BILL ANALYSIS                                                                                                                                                                                                    Ó



          SENATE COMMITTEE ON HEALTH
                          Senator Ed Hernandez, O.D., Chair

          BILL NO:                    SB 1339             
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          |AUTHOR:        |Monning                                        |
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          |VERSION:       |April 11, 2016                                 |
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          |HEARING DATE:  |April 20, 2016 |               |               |
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          |CONSULTANT:    |Scott Bain                                     |
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           SUBJECT  :  Public social services:  intercounty transfers

           SUMMARY  : Makes a number of changes to the inter-county transfer (ICT)  
          process when public assistance beneficiaries move from one  
          county to another county. Changes include requiring either the  
          old or new county to initiate the ICT process; specifying the  
          methods by which someone can request an ICT; requiring that all  
          benefits be transferred within 30 days of either county learning  
          of the move; requiring a simple, user-friendly process and  
          ensuring that recipients do not have to submit information they  
          have already provided; stating that counties should share case  
          files electronically whenever possible. Entitles a Medi-Cal  
          beneficiary moving to a new county to the full scope of benefits  
          for which he or she is enrolled in the county that he or she is  
          residing in at the time, notwithstanding any other provision of  
          law.
          
          Existing law:
          1)Makes it the responsibility of a recipient changing residence  
            from one county to another within the state to promptly notify  
            the county paying aid to the recipient of the move and to  
            apply for a redetermination of eligibility within the new  
            county of residence. Requires, through regulation, as a  
            condition of Medi-Cal eligibility, applicants and  
            beneficiaries, and persons acting on behalf of such applicants  
            or beneficiaries, to report specified information to the  
            county department, including a change of address that may  
            affect the determination of eligibility and share of cost  
            within 10 calendar days, following the date of the change.

          2)Requires, as part of the ICT, the first county to notify the  
            second county of the recipient's move as soon as the  
            recipient's location in the second county is known. 







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          3)Requires the county to which the recipient has moved to be  
            responsible for determining the recipient's continued  
            eligibility for payment of aid, as of the first day of the  
            month following 30 days after the first county has notified  
            the second county of the recipient's relocation. 

          4)Requires the first county to provide the second county with  
            copies of those documents, as specified by DHCS, necessary to  
            establish current eligibility and the grant amount.

          5)Permits, pursuant to regulation, expedited disenrollments from  
            Medi-Cal managed care, subject to specified criteria. One of  
            the criteria is that the beneficiary has not used services for  
            which the plan is contractually obligated to pay during the  
            month for which disenrollment is requested.

          6)Requires, through regulation, the Health Care Options Program  
            (HCO Program) to disenroll any member from a Medi-Cal managed  
            care plan when one of specified conditions is met. One of  
            those condition is there is a change of a member's place of  
            residence outside the plan's service area.

          7)Requires an eligible beneficiary seeking to disenroll from a  
            Medi-Cal managed care plan to submit an enrollment or  
            disenrollment request on an original, signed enrollment/  
            disenrollment form to the HCO Program by mail, fax, telephone,  
            or in person at DHCS-approved HCO Program sites.

          8)Requires expedited disenrollments to be effective on the first  
            day of the month in which the request is processed, and  
            requires the HCO Program to process all completed  
            disenrollments. 

          9)Requires the HCO Program to notify beneficiaries in writing of  
            the approval or disapproval of enrollment and disenrollment  
            requests, including expedited disenrollment requests, within  
            seven working days of receipt of the request. 

          10)Establishes, through regulation, the effective date of  
            enrollment or disenrollment is determined as follows:

               a)     Requires enrollment requests and non-expedited  
                 disenrollment requests processed before the monthly  
                 update to the Medi-Cal Eligibility Data System (MEDS) to  
                 be effective on the first day of the month following the  
                 month in which the request is processed; and, 







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               b)     Requires enrollment requests and non-expedited  
                 disenrollment requests processed after the monthly update  
                 to the MEDS to be effective on the first day of the  
                 second month following the month in which the request is  
                 processed.

          1)Requires expedited disenrollment requests to be effective on  
            the first day of the month in which the request is processed,  
            whether submitted before or after the monthly update to MEDS.
          
