SR 19-03 Dated 03/19

STATE OF NEW HAMPSHIRE

INTER-DEPARTMENT COMMUNICATION – DIVISION OF ECONOMIC AND HOUSING STABILITY (DEHS)

SUMMARY

This SR releases policy regarding the Granite Advantage Health Care Program (Granite Advantage) community engagement requirement. Unless exempt, Granite Advantage recipients must participate in 100 hours per month of community engagement activities.

BFA SR 19-04 will be released in May with final policy details regarding what activities count towards the community engagement requirement, good cause for not completing community engagement requirements, curing non-compliance with community engagement requirement, and suspension of benefits for failing to comply with the community engagement requirement.

BACKGROUND

The Affordable Care Act (ACA) and implementing regulations at 42 CFR 435.119 mandated Medicaid-funded health coverage for a new adult group of non-disabled, non-pregnant individuals who were between the ages of 19-64 and were not eligible for Medicare. A Supreme Court decision made coverage of the newly eligible adult group optional for states. New Hampshire decided to cover the newly eligible adult group and called the group the New Hampshire Health Protection Program (NHHPP/NHHPP-M).

New Hampshire has replaced NHHPP with the Granite Advantage Health Care Program (Granite Advantage). Granite Advantage will cover newly eligible adults aged 19-64 who are not eligible for Medicare like NHHPP, but will be subject to additional requirements described in this SR and SR 19-04 to be released in May.

POLICY

Granite Advantage Community Engagement Requirement

Unless exempt, Granite Advantage recipients must participate in 100 hours of community engagement activities per month.

75-Day Notice Period

New Granite Advantage recipients are given at least 75 days notice before the community engagement requirement begins. The community engagement requirement begins the first of the month following 75 days after a recipient is mandatory for the community engagement requirement.

Example 1: A Granite Advantage recipient continues receiving Granite Advantage on March 1 and is mandatory for community engagement. 75 days from the date the recipient is mandatory for community engagement is May 14. Since community engagement always begins on the first of the month unless exempt, the recipient’s community engagement requirement begins on June 1.

Exception: For recipients who had Granite Advantage closed at redetermination due to not meeting the community engagement requirement and reapply and are mandatory for community engagement, the community engagement requirement will begin on the first month following reapplication if the recipient had Granite Advantage closed in the past six months but not in the past 90 days. Former recipients who reapply more than six months after having Granite Advantage closed at redetermination due to not meeting the community engagement requirement will be allowed at least 75 days notice before the community engagement requirement begins again. Former Granite Advantage recipients who reapply within 90 days of closing for failure to meet community engagement requirements will need to meet the reconsideration requirement. See 230.20 Reconsideration of Granite Advantage.

Example 2: After being given a 75-day, notice period a Granite Advantage recipient’s medical assistance case is suspended on August 1 after failing to comply with the community engagement requirement. The case closes on September 30 at the end of the redetermination month because the recipient continued to fail to meet the community engagement requirement. The recipient applies for Granite Advantage on October 15. The recipient had Granite Advantage benefits closed in the past 6 months prior to the application, therefore the recipient will not be given another 75-day notice period and unless exempt the recipient must comply with the community engagement requirement beginning on November 1, the first of the month following reapplication.

Example 3: After being given a 75-day, notice period a Granite Advantage recipient’s medical assistance case is suspended on August 1 after failing to comply with the community engagement requirement. The case closes on September 30 at the end of the redetermination month because the recipient continued to fail to meet the community engagement requirement. The recipient applies for and is determined eligible for Granite Advantage on April 1 of the following year. Since the recipient’s last closure for failure to meet the community engagement requirement was more than 6 months prior to the recipients reapplication, the recipient is entitled to a new 75 day notice period. The notice period begins on April 1 and the recipient must comply with the community engagement requirement beginning on July 1.

Granite Advantage recipients who have an exemption that ends are allowed at least 75 days notice before community engagement begins even if the formerly exempt Granite Advantage recipient also had Granite Advantage benefits closed due to failure to comply with community engagement requirement in the past 6 months.

Example: 4: After being given at least 75-day notice period a Granite Advantage recipient’s medical assistance case is suspended on August 1 after failing to comply with the community engagement requirement. The case closes on September 30 at the end of the redetermination month because the recipient continued to fail to meet the community engagement requirement. The recipient applies for Granite Advantage on October 15. The recipient also opens for NHEP on October 15 and receives an exemption from NHEP requirements. The recipient’ NHEP case closes on November 1 for reasons unrelated to Granite Advantage. The recipient is determined to be mandatory for community engagement on November 2 because the exemption from NHEP requirements is no longer valid. The recipient gets a 75 day notice period from the date the recipient is determined mandatory for community engagement even though the recipient had Granite Advantage benefits closed or suspended in the past 6 months because recipients who lose exemptions always get a 75 day notice period. The recipient’s notice period begins on November 2 and ends on January 16 of the next year. The recipient must comply with the community engagement requirement beginning on February 1 of the next year.

