On Oct. 1, 2013, enrollment in the Health Insurance Marketplace will begin under the Affordable Care Act (ACA), while coverage will begin on Jan. 1, 2014. Child support agencies have an important role to play in connecting uninsured parents and their children to health care coverage by providing them with information about and referrals to the Health Insurance Marketplace.
But as important as these dates are for consumers, they are not child support program deadlines. Child support program requirements will not change on Oct. 1 and Jan. 1. Instead, we will continue to keep doing what we are doing—what our statute directs us to do, which is to provide for child health care coverage in child support orders. Employers still have the same medical child support responsibilities to respond to the National Medical Support Notice as they had before. Over time, the ACA will likely impact how we carry out our medical child support responsibilities, but not directly and not tomorrow.
At OCSE, we’ve done a number of things to pave the way for the future of medical support:
- Early on, even before the ACA was enacted, we issued grants to bring together state child support and state Medicaid teams to begin to identify the issues.
- Beginning in 2010, we issued guidance to give state child support agencies flexibility to manage consistently with each state’s health care direction and framework—programmatically—as well as data reporting and audits.
- We clarified that state child support agencies may look to both private and public coverage in ordering medical child support.
- We clarified allowable activities, including medical support facilitators and liaisons to cover children and to develop effective health care referral policies for both parents.
- We’ve worked with the Centers for Medicare & Medicaid Services (CMS) to secure a medical support hardship exemption that exempts a parent from paying the shared responsibility payment if their child is not covered because the other parent was ordered to provide coverage but did not do so.
- We’re actively working with CMS to clarify child support assignment, cooperation, and Medicaid referral policies.
- We’re working within the federal government to clarify data sharing legal authorities between state child support and health care agencies, OCSE and state health care agencies, and between OCSE and federal health agencies. Our child support safeguarding rule permits state child support agencies to share certain data with state Medicaid and CHIP agencies.
I hope you’ll look at our new OCSE Child Support Health Care Connections fact sheets with staff in your child support agencies. We’ve prepared these fact sheets to help you find the information you need about the ACA. Please let us know your ideas for sharing the fact sheets.