Since the original publication of this blog, KidCare Expansion has been delayed until at least April 2024, as reported by the Orlando Sentinel. The initial delay was due to a failure to submit the application, called a 1115 waiver, on time. It has since been submitted with an updated structure of premiums that is different from those originally passed in 2023. Ultimately, these premiums are still costly to families, and do not align with new federal laws that require states to provide 12 months of continuous eligibility to children under 19 who are enrolled in Medicaid and the Children’s Health Insurance Program (CHIP), with no exceptions. The new law sets the precedent that families and children cannot be disenrolled for not paying premiums. In response to the new law, on Feb. 1, 2024, the state Agency for Health Care Administration, filed a lawsuit against the federal Centers for Medicare and Medicaid Services and Department of Health and Human Services, claiming that a new requirement “unlawfully undermines” the recent expansion of CHIP. This lawsuit may cause further delays beyond April 2024. Florida Policy Institute has issued a statement, and will continue to monitor this and advocate for solutions that quickly expand access to health care coverage for children in our state.
Introduction
During Florida’s 2023 legislative session, lawmakers unanimously passed House Bill (HB) 121, legislation that increases access to health care for children with low income in the state. The measure is broadly designed to increase the number of children who are eligible for subsidized health insurance by increasing the income limits and enabling more families to qualify. Florida’s Child Health Insurance Program (CHIP), also known as KidCare, covers children in families with incomes that are too high to qualify for Medicaid, and children in families with employer-sponsored insurance that may not cover those children. The changes to Florida’s CHIP program will enable 42,000 currently uninsured children with household incomes between 200 and 300 percent of the Federal Poverty Level (FPL) to get coverage with lower premiums.
Below is information that families should know about KidCare and the upcoming changes to the program under the new law.
What is Florida KidCare?
Florida KidCare is Florida’s Child Health Insurance Program (CHIP), which is comprised of four broad health insurance programs: Medicaid for Children, MediKids, Florida Healthy Kids (FHK), and Children’s Medical Services Health Plan.
Families who have an income that is too high to receive Medicaid but meet other income requirements can apply for one of these other subsidized insurance programs, which require a monthly household premium payment of $15 or $20 depending on the family’s income level. Families who have incomes that are too high to qualify for these subsidized monthly household premium payments can apply for a “full pay” program and receive coverage at a cost of $259.50 ($3,114 annually) per child enrolled in FHK, or $210.18 ($2,522 annually) per child enrolled in MediKids. As of January 2023, there are over 117,000 children enrolled in KidsCare's subsidized programs.
What is Changing Under the New Law?
The new law (HB 121) increases the income limits for families enrolled in KidCare’s subsidized programs so that more families can get coverage, and it adds more tiers of payment levels for a more gradual increase to the full-pay components of the program. Specifically, it increases the levels from 200 percent FPL ($49,720 for a family of three) to 300 percent FPL ($74,580 for a family of three). The new law also requires that FHK establish at least three and no more than six premium “tiers” for families above 150 percent FPL ($37,390 for a family of three). This means that instead of paying $15 or $20 per month for the household, then seeing a jump to $259 per month for each child, eligible families would pay household premiums that start at $17 then increase to $38, $64, $94, $139, and end at $170. This will all depend on a family’s income level and household size.
The new law (HB 121) increases the income limits for families enrolled in KidCare’s subsidized programs so that more families can get coverage, and it adds more tiers of payment levels for a more gradual increase to the full-pay components of the program.
The table below reflects the structure of the new tiers, which are scheduled to take effect on January 1, 2024. However, as reported in an Orlando Sentinel article from December 2023, the expansion has been delayed until April 2024. These tiers were generated from a fiscal analysis conducted by the Florida Healthy Kids Corporation.
The new law also reduces the burden of paperwork on families. KidCare requires that a family’s eligibility for the program is checked every 12 months. A change in these provisions reduces the amount of paperwork families must complete through a process called ex-parte renewal, where the state uses outside data sources, such as income taxes or participation in other federal programs like SNAP, in accordance with federal requirements to automatically check and re-enroll families in the program. Only if the state is unable to verify income through electronic means would a family need to submit proof of family income and a statement from all applicable employed family members, which would detail whether their employers sponsor health insurance, the child does not qualify for the employer’s health insurance plan, or the health plan costs more than 5 percent of the family’s income.
Increased Eligibility and Reduced Paperwork is a Step in the Right Direction
Historically, small changes in income have forced families to go from paying a premium of $15 or $20 per month for the household to paying $259 per month per child enrolled in the program. The burden of paying high premiums often contributes to families choosing to forgo insurance or cover only their most medically needy children. By increasing income eligibility in Florida, 42,073 children will now qualify for subsidized payments instead of the full-pay option and receive health insurance coverage for a cheaper cost.
Reducing paperwork and completing automatic renewals can free families from losing their coverage by reducing the number of administrative burdens or hurdles they must overcome to verify their eligibility. When state agencies do not automatically renew coverage, families are more likely to lose coverage because they may have moved or are unable to respond to requests for information in a timely manner. This can be because they may have trouble understanding notices or cannot reach a call center for help.
Questions Remain on New KidCare Eligibility
It is crucial to ensure that families have access to accurate and understandable information. Historically, it has been complicated for families to know their true eligibility for Florida’s KidCare program due to its complexity and fragmentation. Part of the complexity has been how the state reports the income limits that do not align with the federal income limits for receiving subsidized premiums. For example, the 2023 Florida KidCare table specifies that families with income above 200 percent FPL do not qualify for subsidized CHIP, and must pay the full cost of the monthly premium. This is misleading. Because of changes made by the Affordable Care Act, these income limits are higher. In a January 2023 presentation to Florida’s House Healthcare Regulation Subcommittee, FHK reported that the eligibility income limit is actually an upper limit of 210 percent the FPL, and with an additional 5 percent standard given to some families, this creates an effective upper limit of 215 percent of the FPL. Simply stated, this means that if a family of three had an annual income higher than $49,720 (200 percent FPL in 2023) they would assume that they were not eligible for subsidized payments, even though they could be making up to $53,449 ($3,729 more than the state’s published limit) and still qualify.
Historically, it has been complicated for families to know their true eligibility for Florida’s KidCare program due to its complexity and fragmentation.
In addition to this, the state is required to look at monthly income levels yet publishes these documents with annual income levels. Workers paid low wages who may be experiencing monthly fluctuations in household income may be deterred from applying, even though their families may qualify.
With the upcoming changes to Florida’s CHIP program, FHK should ensure that the public-facing documentation clearly and concisely provides the most accurate information on the new income limits.
It is unclear whether the proposed premium structure is the most equitable approach for ensuring that families can pay for their children’s health coverage. A growing body of research has shown that even small premium charges from $1 to $5 for families with low income can be a significant burden that is also associated with families forgoing care. Premiums that start at $17 and range to $170 for Floridians can potentially contribute to additional hardship for families and should be evaluated when moving forward with the new KidCare Program.
Additionally, implementing six tiers of premium payments may cause undue administrative hurdles. There will be more categories of eligibility to consider, and again, because these small income changes trigger premium payments that more than double the cost per category, it is important to ensure that the Department of Children and Families and Florida’s Agency for Healthcare Administration are equipped with the proper technology and staff to smoothly roll out these changes.
Overall, this change to CHIP is positive in that more families will have access to care. It will be important to monitor and evaluate family experience and premium payment once the program launches.