Community Engagement Requirement Exemptions

Certain individuals may be temporarily or permanently exempt from the Granite Advantage community engagement requirement.

Manual Exemptions

Clients are exempt from the community engagement requirement if the client is:

Parents can claim the designated caretaker exemption for any of the parent’s children under the age of 6 regardless of whether the child lives with the parent. Whenever both parents live together and all children under the age of 6 are common between the two parents only one parent can claim the designated caretaker exemption for their shared children. However if both parents in the 2 parent household have uncommon children under the age of six both will be able to claim the caretaker relative exemption.

Example 1: A mother and father live together with two shared children under the age of 6. Both parents receive Granite Advantage. The father also has another child under age 6 who he has shared custody of a few days per week. Both parents can receive the caretaker relative exemption. The mother can receive the exemption for the shared children and the father can receive the exemption for his child.

Example 2: A mother and father live together with one shared child under the age of 6. Both parents receive Granite Advantage. Neither parent has any other children. Only one parent can receive the caretaker relative exemption.

Note: Medical Frailty is no longer a voluntary designation. Clients claiming to be medically frail must have a licensed medical health professional verify frailty to receive an exemption, even if the client was considered medically frail as part of NHHPP-M.

Automatic Exemptions

Clients are automatically exempt from the community engagement requirement if the client:

Verification of Exemptions

Clients must verify manual exemptions from the community engagement requirement.. SNAP or NHEP recipients who request an exemption from SNAP or NHEP work requirements must meet the verification requirements for SNAP or NHEP. For all other exemptions, clients must request an exemption. A licensed medical professional must verify exemptions for disability, medically frailty, hospitalization, illness and being caretaker of a disabled, developmentally disabled, or ill person. Clients must verify participation in state certified drug court programs by providing a court order.

NEW HEIGHTS & NH EASY SYSTEMS PROCEDURES AND IMPLEMENTATION

New HEIGHTS Updates

Medically Frail Screen

The medically frail screen has been modified because now medically frail status requires verification from a licensed health care provider. Now when a worker enters Yes in response to the question “Is the individual medically frail” a copy of BFA Form 331 Licensed Medical Professional Certification of Medical Frailty and BFA Form 320A Authorization to Release Protected Health Information will be sent to the client. The screen will also contain the documentation status. The default documentation status when a client claims medical frailty will be awaiting documentation. If the client submits completed BFA Form 331, the system will update the documentation status to processed. If the frailty certification that the client uploads is not BFA Form 331, such as a doctor’s note, or if BFA Form 331 is unreadable for the system, the document that was uploaded will appear in the workers inbox.

Work Program Status Screen

The existing Referral Information screen has been renamed to Work Program Status Screen. The screen will appear in the driver whenever a client opens for Granite Advantage. In addition to any existing SNAP or NHEP Work Program Information, this screen will contain information on Granite Advantage Community Engagement Status (Mandatory, Exempt, or Voluntary) for each individual receiving Granite Advantage in the case. Workers will only be able change the community engagement status with an override.

Community Engagement Screen

A new community engagement screen under Work Programs has been created to allow tracking of an individual’s compliance with the community engagement requirement. Currently the only tab on the community engagement screen is the exemption tab. Additional tabs will be created in May and explained with the release of BFA SR 19-04. The exemption tab will display information on each exemption request made by a given individual.

Call Log

A new screen has been created under Work Programs in the Granite Advantage section to log information about Customer Service calls to clients regarding the community engagement requirement. The screen will contain information about what the call(s) are about and whether the caller was able to contact the client or left a message.

NH EASY Updates

NH EASY has been updated to make a link to a new Granite Advantage Community Engagement page appear in the At A Glance menu for all clients enrolled or previously enrolled in Granite Advantage. The NH EASY Community Engagement Page will display an individual’s exemption status (mandatory, voluntary, or exempt). For mandatory individuals the page will include the ability to request an exemption through NH EASY, and the amount of community engagement hours that will be expected from the employment the individual reported at application.