          This bill:
          1)Requires it be the responsibility of a recipient changing  
            residence from one county to another to promptly notify either  
            the county from which he or she moves or the county to which  
            he or she moves of the change of residence. (This requirement  
            currently exists for Medi-Cal.)

          2)Requires that recipients of CalWORKs, CalFresh, or Medi-Cal  
            have the right to report a change of residence in person, in  
            writing, telephonically, or, if the technology is available,  
            electronically online, and to be advised of this right at the  
            time of application and redetermination or recertification. 

          3)Requires counties, if a recipient moves from one county to  
            another county, as soon as either county is aware of the move,  
            that county to initiate an ICT for all benefits that the  
            recipient is receiving. 

          4)Requires benefits for all programs for which the recipient is  
            eligible to be transferred within 30 days after any county  
            becomes aware of the recipient's move in order to effectuate  
            the earliest possible start date.

          5)Requires, to the greatest extent possible, the ICT process to  
            be simple and client friendly and minimize workload for county  
            eligibility operations. Requires the ICT to ensure the  
            applicant or recipient does not need to provide copies of  
            documents that were previously provided to the prior county of  
            residence, and there is no interruption in benefits.

          6)Requires case file documents to be electronically shared  
            between the prior county of residence and the new county of  
            residence, to the extent possible, as specified by the  
            relevant state departments.

          7)Prohibits, to the extent permitted by federal law and  







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            regulation, the new county of residence from interviewing  
            recipients moving to that county from another county to  
            determine continued eligibility for CalWORKs or CalFresh until  
            the next scheduled recertification or redetermination.

          8)Entitles a Medi-Cal beneficiary moving to a new county to the  
            full scope of benefits for which he or she is enrolled in the  
            county that he or she is residing in at the time,  
            notwithstanding any other provision of law.

          9)Requires, if the beneficiary is required to receive services  
            through a Medi-Cal managed care plan and he or she moves to  
            another county and is still enrolled in a managed care health  
            plan in the county from which he or she moved and needs  
            services in the new county and requests disenrollment to the  
            Medi-Cal Managed Care Ombudsman, the beneficiary to be  
            disenrolled as an expedited disenrollment from his or her  
            Medi-Cal managed care health plan effective the next business  
            day after the request is made.

          10)Permits a beneficiary to request an expedited disenrollment  
            by telephone, in person, or electronically online. Requires  
            the expedited disenrollment request to be available for  
            submission by the beneficiary electronically online to reduce  
            administrative costs and increase access to medical services  
            for Medi-Cal beneficiaries.

          11)Requires a beneficiary who is disenrolled from the Medi-Cal  
            managed care health plan in the county from which he or she  
            moved to receive services in the new county through the  
            fee-for-services delivery system until he or she is enrolled  
            in a Medi-Cal managed care health plan in the new county.

          12)Requires, if the Medi-Cal beneficiary moves to a county that  
            provides Medi-Cal services through a county organized health  
            system (COHS), the beneficiary to be enrolled in that COHS  
            plan on the first day of the month the new county of residence  
            assumes responsibility for that beneficiary. 

          13)Requires, if a Medi-Cal beneficiary moves to a county without  
            a COHS, the usual health plan choice process to apply.

          14)Prohibits failure to report a move to a different county  
            within the state in itself from constituting a basis for an  
            overpayment.








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          15)Requires responsibility for payment of aid to a person  
            qualifying for and receiving aid from a county who moves to  
            another county in this state to make his or her home, to be  
            transferred to the second county as soon as administratively  
            possible and within 30 days after either party becomes aware  
            of the aid recipient's move. Counties currently have transfer  
            responsibility as soon as administratively possible but not  
            later than the first day of the month following 30 days after  
            notification to the second county. 

          16)Prohibits an appropriation required under a specified  
            provision of existing law for the maintenance and support of  
            needy children and pregnant mothers from being required for  
            purposes of implementing this bill.

          17)Repeals the existing ICT CalFresh provisions and replaces it  
            with the above-described provisions.

           FISCAL  
          EFFECT  :  This bill has not been analyzed by a fiscal committee.

