Preparing for 2014 - Overview of Ryan White Program Policy Updates and Guidance

August 14, 2013Department of Health and Human ServicesHealth Resources and Services AdministrationHIV/AIDS Bureau

Preparing for 2014:Overview of Ryan White Program Policy Updates & Guidance

1Todays Presentation WillProvide an overview of recently released HIV/AIDS Bureau (HAB) policies and guidance, including:Two new policy clarification notices, one on Medicaid eligibility, and another on client eligibility Joint Centers for Medicare & Medicaid Services (CMS)/Health Resources & Services Administration (HRSA) letter on coordination between Medicaid and the Ryan White HIV/AIDS Program (RWHAP)Letter on outlining allowable uses of RWHAP funds for outreach and enrollment activitiesRevised Core Medical Service Waiver policy

2Upcoming WebcastAn upcoming webcast, to be scheduled shortly, will provide an overview of additional HAB policies, including:13-03: RWHAP Client Eligibility Determinations: Considerations Post-Implementation of the Affordable Care Act13-04: Clarifications Regarding Clients Eligible for Private Health Insurance and Coverage of Services by RWHAP13-05:Clarifications Regarding Use of RWHAP Funds for Premium and Cost- Sharing Assistance for Private Health Insurance13-06: Clarifications Regarding Use of RWHAP Funds for Premium and Cost-Sharing Assistance for Medicaid

Policy Clarification Notice 13-01Clarifications Regarding Medicaid-Eligible Clients and Coverage of Services by Ryan White HIV/AIDS Program13-01: DetailsThis policy clarification reiterates HRSA policy regarding RWHAP clients who are currently eligible for Medicaid or will become eligible for Medicaid beginning on or after January 1, 2014.

Grantees must make every effort to enroll individuals in Medicaid if eligible - including individuals newly eligible for Medicaid under the Affordable Care Act.

The RWHAP will continue to be the payer of last resort and will continue to pay for Ryan White HIV/AIDS Program services not covered or partially covered by Medicaid.

513-01: Retroactive Medicaid EligibilityMedicaid coverage may start retroactively up to three months prior to the clients application date.

Grantees must back-bill Medicaid for services provided during this time.

6Policy Clarification Notice 13-02Clarifications on Ryan White Program Client Eligibility Determinations and Recertifications Requirements 13-02: Initial Eligibility Reiterates current client eligibility requirements to receive RWHAP funded services. Clients must be:HIV positiveLow-income, as defined by the grantee

Grantees have the option of narrowing eligibility requirements; however, requirements may not be broadened. 813-02: RecertificationGrantees must ensure that clients continue to meet eligibility requirements by verifying:Residency, income, and insurance status

Clients must be recertified no less than every six months.

Grantees must conduct an in-depth recertification at least once every 12 months.

Self-attestation can be used for one of the two required certifications; the other must be full recertificationAppropriate documentation is required for any changes

913-02: Summary of DocumentationEligibility CriteriaInitial Eligibility Determination & Once a Year/12 Month Period Recertification Recertification (minimum of every six months)

HIV StatusRequired for Initial Eligibility Determination

Not required for the once a year/12 month period recertification No documentation required IncomeDocumentation required Grantee may require:Full application and associated documentation, or Self-attestation, with documentation required only if there is a change in income.1013-02: Summary of Documentation, contdEligibility CriteriaInitial Eligibility Determination & Once a Year/12 Month Period Recertification Recertification (minimum of every six months) Residency

Documentation required

Grantee may require:Full application and associated documentation, or Self-attestation, with documentation required only if there is a change in residency.Insurance Status

Must verify if the applicant is enrolled in other health coverage and document the clients insurance status

Grantee must verify if the applicant is enrolled in other health coverage. Self attestation, with documentation only if there is a change in insurance status.CD4/Viral LoadDiscretion of the granteeDiscretion of the grantee1113-02: Other ConsiderationsRe-verification of HIV diagnosis is not required.

CD4/viral load is not required by HAB.

PO Boxes can be used for mailing addresses; however, clients must verify addresses via another means.13-02: Other Considerations, contdGrantees may use data-sharing agreements with other grantees and/or sub-grantees for recertification.

In states that have multi-tiered continuous residency, income, and insurance verification processes:No six month recertification is requiredMust be applied consistently to all clientsMust be approved by HAB

Part C, D, and F grantees are encouraged to coordinate with Part A and B grantees.Outreach and EnrollmentRWHAP grantees and planning bodies are encouraged to review their Fiscal Year 2013/2014 HIV service priorities, allocations, contracts and budgets and consider utilization of RWHAP resources to support Affordable Care Act related outreach and enrollment activities.

In March 2013, the HRSA HIV/AIDS Bureau posted recommendations for RWHAP grantees on uses of existing funding to complete activities in the following three areas: outreach education, enrollment and benefits counseling. 14Outreach and Enrollment contdRyan White Program Parts A & BEarly Intervention Services funding may be used for benefits counseling, enrollment and outreach education.

Medical Case Management Services funding may be used for benefits counseling and enrollment.

Non-Medical Case Management Services funding may be used for benefits counseling and enrollment.

15Outreach and Enrollment contdRyan White Program Parts A & B Health Education/Risk Reduction Services funding may be used for Affordable Care Act outreach education.

Outreach Services funding, which is generally used for identifying new HIV cases, HIV testing and linkage to care; or to re-engage individuals who have fallen out of medical care may be used for Affordable Care Act outreach education.

Referral for Health Care/Supportive Services funding may be used for benefits counseling, enrollment and outreach education, as the Affordable Care Act is considered a benefit to people living with HIV/AIDS.

16Outreach and Enrollment contdRyan White Program Minority AIDS Initiative - Part B

Minority AIDS Initiative funding may be used for outreach education, benefits counseling and enrollment.

17Outreach and Enrollment contdRyan White Program Part CMedical Case Management Services funding may be used for benefits counseling and enrollment.

Non-Medical Case Management Services funding may be used for benefits counseling and enrollment.

Outreach Services generally used for identifying new HIV cases, HIV testing and linkage to care; or to re-engage individuals who have fallen out of medical care may be used for Affordable Care Act outreach education.

18Outreach and Enrollment contdRyan White Program Part DMedical Case Management Services funding may be used for benefits counseling and enrollment.

Non-Medical Case Management Services funding may be used for benefits counseling and enrollment.

19Joint HRSA/CMS Informational BulletinIssued to promote a seamless transition of care into 2014

Outlines Federal coordination between HRSA and CMSIdentifies key resources at both agencies

Encourages coordination between Medicaid and the RWHAP AIDS Drug Assistance Program (ADAP)Core Medical Services WaiverFederal Register Notice With Opportunity for Comments Published May 24, 2013

This draft policy Outlines the application process for Part A, B, and C grantees to apply for a waiver of the requirement that 75% of funds be spent on core medical servicesClarifies documentation requirementsProvides more flexibility in the timeframe for grantees to apply for a waiverCore Medical Services Waiver, Contd Comment period closed on June 24, 2013

HRSA is currently reviewing comments and will make decisions shortly on next steps.

As is, the policy goes into effect on September 23, 2013.

Next StepsVisit the HAB webpage, Ryan White & the Affordable Care Act: What You Need to Know : http://www.hab.hrsa.gov/affordablecareact/index.html

On this page you may:Sign up for updates View and download slides from HABs recent webcasts

Email Ryan White Program/Affordable Care Act questions to: RWP-ACAQuestions@hrsa.gov