The end of COVID-19 PHE: “table stakes” for data and IT to keep coverage gains | Manatt, Phelps & Phillips, LLP

Editor’s Note: In a new briefing note prepared for the Robert Wood Johnson Foundation’s State Health and Value Strategies program, Manatt Health examines the “tabletop issues” of the information technology (IT) system of Medicaid agency and the state’s Children’s Health Insurance Program (CHIP). which will have the greatest impact for states seeking to ensure that eligible enrollees are able to retain or switch to new affordable health coverage when federal continuing coverage requirements end. If adopted, these strategies will also allow states to dramatically improve Medicaid / CHIP enrollment and maintenance of long-term coverage for those eligible for government-subsidized health coverage. The highlights of the briefing note are summarized below. Click on here to download a free copy of the complete dossier.

After the continuous coverage requirements expire, states will resume normal eligibility and enrollment activities for all Medicaid and CHIP enrollments. The volume of redetermination activity expected at the end of the public health emergency (PHE) is unprecedented. Throughout the pandemic, every state has seen an increase in enrollments (totaling 10.5 million new Medicaid / CHIP enrollments, a 14.7% increase from 2019),1 while having suspended regular eligibility and registration operations for the more than 70 million people who already had health coverage through Medicaid / CHIP. As a result, many registrants have not gone through the reassessment process for almost two years, and some have never had to reassess their Medicaid eligibility because they signed up during the pandemic.

The triple threat of unprecedented volume, a condensed period of time, and customers unfamiliar with redetermination processes associated with existing IT and data limitations pose a significant risk of loss of coverage after the PHE ends. State and federal operators and administrators now have the opportunity to pursue the following set of ‘table stakes’ strategies to upgrade and improve data quality and IT system capacity to prepare for this major coverage event and ensure retention and continuity of coverage.

State IT table stake strategies

Effective re-determination begins with full registrant contact details, user-friendly ways for individuals to update critical information, and standardized data definitions with partners. Three IT efforts are at stake to meet these needs: adopting a more effective and efficient use of data, improving the quality of account transfer data, and expanding the capabilities and capacity of online portals. States that have not continued these efforts, or have more to do to improve functionality, can undertake system improvements now and perform in a manner that allows them to receive the 90 percent federal match for IT investments. of Medicaid.

Table stakes strategy # 1: Adopt more effective and efficient use of data

Under federal law and regulation, state Medicaid agencies must use all available data to renew eligibility before requesting additional information from the individual.2 However, given the increase in the number of new recruits and the nearly two-year hiatus on reassessment activity, it is likely that state Medicaid agencies will not have the most recent information on their recruits. Accessing data through new partners and sources can help fill these gaps.

States can deploy a creative approach to master data management before the end of the PHE by first aligning with the minimum underlying data that is needed (e.g. first name, last name, e-mail address). mail, mobile phone number), determining which systems and partners have the most up-to-date versions of this data, and prioritizing data import based on feasibility (e.g. time to set up agreements data sharing, the technical complexity associated with importing).

Seeking the most recent information may force states to consider non-traditional partners and data sources within ministries of health or social services, with partners in managed care, or with other external data sources. The broadening of the master data management approach from present until the end of the PHE could allow States to broaden the openness of the data source and evolve to a more modern base that can integrate both structured and unstructured data.

Table stakes strategy # 2: Improve the quality of account transfer data

As states re-determine eligibility, it is likely that higher volume than usual will need to be transferred to the Federal Government Facilitated Market (FFM) due to changes in eligibility or of circumstances. To minimize gaps in coverage and better manage case response, States will need to ensure that transfers not only work from a technical standpoint, but also contain sufficient information for processing. Additionally, although the data currently provided may pass the Technical Account Transfer Scheme to the Federal Data Services Hub, optional fields, such as consumer email address and mobile phone number, will be of importance. crucial to include wherever possible. In fact, the Centers for Medicare & Medicaid Services (CMS) guidelines require states to “include all information collected and generated by the state.”3 In states operating their own state-based exchanges where Medicaid and the exchange do not share an eligibility system and / or case management system, similar challenges may arise.

States have the opportunity to identify and improve account transfer data quality issues in two dimensions:

  1. Completeness of address data: In order for accounts to be successfully transferred to the FFM, a minimum data set must be present.4 States can assess outgoing accounts that have historically failed the initial account transfer, identify the data elements that most often caused that failure, and prioritize correcting those inconsistencies.
  2. Update systems to include additional contact information fields: Some states may not have updated their computer systems to include optional contact information with outgoing account transfers, such as cell phone numbers and email addresses. Resolving gaps in these areas may be simpler technical changes for states already collecting this information and could allow the FFM to take more rapid action to contact transferees after a determination of overage for Medicaid / CHIP.

Table stakes strategy n ° 3: Developing the capacities and capacity of online portals

Mobile access to apps and online accounts not only makes it easier to engage with registrants, but can also dramatically reduce the workload for state and county agencies, allowing social workers to focus on registrants who need more intensive in-person / live assistance. A growing number of states are offering mobile access to online apps and accounts, funded at least in part by enhanced Medicaid matching funds. As of January 2020, individuals can submit applications online via a mobile device in 44 states, up from 28 states in 2017.5 Recognizing the importance of this digital tool at the end of the PHE, States may want to ensure that their portals meet three key criteria:

  1. Portal accounts are easy to create and access.
  2. Portals have the most critical eligibility and registration features, including two key online portal features: the ability to upload verification documents and view member reviews.
  3. The portals are supported by an IT infrastructure capable of handling high volumes.


While difficult, the end of federal continuing coverage requirements and the unwinding of related policies may provide a unique opportunity for states to not only meet the challenge and maintain the coverage gains recorded during the pandemic period, but It also takes a seismic step towards a modern technological evolution and approach to Medicaid eligibility and enrollment that better serves individuals through more efficient data sharing, data management and technology solutions.

1 Kaiser family foundation, Analysis of recent national trends in Medicaid and CHIP enrollment.

2 42 CFR § 435.916.

3 CMCS Information Bulletin, Coordination of eligibility and enrollment between Medicaid, CHIP and the federally facilitated marketplace (FFM or “Marketplace”).

4 CMS Office of Information Services, Federal Data Services Center (Federal DSH).

5 Kaiser Family Foundation, Medicaid and CHIP eligibility, enrollment and cost-sharing policies as of January 2020: survey results in 50 states.

About Florence L. Silvia

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