The budget further adds Autism Spectrum Disorder (ASD) treatment coverage into the Child Health Plan Plus (CHP+) program and accounts for Colorado expanding Health First Colorado coverage to pregnant adults and children who are DACA recipients, pending federal requirements.


In addition to reviewing the budget submission with stakeholders, answering questions and securing the appropriate allocation to advance our safety net coverages and programs, another top HCPF priority continues to be to Keep Coloradans Covered, now that Colorado has resumed regular eligibility reviews for people with Health First Colorado and CHP+ after a 2+ year pause during the COVID-19 public health emergency (PHE). Thank you for your active engagement with members, community partners, and advocates leading up to and during the unwind period and for your continued dialogue to improve the renewal process. Based on stakeholder feedback, we have made the following changes:

  • Renewal packets are shorter and a colored Colorado State seal has been added to help mitigate it being mistaken for junk mail.
  • HCPF is leveraging additional flexibility from the federal government to provide a 60-calendar-day extension to complete the renewal process for our vulnerable populations, including long-term care (LTC), members on waivered services, and buy-in recipients who have not returned their renewal packet on time. This flexibility will remain in place through June 2024. 
  • We’re improving the PEAK and Health First Colorado app user experience by making it easier to submit renewal materials and monitor the status of a submitted renewal.
  • HCPF has created and advanced extensive partner toolkits to help members and partners complete the renewal process or transition to other affordable health coverage; these are now available in the top 11 languages used by our members: Update Your Address, Understanding the Renewal Process and Take Action on Your Renewal. Flyers have been developed for employers to distribute to employees to remind them to look for their Health First Colorado renewal packet and where appropriate, the means to transition to employer-sponsored coverage, and the importance of doing so in a timely manner. We ask that all stakeholders leverage these tools. 


Thank you to the more than 150 partners, advocates, and stakeholders who joined our Oct. 25 quarterly PHE Unwind webinar. All related materials are on our website. Our reporting webpage is updated monthly. Thank you for continuing to visit our websites and reporting pages to secure updated information and tools. 


Over the last few months, I visited with partners and industry leaders in many communities. During these visits, we discussed efforts to Keep Coloradans Covered, expand the health care workforce, drive affordability, transform behavioral health, advance care and support for individuals with disabilities and older adults, propel health equity and innovations, refine the Accountable Care Collaborative Phase III concepts, improve our capabilities and partnerships, and more. Thank you to the many chambers and employer groups, legislators, hospitals, community health centers, mental health centers, Regional Accountable Entities, counties and other key partners who met with me and HCPF leaders across Pueblo, Colorado Springs, Grand Junction, Denver, Northern Colorado and the Eastern Plains. We truly appreciate your feedback and collaborative efforts to achieve shared access, quality, equity, and affordability goals. 

HCPF - Ex Parte at the Individual Level

HCPF is releasing this communication to notify Eligibility Sites of Project 8556 CBMS Medicaid Renewal Ex Parte, a short-term fix to evaluate eligibility at the individual level at the final review of the renewal process.


Details: Project 8556 was implemented to ensure members determined eligible at MA ex parte no longer get terminated with the rest of the household when the household does not return a Renewal Packet or Signature page. This change is required to comply with a recently clarified rule from the Centers of Medicare and Medicaid Services (CMS).


This project will be applied to the extension of September and October Medical Assistance renewals. If the Renewal Packet or Signature page is returned timely, an appropriate eligibility determination will still be made at the individual level. 


Action: Eligibility workers do not need to take any action within CBMS. Sites can expect to see members who would have previously been terminated during MA renewal for failure to return the Renewal Packet and/or Signature page continue to pass if they were found eligible at MA ex parte members. Eligibility workers may also expect to see members reach out for guidance. 


Eligibility Sites can access the updated training and resources: 


MA Renewal Revamp Training

  • COLearn
  • Medical Assistance Renewals – Web-Based Training (WBT) 

MA Renewal Resources 

  • Renewal of Eligibility (bottom of page)
  • Renewal Revamp FAQ
  • Updates to the Renewal Revamp Workbook - coming soon


Contact: Questions regarding this communication may be directed to HCPF Medicaid Eligibility.

NEMT Provider Enrollment Moratorium: How to Protect Health First Colorado Members

Effective Oct. 1, the Centers for Medicare and Medicaid Services (CMS) approved a moratorium of at least six months on any new and pending Non-Emergent Medical Transportation (NEMT) provider enrollments. The moratorium is due to a significant potential for fraud, waste, or abuse of the Health First Colorado (Colorado Medicaid) program. Visit HCPF’s provider news page to stay up to date on any changes in the coming months. 


