July 13, 2023
The Honorable Phil Mendelson
Chairman
Council of the District of Columbia
John A. Wilson Building
1350 Pennsylvania Avenue, N.W. , Suite 504
Washington, D.C. 20004
Dear Chairman Mendelson:
Enclosed for consideration and enactment by the Council of the District of Columbia is the "DC
Health Care Alliance Enrollment Rulemaking Emergency Approval Act of 2023 ," along with an
accompanying emergency declaration resolution.
This legislation will approve proposed final rules of the Department of Health Care Finance to
implement a 12-month certification period for the DC Health Care Alliance ("Alliance")
program and require renewals to occur every 12 months. This change will remove barriers to
Alliance beneficiaries in maintaining health care coverage and create greater parity with
Medicaid eligibility requirements and processes.
If you have any questions regarding the proposed legislation, please contact Acting Chief of
Staff and Director of Health Care Policy and Research Administration, DHCF, Eugene Simms, at
(202) 427-1509.
I urge the Council to take prompt and favorable action on the legislation.
Sincerely,
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~k- at the request of the Mayor
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7 A BILL
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12 IN THE COUNCIL OF THE DISTRICT OF COLUMBIA
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17 To approve, on an emergency basis, rules governing the Health Care Safety Net
18 Administration to provide for implementation of statutory changes that extend the
19 certification period for Alliance program eligibility.
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21 BE IT ENACTED BY THE COUNCIL OF THE DISTRICT OF COLUMBIA,
22 That this act may be cited as the "DC Health Care Alliance Enrollment Rulemaking
23 Emergency Approval Act of 2023".
24 Sec. 2. Pursuant to section 7a of the Health Care Privatization Amendment Act of
25 2001, effective March 30, 2004 (D .C. Law 15-109; D.C. Official Code§ 7-1406), the
26 Council approves the proposed final rules of the Department of Health Care Finance that
27 were transmitted to the Council by the Mayor on [INSERT DATE] to amend Chapter 33
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(Health Care Safety Net Administration) of Subtitle B (Public Health and Medicine) of
29 Title 22 (Health) of the District of Columbia Municipal Regulations, regarding the Health
30 Care Safety Net Administration. A notice of proposed rulemaking was published in the
31 District of Columbia Register on March 3, 2023 , at 70 DCR 002725 .
32 Sec. 3. Fiscal impact statement.
33 The Council adopts the fiscal impact statement of the Chief Financial Officer as
34 the fiscal impact statement required by section 4a of the General Legislative Procedures
35 Act of 1975, approved October 16, 2006 (120 Stat. 2038; D.C. Official Code§ 1-
36 301.47a).
37 Sec. 4. Effective date .
38 This act shall take effect following approval by the Mayor (or in the event of veto
39 by the Mayor, action by the Council to override the veto), and shall remain in effect for
40 no longer than 90 days, as provided for emergency acts of the Council of the District of
41 Columbia in section 412(a) of the District of Columbia Home Rule Act, approved
42 December 24, 1973 (87 Stat. 788; D.C. Official Code§ l-204.12(a)).
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 DEPARTMENT OF HEALTH CARE FINANCE
NOTICE OF FINAL RULEMAKING
[as submitted to the Council of the District of Columbia for its approval pursuant to section 7a
of the Health Care Privatization Amendment Act of 2001 (D.C . Official Code§ 7-1406)]
The Director of the Department of Health Care Finance (DHCF) , pursuant to the authority set forth
in section 7a of the Health Care Privatization Amendment Act of 2001 ("Health Care Privatization
Amendment Act"), effective July 12, 2001 (D.C. Law 14-18; D.C. Official Code§ 7-1405(a)), and
section 6(6) of the Department of Health Care Finance Establishment Act of 2007, effective
February 27, 2008 (D.C. Law 17-109; D.C. Official Code§ 7-771.05(6)), hereby gives notice of
the adoption of amendments to Chapter 33 (Health Care Safety Net Administration) of Subtitle B
(Public Health and Medicine) of Title 22 (Health) of the District of Columbia Municipal
Regulations (DCMR).