           COMMENTS  :
          1)Author's statement.  According to the author, this bill  
            modernizes and simplifies the ICT process in state statute to  
            make sure that benefits are not interrupted when a beneficiary  
            of the CalWORKs, CalFresh, or Medi-Cal program relocates.  
            There is some confusion among counties with regard to the  
            implementation of ICTs and there are instances in which the  
            sending or receiving county does not fully understand the  
            process due to current law being vague.  For Medi-Cal  
            beneficiaries, delays in transfers is of particular concern  
            because it could disrupt continuity and access to care or cost  
            the state more money if the only other access to care in the  
            new county is the emergency room. This bill makes it clear in  
            the statute that Medi-Cal beneficiaries are entitled to care  
            in their new county even if they are in a health plan and  
            outlines procedures to ensure the consumer can enroll in the  
            new county.
          
          2)ICT. The process of transferring cases for eligibility and  
            case management purposes is known as an ICT. The three major  
            programs (CalFresh, CalWORKs and Medi-Cal) all have ICT  
            procedures. DHCS guidance to counties instructs counties to  
            ensure all Medi-Cal cases remain active throughout the ICT  
            period with no interruption in benefits. Counties are  
            instructed not to terminate benefits when a Medi-Cal  







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            beneficiary moves to another county until an effective date of  
            benefits for the beneficiary in the new county is confirmed.  
            In addition, counties are prohibited from requiring a  
            beneficiary to reapply for Medi-Cal benefits or apply for a  
            redetermination of eligibility in the new county solely due to  
            the change in county residence.

          3)Double referral. This bill was heard in the Senate Human  
            Services Committee on March 30, 2016 and passed as amended on  
            a 4-0 vote.

          4)Support. This bill is jointly sponsored by the Coalition of  
            California Welfare Rights, United Ways of California and  
            Western Center on Law and Poverty (WCLP). WCLP writes this  
            bill would modernize the process for transferring records for  
            people who are receiving CalWORKs, CalFresh or Medi-Cal when  
            they move from one county to another within California to  
            ensure no break in benefits. WCLP states that low-income  
            families move more frequently than higher income families, and  
            this is especially true during this time of low renter vacancy  
            rates, high eviction rates and the displacement of low-income  
            families of color from urban centers. Retaining safety net  
            benefits when moving to a new county is not only critical to  
            the health and stability of the family in their new community,  
            but also a right to which recipients are entitled. WCLP states  
            it has heard from community partners assisting consumers who  
            have had trouble transferring their benefits to a new county.  
            In these cases, people haven't been able to access medical  
            care or CalWORKs supportive services including cash aid,  
            transportation and child care services. WCLP states delays in  
            processing ICTs results in individuals and families who are  
            already struggling to get by on very limited means being  
            unable to participate in job training or see the doctor,  
            because their benefits have not been moved to their new  
            county. Current ICT rules require people to report the move to  
            the county human services agency in the county from which they  
            moved, which has proven not to work well sometimes, and the  
            process itself is outdated in a number of other respects. This  
            bill would streamline and modernize the ICT process. 

            In addition to the ICT, this bill also addresses an issue in  
            Medi-Cal when people move from one county to another. WCLP  
            states that now that most people are in a Medi-Cal managed  
            care plan, there is the additional step of getting into a plan  
            in the new county once someone's address has been changed in  
            the eligibility system. People who move mid-month are still  







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            enrolled in their Medi-Cal health plan from their old county.  
            They can access emergency services but often are unable to  
            access non-emergent services if their plan's network of  
            providers does not have providers in the new county. This can  
            be tragic for someone undergoing a course of treatment,  
            including people with acute conditions as well as pregnant  
            women in need of prenatal care. This bill will address access  
            to care by making it clear that Medi-Cal members are entitled  
            to care in their new county even if they are in a health plan  
            by outlining procedures for a consumer to disenroll from the  
            health plan in their old county through an expedited  
            disenrollment process so they can access services pending  
            enrollment into the new county. The bill largely formalizes  
            the current process whereby the Medi-Cal Managed Care  
            Ombudsman does expedited disenrollments for Medi-Cal members  
            who need non-emergent care. The new component in the bill is  
            the ability for a member to initiate this disenrollment online  
            - a process that already exists for county workers and should  
            be extended to consumers.
            
