This article originally appeared in Bloomberg Law on January 20, 2023.
State Medicaid programs are racing to make sure they are prepared to help as many people as possible retain health coverage once income eligibility checks resume in the coming months.
They are working to ensure that they’re not only in compliance with provisions of the Consolidated Appropriations Act—which includes new reporting requirements, funding conditions, and tools to promote coverage retention—but that they also have the infrastructure necessary to handle the 5 million to 14 million people who could lose their Medicaid coverage.
This flurry of activity comes as the April 1 deadline looms for states to resume eligibility checks. Medicaid rolls grew by nearly 20 million people during the pandemic, due in large part to the Families First Coronavirus Response Act’s continuous coverage requirement. The law served as a de facto moratorium on eligibility redeterminations during the Covid-19 public health emergency.
For months, states have looked to Washington for answers on what to do when the public health emergency and the 6.2% increase in the federal match rate for states who comply with continuous coverage requirements eventually come to an end.
In December, state Medicaid programs finally got their answer with passage of the Consolidated Appropriations Act, a law that lays the groundwork for a transition back to pre-pandemic Medicaid eligibility requirements.
Low-income individuals are eligible for Medicaid if they make less than an income limit set by individual states. Children whose families earn more than that can receive coverage through the Children’s Health Insurance Program.
So far, agencies have focused on bolstering their communications infrastructure to curtail a loss of coverage due to logistical reasons, such as failing to complete or receive eligibility forms.
For example, Michigan’s Medicaid agency has set up action teams to ensure that individuals with Medicaid coverage remain eligible.
These action teams are collaborating with health plans, community mental health organizations, and other partners to assist residents who will be affected by any changes in their Medicaid coverage, said Lynn Sutfin, director of communications for the Michigan Department of Health and Human Services.
The state has also set up a web portal to keep Michigan residents up to date with information related to their Medicaid benefits.
Attention on Automatic Enrollment
A major part of states’ communications overhaul will be fortifying automated enrollment systems, Jack Rollins, director of federal policy for the National Association of Medicaid Directors, said.
“The more that states can maximize the success rate of the automatic enrollment process, the more that state will be able to alleviate the workload on those frontline eligibility workers, which is pretty important because what our members are trying to gear up for is having sufficient staffing and resources,” Rollins said.
Automatic enrollment, also known as “ex parte” renewal, uses demographic information from third parties like the Supplemental Nutrition Assistance Program (SNAP) to determine eligibility for Medicaid, circumventing the need for individuals to file paperwork with state Medicaid agencies.
Automatic renewals are essential for state strategies because they can help redirect resources used to pursue policyholders to other areas of the agency’s communications infrastructure like call centers dedicated to eligibility and enrollment actions, Rollins said.
Call Centers a Choke Point
Call centers have traditionally been a choke point for Medicaid recipients looking to retain their eligibility, with long wait times often causing them to abandon their inquiries and lose coverage.
A key part of states’ preparation once redeterminations begin will be monitoring call center statistics to avoid long wait times and staff burnout, said Tricia Brooks, research professor at the Georgetown Center for Children and Families.
“States have indicated they are finding it difficult to recruit and retain eligibility and call center staff,” Brooks said. “With an insufficient capacity to handle demand, staff can burn out quickly.”
“Monitoring call center data and taking mitigation steps if the workload becomes unmanageable can help avoid exacerbating the staffing shortage,” she said.
To prepare for the inevitable wave of call center inquiries, Congress included provisions in the Consolidated Appropriations Act to ensure customer service transparency by introducing monthly call center reporting requirements.
The law requires state Medicaid programs to report average wait times, call center volume, and abandonment rates.
The Consolidated Appropriations Act also grants the CMS the authority to police states failing to comply with the reporting requirements, Brooks said.
“If they’re not reporting the data that they’re supposed to be reporting, then CMS can step in and require the state to submit a corrective action plan,” she said. “And if the state doesn’t implement that corrective action plan, then CMS can require the state to stop disenrolling people for non-eligibility reasons.”
Steps by CMS
This strategy is just one of many actions that CMS is taking.
The agency laid out a timetable earlier this month for states preparing to resume eligibility checks.
It also recently released guidance for Medicaid programs and their managed care organizations (MCOs) to identify and reach out to patient populations most at risk of losing coverage.
One of the biggest steps in helping people maintain coverage will be tracking down beneficiaries whose address has changed since the last time they applied for Medicaid.
“We want to make sure that states are working with the health plans to reach out to those individuals using information the state would not have access to in order to help make sure those folks maintain their Medicaid coverage,” a senior HHS official told Bloomberg Law.
To better facilitate this strategy, the CMS will work with states and MCOs to move former beneficiaries into plans that meet the coverage requirements of the Affordable Care Act.
The agency also said it was contacting state Medicaid directors for individual meetings on systems readiness starting this week.