Policy and Process Changes
Memorandums of Understanding (MOUs) between state agencies
In 2004, the Department of Health Services (DHS) and the DOC in Wisconsin established their first MOU related to developing processes to allow eligible incarcerated individuals to enroll in Medicaid prior to release.
The MOU was updated in January 2015 with revised language to reflect changes to the state’s Medicaid program and in the procedures for processing incarcerated individuals’ applications. The updated MOU describes each agency’s roles and responsibilities, such as how DOC facilities will designate ACA site coordinators to address specific needs and how DHS will monitor and resolve any issues related to the enrollment process.
Eligibility Determination Changes
The Department of Health Services (DHS) implemented a new policy of allowing incarcerated individuals with explicit dates of release to apply for health coverage prior to release. Additionally, the DHS revised existing policy to allow for Medicaid eligibility to begin the day prior to an individual’s release from incarceration. DHS reported that they specifically selected the 20th of the month prior to the month of release as the date that individuals could apply for coverage in order to increase the likelihood that there was an adequate amount of time for the Medicaid card to be mailed back to the correctional facility prior to the individual’s release date.
Application Process Changes
In November 2014, the DHS issued a memorandum developed in conjunction with the DOC that builds on the MOU between the two agencies and provides further detail about the roles and responsibilities of each. The operations memo describes new processes for accepting telephonic Medicaid applications from incarcerated individuals. The new policy allows individuals with explicit dates of release to apply for health coverage on or after the 20th day of the month prior to the month of the individual’s scheduled release date. This allows enough time for the Medicaid card to arrive at the correctional facility. Individuals are able to apply via phone and can telephonically sign the application. The memo also provides guidance to the DOC regarding the length of time permitted for the individual to complete the application via phone and for providing application assistance. Additionally, the memo eliminates the need to verify prison income for these applications being submitted by incarcerated individuals and it provides instructions for verifying certain eligibility information and issuing identification cards.
In terms of implementing the processes at the correctional facilities, the DOC recognized that their reentry social workers already had many tasks and so the department focused on implementing streamlined procedures with minimal staff involvement. Some facilities use the regular phone system but others have set up special conference rooms or call booths for greater privacy for individuals who are calling to apply for coverage. Also, the DOC indicated that there are ACA “site coordinators” at the correctional facilities who serve an important role in the internal implementation of the telephone enrollment processes at each facility and address any questions related to enrollment in health coverage.
Enrollment as Part of Pre-Release Planning
Medicaid Enrollment Education/Training for Incarcerated Individuals
In many Wisconsin prisons, approximately one month prior to release, incarcerated individuals attend a one-hour long group session specifically focused on enrollment to prepare them to submit applications by phone. Four online modules are used to train DOC staff to facilitate the session.
In all Wisconsin prisons, corrections staff screen incarcerated individuals who may fall into one or more of the four categories potentially indicating a need for application assistance: those with 1) mental health issues; 2) lower reading scores; 3) language barriers; and/or 4) developmental disabilities. If an individual is identified as falling within one of these categories, social workers screen further to determine if the inmate can complete the telephonic enrollment application independently. If they cannot, the social worker facilitates the call process. The social workers are employed by the DOC, which also rotates three additional contracted benefits specialists between six DOC facilities who schedule and facilitate calls with incarcerated individuals at those six facilities.
Health Literacy Materials
The DOC developed and distributed informational pamphlets [add link to WI – 3] designed to help answer general questions related to health coverage through both Medicaid and the marketplace, as well as ways to access care.
Access to Care
State officials emphasized the importance of ensuring that individuals connect with health services quickly after release from incarceration, in particular to avoid gaps in prescription use. Correctional facilities in Wisconsin begin the enrollment process early in order to ensure that there is enough time for a Medicaid card to be mailed to the prison so that individuals have the card in their possession upon release. Currently, individuals are provided with two weeks of prescription medications on the day of their release, with a written prescription for another two-week supply.
Cross-Agency Coordination and Partnerships
Both the Department of Health Services (DHS) and the DOC indicated that they had an effective and established partnership and this was a key factor to the successful implementation of enrollment procedures for incarcerated individuals. The departments attributed the success of the partnership to good communication between the two agencies, support from both departments’ leadership, involvement of the appropriate staff from both agencies in the discussions, and taking time to carefully plan and think through the key issues. The agencies also attribute the success to existing working relationships between the two departments in the years prior to the implementation of the enrollment processes in correctional facilities. For example, DOC social workers conducting release planning had been sharing information with incarcerated individuals reentering the community, but had not been able to link them directly to those programs until after they were released. Also, there is a facility administered by DHS and staffed partially with DOC security employees, the Wisconsin Resource Center, which is a secure and specialized facility that houses incarcerated individuals with acute mental health issues to provide treatment and care for these individuals.
In addition to the strong partnership between DHS and DOC, connections with local entities are also working well. Wisconsin’s Medicaid is locally based and eligibility offices are administered through groups of counties called consortia. While efforts to implement enrollment processes in local jails are in the early stages, DHS indicated that they have monthly meetings with the consortia to maintain effective communication channels, and the DOC has provided information to local jail administrators about possibilities for implementing more formalized enrollment procedures in these facilities. Both DHS and DOC indicated that because prior to the ACA many local jails would refer potentially eligible individuals reentering the community to connect with local income maintenance offices to apply for coverage, these existing community-based relationships provide a promising foundation to establish more formal local-level enrollment efforts.
Looking Forward: Future Issues to Address
The state is pursuing a method to track the number of justice-involved individuals enrolling in coverage via the established telephonic application process. Title 32 U.S.C. § 405(c)(2)(C)(i) limits the state in its release of complete Social Security numbers (SSN) unless it is for “the administration of any tax, general public assistance, driver’s license, or motor vehicle registration law within its jurisdiction.” Consequently, the DOC may only release the last four digits of the SSN to the Department of Health Services. They may then match the individuals’ names, dates of birth, and last four digits of the SSN to analyze Medicaid enrollment data and share information with the DOC for the purposes of tracking recidivism and how that may correlate with enrollment. In addition, this system also allows for better tracking of the application rates at each correctional facility.
Policy and Process Changes