HHS Plan Review Confirms Critical Role of CHIP in Post-ACA Health Care System

Health

Baby in a high chair

Last week, on Thanksgiving Eve, the HHS Centers for Medicare and Medicaid Services (CMS) released summary findings from a months-delayed congressionally-mandated review of health plans for children, “Certification of Comparability of Pediatric Coverage Offered by Qualified Health Plans.” This plan review, which was mandated under the Affordable Care Act (ACA), required the HHS Secretary to compare benefits and cost-sharing requirements between CHIP plans and Qualified Health Plans (QHPs) offered in state Marketplaces and to certify those that are comparable to CHIP. While HHS only released topline findings in a short white paper, the review confirms similar findings from the Wakely Consulting Group and, more recently, research commissioned by the Medicaid and CHIP Payment and Access Commission (MACPAC) that CHIP is far superior to QHPs in terms of affordability and benefits for children in all 50 states.

Specifically, HHS’s comparison analysis looked at the second lowest cost silver plan (SLCSP) in the largest rating area of every state in the nation and compared it with the corresponding state CHIP program. The review was based on actuarial value (AV) and premium plus cost sharing out-of-pocket costs of QHPs and CHIP plans. The leading findings of the HHS plan review include:

  • Average out-of-pocket spending in the SLCSP was higher than out-of-pocket spending in CHIP in every state on a per child basis under CHIP and under the SLCSP with financial assistance.
  • The actuarial value (AV) of SLCSPs was lower than CHIP in all states, except for Utah, where the AV was equivalent. However, when premiums were taken into account there was no state where out-of-pocket costs are not significantly higher for families in QHPs compared with CHIP.
  • Benefit comparisons indicated that benefit packages in CHIP are more comprehensive among “child-specific” services, including dental, vision, and habilitative services.

This plan comparability review, which was due to Congress by April 1, 2015, affirms what children’s health experts have long known – there are no Marketplace plans in any state that are equivalent to CHIP in terms of affordability for families and benefits for children. Notably, based on this review, HHS Secretary Sylvia Burwell announced that HHS would not certify any QHPs as comparable to CHIP coverage at this time.

While we are grateful to have confirmation from CMS that CHIP provides superior coverage for children under every measure (and at a lower cost to the federal government, I might add), it is unfortunate that this data was not shared in time to inform the debate when Congress was deliberating CHIP’s future back in February and March. This data would have been enormously helpful as Congress was considering whether to fully fund CHIP through its authorization period, which expires in 2019, or to provide only two-years of stop-gap funding for CHIP through 2017. Ultimately, in passing the Medicare Access and CHIP Reauthorization Act (MACRA) Congress provided just two years of continued CHIP funding despite the fact that there is no comparable alternative source of coverage for children on the horizon.

It is interesting to recall the origins of the CHIP-QHP plan comparability review. Back in 2010, as the ACA was being debated, now-retired Sen. Jay Rockefeller (D-WV) sought to protect and maintain CHIP in the newly reformed health system. He successfully amended the Senate’s ACA bill to extend CHIP’s authorization through 2019, embedding CHIP into the ACA coverage system, but he could only convince his colleagues to pay for funding through 2015. Concerned about the 2015 funding cliff and the enormous differences between CHIP and QHP plans, First Focus worked closely with children’s health champions on Capitol Hill – including Senator Debbie Stabenow (D-MI), Representative Diana DeGette (D-CO) and Senator Rockefeller – to include language in the ACA requiring HHS to compare CHIP plans and QHPs in an effort to protect children from being shifted into QHP coverage unless that coverage was at least comparable to CHIP. We knew then what the HHS review shows today – for children CHIP is simply a better deal.

We appreciate HHS’s release of the summary of CHIP/QHP comparability because it adds to the growing body of policy research that shows that CHIP is an essential component of the health care system for children. While we won’t face another CHIP funding shortfall till 2017, First Focus will renew our advocacy early in 2016 to make sure that CHIP funding is secured into the future. We will continue to educate lawmakers about CHIP’s role in covering more than 8 million children and remind them that in order for children’s coverage to remain strong states need to know well in advance of the funding deadline whether their CHIP programs will continue to be funded. As we celebrate new record lows in the numbers of uninsured children – now at a 6 percent – our work must continue to protect the programs like CHIP that have helped us reach this remarkable goal.


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