Advocating for Increased Access to Healthcare for Immigrants

CareFirst BlueCross BlueShield submitted comments on a Federal proposed rule that, if finalized, would expand access to healthcare coverage for Deferred Action for Childhood Arrivals (DACA) recipients. The proposed rule amends the definition of “lawfully present” for the purposes of Medicaid and Affordable Care Act (ACA) coverage.

Legal status is a key determinant of an immigrant’s access to social services, jobs that provide benefits and health insurance. 65% of undocumented immigrants do not have health insurance, compared to 32% of permanent residents. Undocumented immigrants experience adverse health outcomes related to their high risk of being uninsured and often receive lower quality of care. They have limited access to employer-sponsored insurance and face eligibility restrictions that prevent them from purchasing individual health insurance plans offered through an ACA Marketplace or enrolling in Medicare, Medicaid or the Children’s Health Insurance Program.

Timely use of healthcare services is associated with better health outcomes. Inadequate health insurance coverage is one of the largest barriers to healthcare access, which leads to individuals delaying or forgoing needed medical care. Uninsured adults are less likely to receive preventive services for chronic conditions, such as diabetes, cancer and cardiovascular disease. Similarly, children without health insurance coverage are less likely to receive appropriate treatment for conditions like asthma or critical preventive services, such as dental care, immunizations and well-child visits that track developmental milestones. Expanding the definition of “lawfully present” to include DACA recipients will open eligibility for insurance affordability programs, such as premium tax credits and cost-sharing reductions, which will increase access to Marketplace plans.

As states resume Medicaid eligibility redeterminations, it is estimated that between five and 14 million individuals could lose Medicaid coverage nationwide. Given this context, it is a key priority to make every effort to reduce the overall uninsured rate. It is also critical to ensure outreach materials are culturally competent and offered in multiple languages so this rule can have maximum impact in improving access to care for this population.

CareFirst also voiced support for an effective date of November 1, 2023, to align with the Marketplace Open Enrollment period, as doing so would further encourage enrollment by leveraging existing outreach activities already occurring during this time period.

CareFirst strongly believes all people, regardless of race, ethnicity or citizenship status, deserve access to quality, affordable healthcare and supports this proposed rule as it clearly demonstrates a commitment to health equity for all.

Supporting Materials - For More Information About the Proposed Rules, Read Below

CMS Fact Sheet on Proposed Rule

The above is a link to a fact sheet from CMS describing the rule, clarifying that under the proposed change, DACA recipients would be treated the same as other deferred action recipients for the purposes of eligibility for these CMS insurance affordability programs. The fact sheet also details additional impacts associated with the proposed rule, if finalized.

U.S. Department of Health and Human Services (HHS) Press Release on Proposed Rule

The above links to a press release from HHS and underscores the Biden Administration’s efforts to promote health equity.

Key Facts on Deferred Action for Childhood Arrivals (DACA)

This article provides an overview of DACA, who DACA recipients are, and key demographic information about DACA recipients, such as health, uninsured rates, work status and income. Of note, the article highlights that DACA recipients currently are not considered lawfully present for purposes of health coverage eligibility, leaving these individuals with limited options for any form of healthcare. The article also highlights the proposed rule, indicating that it would likely reduce uninsured rates among DACA recipients and enhance financial protections from medical costs. While the expansion would increase federal and state costs, the number of individuals who would become eligible is limited. Additionally, this expansion would help alleviate state cost burden in states that provide state-funded coverage to individuals regardless of immigration status.