Commonwealth Care, Medical Security Program & Seasonal Workers: A Challenging Maze

With the seasonal employment swing on Cape Cod, we and our patients are lost in the maze of Commonwealth Care and Medical Security Program (MSP) enrollment. There are new applications, coverage gaps, frustration and confusion at every turn. Perhaps those of you on the North Shore and in the Berkshires are having a similar experience.

Typical seasonal employees here on the Cape work between April/May and September/October and collect unemployment compensation for up to 26 weeks during the winter. While seasonal employees are working, they may be eligible for Commonwealth Care. Once they begin to collect unemployment, however, they are technically ineligible for CommCare and are supposed to enroll in the Medical Security Plan instead. A seasonal worker may switch between CommCare and MSP up to four times a year. Unfortunately, this switch sounds simpler to make than it actually is.

Last week, I had a patient who mailed in the MSP application the day after opening her unemployment claim at the end of September because she knew she was about to lose her CommCare eligibility. In turn, she received a denial from Medical Security Program because she had Commonwealth Care. We learned through her experience that MSP is requiring a termination letter from CommCare before considering an application, even though the state denies CommCare to anyone collecting unemployment.

The MSP representative referred her back to her CommCare plan for a termination letter. Her plan referred her back to Commonwealth Care customer service, who referred her back to the MassHealth Enrollment Center (MEC). Assuming that everything goes as smoothly as possible and there is no further confusion, the patient will wait up to 4 weeks for MSP to reprocess her application. The coverage is retro-active to the opening of her claim, but she will not have a card to receive services until the application is processed. In the meantime, her CommCare has been terminated and the patient is left with an enormous amount of frustration and a coverage gap during which she can get only Partial Health Safety Net (HSN).

In the spring, when she returns to work and reports her earnings—ideally within the first two weeks—the MEC will take another two weeks to process the change. Since Commonwealth Care coverage starts on the first day of the month after her first premium check is received, rather than the date of application, she may have to wait up to eight weeks after losing MSP coverage to be re-enrolled in CommCare.

Seasonal workers are required to switch coverage types more frequently if they have to re-open their old unemployment claims in the fall until their benefits are exhausted (during which time they’re MSP-eligible). This is followed by the requisite waiting period before opening a new unemployment claim (now they’re CommCare-eligible), the opening of a new unemployment claim (back to MSP-eligible again), and finally, going back to work in the Spring (when they become CommCare-eligible once more). In cases like this, a seasonal employee becomes subject to a gap in coverage between the two programs four times a year.

Some patients are even willing to pay their CommCare premium while on unemployment just to avoid the on-and-off-again insurance coverage, but do not seem to be permitted to do so. They should be. Scheduled appointments, referrals, procedures, and continuity of prescription therapy are all undermined by the inconsistent coverage.

The best strategy that I have developed so far is to encourage our patients to sign up for MSP AND complete their annual eligibility review (ERV) for CommCare as it comes due, so that at least Health Safety Net (HSN) or Partial HSN may fill the coverage gap(s) and be in place when they receive their last unemployment check in the spring and before they can re-start the CommCare enrollment process. Does anyone else have a plan to make this very complicated system function better?