Pursuant to sections 3 and 7 of the Health Care Privatization Amendment Act (D.C. Official Code
§§ 7-1401 and 7-1405), DHCF finances and monitors the health care and medical services that are
provided to District residents enrolled in the District of Columbia Health Care Alliance program
(Alliance program) through contracts with providers. The Alliance program provides
comprehensive health care and medical services to District residents ages twenty-one (21) years
and over, who have incomes at or below two hundred and ten percent (210%) of the federal poverty
level and are not otherwise eligible for or enrolled in Medicare, the Children ' s Health Insurance
Program (CHIP), or federally-funded Medicaid benefits.
The District recently updated its rules governing Alliance program eligibility to create parity with
Medicaid eligibility requirements and processes to the greatest extent possible. One of the major
changes included the removal of the interview requirement during applications and renewals .
However, the current rules governing the Alliance program retained the requirement for
beneficiaries to renew their eligibility every six (6) months; whereas, Medicaid rules require
beneficiaries to renew eligibility every twelve (12) months . Consistent with recent legislative
requirements under the Fiscal Year 2023 Budget Support Act of 2022, effective September 21,
2022 (D.C. Law 24-167; D.C. Official Code § 7-1407), DHCF is extending the Alliance
certification period to further align with Medicaid standards and require renewals to occur every
twelve ( 12) months beginning on October 1, 2022. These changes will remove barriers for Alliance
beneficiaries in maintaining health care coverage and create greater parity with Medicaid
eligibility requirements and processes. DHCF estimates that proposed changes in this rule will
result in an increase of five million, five hundred eighty-one thousand, eight hundred and eighty-
six dollars ($5 ,581 ,886) in total local expenditures in Fiscal Year 2023.
A notice of proposed rulemaking was published in the District of Columbia Register on March 3,
2023, at 70 DCR 002725 . No comments were received, and no changes have been made to the text
of the rule as proposed.
The proposed final rules were submitted to the Council of the District of Columbia, pursuant to
section 7a of the Health Care Privatization Amendment Act, effective July 12, 2001 (D.C. Law
14-18; D.C. Official Code§ 7-1406). The Council approved the rules through D.C. Act [INSERT
NUMBER], which became effective on [INSERT DATE].
The Director of DHCF took final action to adopt this rulemaking on [INSERT DATE], and the
rules shall become effective upon publication of this notice in the District of Columbia Register.
Chapter 33, HEALTH CARE SAFETY NET ADMINISTRATION, of Subtitle B, PUBLIC
HEALTH AND MEDICINE, of Title 22, HEAL TH, of the DCMR is amended as follows:
Section 3301 APPLICATION, REDETERMINATION, AND RENEWAL, is amended as
follows:
Subsection 3301.13 is amended to read as follows:
3301.13 Beginning on October 1, 2022, each Alliance program beneficiary shall renew
eligibility every twelve (12) months by submitting a renewal form to the
Department of Health Care Finance either in person, by mail, by other commonly
available electronic means, including by fax or online via web-based portal, or by
completing the renewal telephonically.
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 GOVERNMENT OF THE DISTRICT OF COLUMBIA
OFFICE OF THE ATTORNEY GENERAL
ATTORNEY GENERAL
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BRIAN L. SCHWALB
Legal Counsel Division
MEMORANDUM
TO: Beverly Perry
Senior Advisor
Office of Policy and Legislative Affairs
FROM: Megan D. Browder
Deputy Attorney General
Legal Counsel Division
DATE: January 4, 2023
SUBJECT: Legal Sufficiency Review of the "Alliance Enrollment and Financial
Eligibility Amendment Rulemaking Approval Resolution of 2022"
(AD-22-744C)
This is to Certify that this Office has reviewed the above-
referenced resolution and that we have found it to be legally sufficient. If you have any
questions in this regard, please do not hesitate to call me at (202) 724-5524.