HCPF has created fliers to help Health First Colorado members know what NEMT drivers should and should not do when giving members a ride. There are also directions for members to report suspicious activity. Please help us prevent fraud, waste, and abuse, and to protect member health and safety, by printing and posting the English and Spanish flyers in spaces where Health First Colorado members can see the information. Thank you for your continued partnership caring for members.

Recent Memo Series Issued to Counties

All memos and their attachments are on the Memo Series website.

Policy Memos

None

Operational Memos

HCPF OM 23-074

Minimum Monthly Maintenance Needs Allowance (MMMNA)

The purpose of this operational memo is to advise eligibility sites of the increase to the Community Spouse Minimum Monthly Maintenance Needs Allowance (MMMNA) and Shelter Allowance. Please share this letter with all eligibility staff, supervisors and administrators that manage nursing facilities, Home and Community Based Services (HCBS), the Program of All Inclusive Care for the Elderly (PACE) and other outside agencies as appropriate. 


HCPF OM 23-073

PHE Long Term Care Extension Outreach

The purpose of this Operational Memo is to provide instructions to county departments of human/social services (counties), Medical Assistance (MA) sites, and Eligibility Application Partners sites (EAP) regarding the Public Health Emergency (PHE) Long Term Care Extension Outreach project HCPF implemented in September 2023. The purpose of the project is to ensure individuals with Long-Term Care coverage at risk of procedural denials receive an additional outreach before being disenrolled, in accordance with federal direction. 


HCPF OM 23-067

State Requirements for Eligibility Site Medical Assistance Training

The purpose of this Operational Memo is to promulgate sub-regulatory requirements relating to required initial hire, ongoing and annual trainings for staff at county departments of human/social services, Medical Assistance and Eligibility Application Partner Sites (herein referenced as “Eligibility Sites”) to comply with Medical Assistance (MA) training requirements as referenced in 10 CCR 2505-5 1.020.3.3. Trainings related MA eligibility determinations are offered by the state to Eligibility Sites through the Health Care and Economic Security Staff Development Division (SDD). The SDD develops and implements training plans and provides instruction to staff who will, or currently have, access to the Colorado Benefits Management System (CBMS).


HCPF OM 23-062

Behavioral Health Administration Community Services

This memo aims to provide Colorado Benefits Management System (CBMS) eligibility workers with general information about the new High-Level Program Group (HLPG), Behavioral Health Administration (BHA) Community Services, that went live on July 1, 2023. This memo will outline its impact on PEAK/PEAKPro and CBMS. Additionally, further information will be provided about BHA Community Services’ eligibility and program benefits. Please share this memo with anyone who works with applicants seeking benefits from programs administered by the Behavioral Health Administration and the Colorado Department of Health Care Policy & Financing.

Informational Memos

None

Informational Updates

Civil Rights Discrimination Complaints

Per HCPF OM 23-003, counties are required to track all civil rights discrimination complaints. The tracking of civil rights investigations should include: 

  • date the complaint was received 
  • date the investigation was completed 
  • the type of investigation (informal or formal)
  • if the complaint was founded or unfounded
  • any process changes implemented as a result of the investigation
  • any training conducted as a result of the complaint


OM 23-003 also requires counties to submit their civil rights discrimination complaint tracker to HCPF biannually on Jan. 31 and July 31 of each year. The first submission is due Jan. 31, 2024. 


The tracker can be submitted using the County Relations Webform with the ticket type “County Oversight.” The county tracker must be submitted, even if there are no new discrimination complaints to report.


If you have any questions, please submit a ticket to the County Relations Webform.

Benefit Plans for Free Family Planning Services

Individuals not eligible for full Medicaid coverage may be able to receive free family planning services through Health First Colorado. Effective July 2022, the Family Planning Limited Benefit and the Reproductive Health Care Program now cover family planning and family planning-related services at no cost to the member. 

  • The Family Planning Limited Benefit Plan (FAMPL) is available for individuals who have a higher income than the Medicaid limit but meet all other eligibility requirements. 
  • The Reproductive Health Care Program (RHCP) is combined with the Emergency Medicaid Services Benefit Plan (EMS) and is available for individuals who do not meet Medicaid’s citizenship requirements but meet all other eligibility requirements. 