DESCRIPTION OF REVISIONS MADE TO FORMS

Things You Need to Know

New BFA Form 310, Things You Need to Know Granite Advantage Health Care Program, is a one page double-sided form with information about Granite Advantage. BFA Form 310 provides clients with information about the community engagement requirement, what activities count towards community engagement, and resources for finding volunteer work or applying for Granite Workforce assistance. BFA Form 310 will be sent to each new Granite Advantage beneficiary in an initial mailing.

Exemption Request

New BFA Form 330, Exemption Request Form Granite Advantage Health Care Program, is a two page double-sided form that clients may use to request an exemption from Granite Advantage community engagement requirements. The form also lists what verifications clients must submit to receive an exemption.

Medical Provider Certification of Medical Frailty

New BFA Form 331, Licensed Medical Professional Certification of Medical Frailty, is a one page double-sided form that licensed medical providers use to certify a medical condition that prevents a client from participating in community engagement activities.

Authorization for Release of Protected Health Information

New BFA Form 320A, Beneficiary Authorization for Licensed Medical Professional to Release Protected Health Information, is a one page double sided form that clients provide to medical professionals to allow the professional to release health information regarding the client’s inability to participate in community engagement activities.

All new forms are online only. The forms will be generated in the New HEIGHTS systems and sent to clients. The forms are available electronically, for Department staff only, in the Family Services Folder on the N Drive.

POLICY MANUAL REVISIONS

Revised Medical Assistance Manual Topics

PART 230        GRANITE ADVANTAGE HEALTH CARE PROGRAM (GRANITE ADVANTAGE)

Section 230.01 Granite Advantage Eligibility Criteria

Section 230.03 Granite Advantage Community Engagement Requirement

Section 230.05 Community Engagement 75 Day Notice Period

Section 230.07 Community Engagement Requirement Exemptions

IMPLEMENTATION

All policy in this SR is effective March 1, 2019. SR 19-04 with policy regarding community engagement activities and good cause for not meeting community engagement requirements will be released in May.

All new forms are online only. The forms will be generated in the New HEIGHTS systems and sent to clients. The forms are available electronically, for Department staff only, in the Family Services Folder on the N Drive. Current versions of BFA Form 800, 811R, and 811S should be used until supplies are exhausted. BFA Form 800, 811R, and 811S can be ordered using current forms reordering procedures, via the Quarterly Forms Order (QFO).

CLIENT NOTIFICATION

At the end of September, all NHHPP/NHHPP-M clients were sent a one page notice that NHHPP would be transitioning to Granite Advantage. The notice explained that Granite Advantage would have care delivered through Managed Care Organization instead of Qualified Health Plans. The notice also warned that Granite Advantage would have a community engagement requirement beginning in April with basic information on exemptions and activities. In January, Granite Advantage recipients were sent another letter informing them the Granite Advantage community engagement requirement had been postponed to March and would begin, after a notice period, in June.

In March, each client currently enrolled in Granite Advantage will receive an initial mailing with a letter and various forms depending on the client’s community engagement status. Clients who are mandatory for community engagement, meaning the system could not verify an exemption automatically, will receive a letter explaining mandatory status and how to request exemptions, BFA Form 310 Things You Need to Know, and BFA Form 330 Exemption Request Form. Clients who are mandatory for community engagement and were previously designated as medically frail in NHHPP-M will receive a letter explaining mandatory status and how to request exemptions with additional language on how to verify medical frailty, BFA Form 310 Things You Need to Know, BFA Form 320A, Beneficiary Authorization for Release of Protected Health Information, and BFA Form 331, Licensed Medical Provider Certification of Medical Frailty.

The Department held a series of public forums on Granite Advantage at various locations in the state throughout the months of November through January.

For several months the home webpage for DHHS has had a link to information on Granite Advantage. https://www.dhhs.nh.gov/medicaid/granite/index.htm

The Department has contracted with a customer service firm to make outgoing customer service calls to all NHHPP and Granite Advantage clients to inform clients about Granite Advantage program changes.

TRAINING

The Training Unit is conducting a series of training in February to prepare workers for Granite Advantage.

FORMS MANUAL POSTING INSTRUCTIONS

DISPOSITION

This SR may be destroyed or deleted after its contents have been noted and the revised manual topics released by this SR have been posted to the On-line manuals.

DISTRIBUTION

This SR will be distributed according to the electronic distribution list for BFA policy releases. This SR, and revised On-Line Manuals, will be available for agency staff in the On-Line Manual Library, and for public access on the Internet at www.dhhs.nh.gov/DFA/publications.htm, effective April 1, 2019. Additionally, this SR, and printed pages with posting instructions, will be distributed under separate cover to all internal hard copy holders of the Family Assistance Food Stamp and Medical Manuals.

BFA/BDC:s