Megan D. Browder
 Government of the District of Columbia
Office of the Chief Financial Officer
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Glen Lee
Chief Financial Officer
MEMORANDUM
TO: The Honorable Phil Mendelson
Chairman, Council of the District of Columbia
FROM: Glen Lee _ fj /) /}
Chief Financial O f f i c e p - /U e_
DATE: January 18, 2023
SUBJECT: Fiscal Impact Statement - Alliance Enrollment and Financial Eligibility
Amendment Rulemaking Approval Resolution of 2023
REFERENCE: Draft Introduction as provided to the Office of Revenue Analysis on
January 13, 2023
Conclusion
Funds are sufficient in the fiscal year 2023 through fiscal year 2026 budget and financial plan to
implement the proposed rules.
Background
The bill approves two proposed rulemakings by the Department of Health Care Finance (DHCF) that
make changes to rules for the District of Columbia Healthcare Alliance (Alliance) program.
The first rulemaking increases the Alliance eligibility period from six months of eligibility to twelve
months of eligibility. This increase will align the rules with eligibility period changes that were
included in the fiscal year 2023 budget. 1
The second rulemaking updates the Modified Adjusted Gross Income (MAGI) financial eligibility
requirements calculation methodology. With this change, the Alliance MAGI methodology will align
with Medicaid MAGI methodology.
The second rulemaking also aligns the Alliance program with upcoming Medicaid policy changes to
increase the reasonable compatibility standard for verifying electronic data sources when an
1 Fiscal Year 2023 Budget Support Act of 2022 , Subtitle V(C) , Alliance Enrollment Amendment Act of 2022,
effective September 21, 2022 (D.C. Law 24-167; 69 OCR 11937).
1350 Pennsylvania Avenu e, NW, Suite 203, Washington, DC 20004 (202)727-2476
www.cfo.dc.gov
 The Honorable Phil Mendelson
FIS: "Alliance Enrollment and Financial Eligibility Amendment Rulemaking Approval Resolution of 2023,"
Introduction as provided to the Office of Revenue Analysis on January 13, 2023
individual attests to their financial information. The District uses electronic data sources to verify
Medicaid and Alliance financial eligibility, and a reasonable compatibility standard to match financial
information obtained from federal and state electronic data sources with attested application
information. If an applicant's self-attested income is within the reasonable compatibility standard,
the applicant is not required to submit more documentation to be eligible to enroll in Alliance. The
proposed rule will increase the reasonable compatibility standard from ten percent to twenty
percent to be consistent with federal guidance on Medicaid.
Financial Plan Impact
Funds are sufficient in the fiscal year 2023 through fiscal year 2026 budget and financial plan to
implement the proposed rules.
Approving rules that extend the Alliance enrollment period from six months to twelve months does
not have an additional cost. The fiscal year 2023 budget and financial plan includes funding to
implement the enrollment extension. Updating the MAGI financial eligibility requirements
calculation methodology does not have a cost to the District. Approving rules that increase the
reasonable compatibility standard from ten percent to twenty percent will slightly increase the
number of Alliance beneficiaries enrolled in the program. The estimated cost of the additional
enrollees is $680,000 in fiscal year 2023 and $2.8 million over the financial plan. DHCF can absorb
these costs using savings realized from the extension of public health emergency enhanced Federal
Medical Assistance Percentage through the end of the calendar year and through growth included in
the financial plan. The agency also anticipates efficiencies from having the same reasonable
compatibility standard in place for Medicaid and Alliance enrollment, since the application and
renewal process will be more streamlined, although efficiency savings have not been quantified.
Alliance Enrollment and Financial Eligibility Amendment Rulemaking Approval Resolution of 2023
Total Cost
FY 2023 FY 2024 FY 2025 FY 2026 Total
Reasonable
CompatibilityCaJ $680,000 $691,000 $704,000 $716,000 $2,791,000
Table Notes:
(a) Assumes 1.75 percent cost growth.
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