Unlocking the Potential of the ACA’s ‘No Wrong Door’
States have an opportunity under the health-care law to modernize their eligibility systems to cover a broad range of social services programs.
The Affordable Care Act, with its creation of online health insurance exchanges, sweeping commercial insurance reforms and expansion of the Medicaid program, is the most substantial expansion in health coverage since the creation of Medicare and Medicaid in 1965.
But while the law's focus on ensuring health coverage for all is an important starting point to improving overall health status, we cannot ignore the impact of social factors such as education, job training, access to food and housing, and financial stability that significantly impact the overall health and longevity of many. As we move beyond the rollout of the ACA's initial coverage provisions, we must pay greater attention to the "no wrong door" philosophy at the heart of this legislation.
The "no wrong door" policy was intended to enable consumers seeking coverage to complete a single, streamlined application to determine their eligibility for and enroll in programs including Medicaid, the Children's Health Insurance Program (CHIP) and the Qualified Health Plans (QHPs) offered through the new health benefit exchanges. Using a single eligibility determination and enrollment process means consumers would no longer have to navigate multiple agencies and systems to secure the various benefits they were eligible for.
While the initial implementation of the ACA has helped millions of Americans secure health coverage, the vision of the ACA encompassed a much broader approach to "no wrong door." That vision includes connecting consumers with other programs that are instrumental to health and well-being, such as the Supplemental Nutrition Assistance Program (SNAP, formerly known as food stamps) and Temporary Assistance to Needy Families (TANF). The law states that the exchanges must have the ability to expand enrollment systems to integrate new programs, rules and functionalities, to operate at increased volume, and to apply streamlined verification and eligibility processes to other federal and state programs. This expanded view has yet to be fully realized.
Recognizing the value of horizontal integration and the opportunity to further leverage systems built to support the ACA, federal agencies established guidance known as the A-87 Cost Allocation Exception. This provision allows states to modernize their health and human services eligibility systems for programs such as TANF and SNAP as long as the costs would have been incurred to develop systems needed for Medicaid, CHIP or an exchange. While the impetus behind the A-87 Exception was the ACA, funding is not limited to states that have expanded their Medicaid programs or developed their own health insurance marketplaces.
By leveraging the A-87 Exception, state health and human services organizations have the opportunity to update legacy systems to achieve better health outcomes and greater overall administrative efficiency. The A-87 Exception was originally set to expire this December, but the Center for Medicare and Medicaid Services recently announced an extension for three more years.
By leveraging the foundation put in place by the ACA, we can expand the "no wrong door" policy to promote horizontal integration across a full spectrum of federal, state and local health and social-services programs. Connecting consumers to a broader range of services holds the promise of making real, lasting progress toward improving overall health status.