What Human Resource Leaders in Agriculture Need to Know About the Coming Wave of Medicaid Disenrollments By Ed McClements , CLU, ChFC, and Jon Alexander , Esq. of Western Growers Association The Kaiser Family Foundation reports an estimated 5 million to 14 million Medicaid enrollees will, over the next 12 months, have their coverage disrupted or eliminated. In California and Arizona, this disenrollment process is just getting started and will affect well over a million people. If even just one of those disenrolled is employed by your firm and that person ends up being transferred to Covered California or the Federal Exchange to take advantage of the Affordable Care Act (ACA) Premium Tax Credit, it could trigger potentially significant IRS penalties for your company. How well prepared are you for an ACA compliance audit? states were told to resume normal Medicaid
Why are Medicaid enrollees losing coverage? Under the Families First Coronavirus Response Act (FFCRA), states were encouraged to expand their Medicaid programs (in California, we call it Medi-Cal and in Arizona it is sometimes referred to as AHCCCS). To ensure continuous enrollment throughout the COVID pandemic, FFCRA suspended the need to worry about income or status changes that typically impact eligibility. This lack of enforcement of eligibility criteria has allowed enrollment to swell. The Consolidated Appropriations Act of 2023 declared an official end to Medicaid’s “continuous enrollment provision.” Beginning April 1, 2023,
eligibility determinations—and begin to process subsequent disenrollments for those who failed to meet current rules. Why is that an issue for large ag employers? In both California and Arizona (and most other states), residents are eligible for Medicaid if they have household incomes of below 138 percent of the Federal Poverty Level (FPL). Workers with incomes between 138 percent-400 percent of FPL are eligible for federal subsidies called Premium Tax Credits (PTCs) if they purchase their coverage via Covered California or the Federal Exchange.
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SEPTEMBER | OCTOBER 2023
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