Washington State: Draft 2024 Cascade Care Savings Policy
The Washington Health Benefit Exchange released the draft 2024 Cascade Care Savings policy for public comments, due April 17, 2023. Cascade Care Savings is a state-funded premium assistance program for individuals with income up to 250 percent of the federal poverty level enrolling in coverage on the Exchange.
The draft 2024 policy mostly mirrors the 2023 policy, with the exception of some key policy changes. In PY 2024, the Exchange plans to carry out new practices intended to streamline processes for making and updating eligibility determination. Washington State received 1332 waiver approval to extend state premium assistance to eligible enrollees, regardless of their immigration status, in PY 2024.
Cascade Care Savings is funded at $55 million per year. The state premium assistance amount will be determined in actuarial analysis. In PY 2023, the fixed-dollar maximum per-enrollee Cascade Care Savings amount for plan year 2023 was $155 per month per member (PMPM).
Eligibility and Enrollment
Eligibility Criteria. As required by statute, eligible enrollees are Washington State residents with income up to 250 percent of the federal poverty level and who are eligible for Marketplace coverage (i.e., U.S. citizen or lawfully present, not incarcerated, ineligible for Medicare). Eligible enrollees are not eligible for existing state and federal coverage programs, such as Medicaid, and are not enrolled in Medicare. Lastly, individuals must apply for and access all available federal tax credits (i.e., Advanced Premium Tax Credits).
Eligibility Determinations. The Exchange generally determines eligibility for the State Premium Assistance Program on a prospective basis for the next month’s coverage. In PY 2024, the Exchange intends to extend state premium assistance to individuals enrolled in retroactive coverage (e.g., in the case of special enrollment due to a birth or loss of Medicaid coverage) and individuals enrolled in partial month coverage (e.g., death of enrollees), which would provide a prorated premium adjustment. Additionally, beginning in PY 2024, the Exchange intends to perform “periodic data matching” throughout the year to determine if an enrollee may be enrolled in Medicare or is deceased, and therefore ineligible for state premium assistance. Enrollees would have 30 days of the data match to dispute the eligibility determination before program eligibility is terminated at the end of that month of coverage.
Notice and Appeals. Individuals may use the existing appeals process to appeal eligibility decisions made by the Exchange on ineligibility and state premium assistance amount.
Special Enrollment Period. Eligible individuals with an income up to 250 percent who are not enrolled in a Cascade Care Silver or Gold plan are eligible for a monthly Special Enrollment Period in order to enroll in these types of plans. Coverage will be effective the first day of the month after plan selection.
Premium Assistance Amount
Funding. The Washington State Legislature funded the program at $55 million, including $5 million that is specifically allocated for individuals who do not receive federal subsidies (e.g., immigrants without proper documentation). Washington State received 1332 waiver approval to allow Washington residents, regardless of immigration status, to receive state premium assistance beginning PY 2024.
Premium Assistance Amount. The premium assistance amount will be calculated in an actuarial analysis based on 2024 premium rate filing, enrollment data, and other information. In PY 2023, the fixed-dollar maximum per-enrollee Cascade Care Savings amount for plan year 2023 was $155 per month per member (PMPM). The final PY 2023 Cascade Care Savings Amount Methodology performed by Wakely is available here.
Contingency for Low Funds. If the Exchange determines that program spending is at risk of exceeding available funds, then the Exchange may not distribute assistance to newly eligible households for the remainder of the year or until funds are replenished. The Exchange tries to prevent this scenario by reserving up to 10 percent of appropriated funds to account for enrollment uncertainty.
Administration
Premium Assistance Payments. The Exchange transmits payments to issuers who accept payments for enrollee premiums. Issuers must also comply with other requirements regarding data transmission, invoicing, and other matters. Notably, issuers are required to provide a three-month consecutive grace period to enrollees who fail to timely pay premiums and receive state premium assistance. Federal grace period rules apply to enrollees receiving APTC.
Premium Assistance Audit. The Exchange is required to annually contract with an independent Certified Public Account firm to audit the financial statements of the Program, which must be shared to the Washington State Legislature and other governing bodies.