          5)Change to expedited disenrollment. Under existing regulation,  
            expedited disenrollment from Medi-Cal managed care is subject  
            to specified criteria. One of the criteria is that the  
            beneficiary has not used services for which the Medi-Cal  
            managed plan is contractually obligation to pay during the  
            month for which disenrollment is requested. Under current  
            regulation, expedited disenrollment requests are be effective  
            on the first day of the month in which the request is  
            processed. 

          This bill would no longer limit the expedited disenrollment of  
            Medi-Cal managed care beneficiaries to individuals who have  
            not received services in a month in their original county  
            Medi-Cal managed care plan. Instead, this bill would require  
            that beneficiaries be disenrolled as an expedited  
            disenrollment effective the next business day after the  
            request is made. In addition, the beneficiary would be  
            entitled to the full scope of services for which he or she is  
            entitled in the new county for FFS Medi-Cal. The argument for  
            granting the same scope of coverage to a Medi-Cal beneficiary  
            in a new county is Medi-Cal is a statewide program, and its  
            beneficiaries have limited income and assets and are less  
            likely than individuals with private coverage to be able to  
            pay-out-of pocket for non-emergency services. In discussions  
            with DHCS on this issue, DHCS views allowing an expedited  
            disenrollment mid-month as "paying twice" as the state has  







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            reimbursed the Medi-Cal managed care plan for that month of  
            care, and the beneficiary would then be eligible for the full  
            extent of their Medi-Cal covered services under this bill on a  
            fee-for-service basis in their new county.

          6)Author's amendment. To clarify that this bill is not intended  
            to require Medi-Cal managed care plans to cover services  
            out-of-network when a beneficiary moves to another county, the  
            author proposes to amend this bill as follows:

          (e)  Notwithstanding subdivision (a) or any other law, a Medi-Cal  
          beneficiary moving to a new county shall be entitled to the full  
          scope of benefits for which he or she is enrolled in the county  
          that he or she is residing in at the time.  For beneficiaries  
          required to receive services through a Medi-Cal managed care  
          health plan, the following shall apply:
             
          (1) If the beneficiary moves to another county and is still  
          enrolled in a managed care health plan in the county from which  
          he or she moved and needs services in the new county, the  
          beneficiary shall, upon request to the Medi-Cal Managed Care  
          Ombudsman, be disenrolled as an expedited disenrollment from his  
          or her managed care health plan effective the next business day  
          after the request is made. A beneficiary may request an  
          expedited disenrollment by telephone, in person, or  
          electronically online. The request shall be available for  
          submission by the beneficiary electronically online to reduce  
          administrative costs and increase access to medical services for  
          Medi-Cal beneficiaries.
             
          (2) A beneficiary who is disenrolled from the managed care  
          health plan in the county from which he or she moved pursuant to  
          paragraph (1) shall  receive services   be entitled to the full  
          scope of benefits for which he or she is entitled  in the new  
          county through the fee-for-services delivery system until he or  
          she is enrolled in a managed care health plan in the new county.

           SUPPORT AND OPPOSITION  :
          Support:  Coalition of California Welfare Rights (co-sponsor)
                    United Ways of California (co-sponsor)
                    Western Center on Law and Poverty (co-sponsor)
                    Asian Law Alliance
                    Bay Area Legal Aid
                    California Food Policy Advocates
                    Central California Legal Services
                    Community Health Councils







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                    County Welfare Directors Association
                    Courage Campaign
                    Disability Rights Legal Center
                    Hunger Action Los Angeles
                    Inland Empire United Way
                    Law Foundation of Silicon Valley
                    Legal Aid Society of Orange County 
                    LIUNA Locals 777 & 792
                    Maternal and Child Health Access
                    National Association of Social Workers, California  
               Chapter
                    National Health Law Program
                    North Coast Opportunities, Inc.
                    Nurse-Family Partnership
                    Orange County United Way
                    Project Inform
                    San Francisco AIDS Foundation 
                    The Children's Partnership
                    United Way of the Bay Area
                    United Way Fresno and Madera Counties
                    United Way Monterey County
                    United Way of Santa Cruz County 
                    United Way of Stanislaus County

          Oppose:   None received

          
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