Applicants should select that they want family planning services when completing the application. Here’s how counties can help members learn and enroll in these benefit plans so Health First Colorado can improve access to reproductive health services: 

  • Post and share flyers informing individuals about the benefit plans:
  • Family Planning Limited (FAMPL) Benefit Plan English I Spanish 
  • Reproductive Health Care Program (EMS/RHCP) Benefit Plan English I Spanish
  • Direct members to our Health First Colorado website to learn more:
  • FAMPL and RHCP Website
  • EMS Website
  • Member Handbook
  • Family Planning Benefits and Services
  • Ensure members understand the Public Charge rule so they can feel confident when applying for and using Health First Colorado Benefits:
  • Public Charge Information: English I Spanish 
  • Recommend this as an option for individuals who are concerned they will lose coverage with the end of the PHE.
  • Increase use of translated resources that ensure all individuals can access these benefit plans.


Members can learn more online, in-person or over the phone. 


If your county would like additional information on the new benefit plans, please reach out to Kim Tolchinsky.

Long-Term Care (LTC) and Buy-In Renewal Extension

A CBMS update will automatically extend the renewal period for 60 days for Long-Term Care (LTC), individuals on Waivered Services, and Buy-In recipients who have yet to return their renewal packet on time during COVID Unwind.  


HCPF is providing an additional 60-day extension to assist our vulnerable populations, including Long-Term Care (LTC), individuals on Waivered Services, and Buy-In recipients who have not returned their renewal packet on time during COVID Unwind.  


CBMS will add 60 days to September renewals for vulnerable populations, including Long-Term Care (LTC), individuals on Waivered Services, and Buy-In recipients who do not return their renewal packet on time. This does not include cases that have already closed.


Action: Below are resources for eligibility workers that provide additional information and data entry guidance.     


  • The Staff Development Division (SDD)
  • MA Renewal for LTC & Buy-in Population Desk Aid 
  • Navigate to the Document Library on the website and find the above titled desk aid in the Long-Term Care folder
  • COVID Resources for County and Eligibility Partners  
  • Aug. 24 HCPF/Eligibility Sites COVID Unwind Touch Base Meeting
  • Slide Deck (coming soon)
  • Recording 


Contact: Any questions regarding this communication may be directed to hcpf_medicaid.eligibility@state.co.us.

Temporary Extension for All Members Up for Renewal

HCPF will be temporarily extending members’ renewals due in September and October for those who have not yet submitted their renewal packet. This is to comply with recent federal guidance.

 

HCPF received new guidance from the Centers for Medicare and Medicaid Services (CMS) on Aug. 30, 2023, that requires a change to the ex parte process for renewals. Instead of renewing members with ex parte at the household level (all members of a household receiving Health First Colorado or CHP+ benefits reviewed for eligibility at the same time), CMS is requiring states to perform ex parte reviews on an individual basis, meaning each person in the household is reviewed and approved separately. This new guidance will require significant changes to our eligibility system that will need to be done in a phased approach. As a result, HCPF is implementing a temporary renewal extension for all members up for renewal in September and October until we implement a short-term system change in mid-October to bring us into compliance with CMS guidance. The extension and short-term system change will not impact the member’s experience of the renewal process. Members are strongly encouraged to complete, sign, and return their renewal packet right away.

 

Action: New functionality is not being added. This means no additional action is needed from eligibility workers beyond normal processing of renewals. Similar to the Long-Term Care (LTC) and Buy-In Renewal Extension, the extension will be done systematically by setting the Data Entry Complete field in CBMS to No on the Case Wrap up screen. This is for September and October Medical Assistance renewals in which a renewal packet has not yet been started and will prevent a termination for failure to return the renewal packet. This will not affect renewals that have been started in CBMS and are already in progress.

 

Renewals that are received from members should be started in CBMS within 24-48 hours of receipt and processed accordingly. Once data entry is complete, eligibility workers must manually update the Data Entry Complete field to Yes and run eligibility.

 

Contact: hcpf_medicaid.eligibility@state.co.us

County Relations Team Introduces
Customer Relationship Management System

Do you need help? Do you have a question? Does a case need to be escalated? There are two ways you can contact the HCPF County Relations team.

  1. County Relations Web Form. Try this method first. It allows you to enter details to help us resolve your issues.
  2. County Relations Email. You can still email us at hcpf_countyrelations@state.co.us. Your email to us will automatically create a service ticket with your email included. We cannot open encrypted messages within our ticketing system.
Supplemental Information

HCPF Contacts & Resources

Staff Development Center (SDC) Homepage


CO.Learn/Learning Management System Login


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