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If a member loses Medicaid, either because they didn't get recertified or they no longer qualify, there is a grace period called a deeming period by CMS. During this period, you allow them to stay on the D-SNP plan, giving them the opportunity to either get reinstated if they qualify or conclude that they no longer qualify and then leave the plan. When I joined the organization during the pandemic, CMS sent out guidance on what to do for dual special needs plan members who seemingly lost their Medicaid eligibility. They also directed states not to terminate people from Medicaid. Some states complied and didn't terminate people, while others continued to do so. As a plan, you must ensure that you follow CMS guidance and don't remove people from the roll inappropriately. There was confusion between what the state was doing and CMS's guidance. We needed to ensure internally that we were following the guidance, ensuring members were not inappropriately removed, and honoring the deeming period. The same applies to members who move out of the area. Many people had to relocate due to needing care or help, or to live with a caregiver because of the lockdown. This was a significant issue that organizations, not just Molina, had to work through with those D-SNP populations.
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