COVID-19 Response Recommendations for Illinois Governor

By Legal Council | March 13, 2020

March 13, 2020

Dear Governor Pritzker,

Thank you for your leadership on protecting Illinois residents from the spread of COVID-19. We appreciate the steps the administration has taken to ensure that healthcare coverage for testing is affordable and available for all Illinois residents. We believe that there are more critical steps that must be taken as soon as possible to ensure the health of our most vulnerable and at-risk populations.

On behalf of Protect Our Care Illinois and the undersigned organizations, we recommend that you implement the following policies to protect the health and well-being of our state:

Acquire additional testing capacity:

A proper response to the COVID-19 emergency demands far greater testing capacity. We urge the Administration to work with the federal government and other states to explore all possible avenues for additional testing supplies and capacity.

Use all available federal resources and tools:

The declaration of a national emergency by the Trump Administration unlocks billions of dollars from the disaster fund managed by the Federal Emergency Management Agency. Illinois must make use of these resources to the fullest extent to support our state and local emergency response.

Expand access to comprehensive health coverage:

Suspend Medicaid redeterminations and cancellations for April and May and reassess continuation of these suspensions in mid-April. The state does not need to seek any special federal approval to waive the timeliness standard due to the COVID-19 emergency. The state may also submit a formal plan under a Section 1135 Waiver thanks to the declaration of a national emergency by the President.
Immediately approve or provide Temporary Medicaid to all Medicaid applications delayed more than 45 days.
Expand presumptive eligibility to all qualified Medicaid applicants including adults. Allow self-attestation for eligibility verification and provide immediate presumptive eligibility to those applying for Medicaid coverage.
Advocate to the Centers for Medicaid and Medicare Services (CMS) to establish a special enrollment period for HealthCare.gov, the Illinois ACA Marketplace.

Eliminate barriers to obtaining needed testing or treatment:

COVID-19 testing, diagnosis, and treatment are all covered under Essential Health Benefits but cost-sharing and out of pocket costs could prove to be a barrier. The state should eliminate cost-sharing for both testing and treatment in the Medicaid program and should mandate that private payers do the same. This should apply to all public and private plans regulated by the state.
Suspend Medicaid MCO in-network and prior authorization requirements for COVID-19 testing, treatment, and services for any associated chronic health conditions.
Mandate that free charity care be provided to any uninsured Illinoisans seeking testing or treatment for related symptoms. Monitor the policies at hospitals and health clinics to ensure that lack of health coverage is not a barrier to care.

Facilitate social distancing:

Eliminate any unnecessary requirements for telehealth services in the Medicaid program. The state should actively promote telehealth for routine primary care and behavioral health visits and conduct an analysis of what administrative requirements can be waived during this crisis. Some changes may require a State Plan Amendment or Section 1135 Waiver in the event of an emergency declaration but expanding telehealth as a service delivery method is essential.
Direct private plans to promote the use of telehealth services and reduce administrative barriers.
Require all insurers and Medicaid to cover 90 days of medications for all insured and Medicaid recipients. When applicable, allow for and encourage use of mail order pharmacy services.
Implement requirements for paid sick time for all employees across the state.
Ensure young adults whose colleges have closed do not lose access to stable food and housing during the crisis.

Attend to vulnerable populations:

Pay special attention to institutionalized populations (e.g., group home residents, nursing home or long-term care facility residents and incarcerated individuals) who are at high risk of complications due to COVID-19. Ensure that policies are in place to provide ongoing services to those who are quarantined either at home or in an institutional setting.
Provide additional protections to pregnant and postpartum individuals.
Update infectious disease policies at nursing homes and other institutional settings.

Promote equity in our response:

Craft all programs with vulnerable populations in mind, including homeless and undocumented individuals. Communicate with tailored messaging to these and other populations around the urgency of seeking care and provide assurances they will be held harmless when they do seek care with respect to both cost and immigration status.
Ensure our response is equitable towards those who have less access to digital communication, health resources, and health coverage. Individuals with additional resources should not receive preferential treatment during this pandemic.

This is an unprecedented time and we must all band together to overcome the challenges we face. These policies represent a step towards coming together as a state to mitigate these difficulties and look after one another. Please consider these and any other steps that put the health and well-being of our neighbors first.

If Protect Our Care Illinois can be of assistance, please do not hesitate to reach out. You can contact Stephanie Altman at stephaniealtman@povertylaw.org, Dan Rabbitt at drabbitt@heartlandalliance.org or Logan Charlesworth at lcharlesworth@heartlandalliance.org for further information about these recommendations or to get in contact with other members of the coalition.