States have broad latitude to determine how to handle the unprecedented volume of eligibility checks, including the ability to adopt several flexibilities granted by the Centers for Medicare & Medicaid Services (CMS), and leveraging Medicaid Managed Care Organizations (MCO) to support states and people.
States can consider adopting new CMS flexibilities, including two key flexibilities that may have the most significant impact in ensuring Medicaid-eligible Americans are not inappropriately disenrolled (i.e., for procedural or administrative reasons). States can:
1. Postpone disenrollments for one month before disenrolling someone for administrative reasons, giving the state and other appropriate stakeholders (e.g., providers, MCOs, navigators, and others) time to continue outreach to people and support them in completing the necessary paperwork.
- Protects children: Kids are likely disproportionately impacted by procedural terminations, as they are often eligible for coverage at higher household income levels than their parents or caregivers. Parents or caregivers at higher income levels may not realize their child is still eligible and not send in paperwork.
- Meets people where they are: Many Medicaid enrollees have never been through a renewal process and still aren’t aware they may lose coverage. Others face a variety of procedural barriers in understanding or fulfilling the verification requirements and have a difficult time accessing timely assistance.
- Saves state resources: States are required to re-instate people for 90 days after their coverage ends (the “reconsideration period”), if they prove they are still eligible. Simply postponing the disenrollment for one month prevents unnecessary gaps in coverage for people who remain eligible and would be able to re-enroll in Medicaid at any time anyway, but with much lower administrative burden to the state and enrollees.
- Easy to implement: States only need to get a simple waiver from CMS and ensure their eligibility system extends coverage for applicable individuals. The state continues to receive federal matching funds during the 30-day extension
2. Extend the reconsideration period past 90 days, giving people who lose coverage for procedural reasons additional time to re-establish eligibility, without having to start the application process from scratch.
- Protects children: Kids are likely to be disproportionately impacted by procedural terminations. This will help them get back
into the coverage that they are eligible for by reducing the paperwork burdens on parents and caregivers. - Meets people where they are: The rates of procedural disenrollments are much higher than predicted across many states. This will help people get back into their eligible coverage.
- Saves state resources: There’s less paperwork for people to fill out and for state employees to process. Although people may apply for and enroll in Medicaid at any time (continuous open enrollment), initial applications are much longer and require several verifications that aren’t necessary for renewal.
- Easy to implement: States only need to inform CMS via email and update eligibility systems to allow re-instatement for the longer time period.