How eligibility may look different in this bridging year

Medicaid partners and advocates can expect this year to be characterized by a bridging towards a post-unwinding, “new normal” in Medicaid eligibility operations. Program leaders are working to institutionalize lessons learned and best practices from the unwinding into core eligibility processes, like new ways of communicating with members, engaging community partners to support renewals, and improving automatic or “ex parte” renewal rates. At the same time, Medicaid programs will need to adjust eligibility operations to a size and scale that is sustainable as state budget realities tighten.

This will impact how members experience the eligibility process in four ways.

1. Processes and communications will continue becoming more member friendly. Through the unwinding, eligibility leaders have learned (and continue to learn!) an incredible amount about how to better support Medicaid members through the renewal process. For example, Medicaid programs used new strategies to keep contact information up-to-date and connect with members, such as through text messaging. Programs also took steps to make information more accessible to members, such as updating notices, upgrading online portals, and adding online tools so that Medicaid members can check their renewal date. Programs also made significant strides in strengthening their automatic or “ex parte” renewal processes. This means that more Medicaid members have their coverage renewed automatically and without having to complete paperwork. Medicaid partners can expect to see many of these efforts to continue – and evolve –to help make the eligibility process more member friendly.
2. Investments in outreach, staff, and contractor resources will need to be scaled to new budget realities. All states increased one-time spending to support the unwinding of continuous coverage. As state budgets tighten, Medicaid programs will not be able to sustain this level of investment without an infusion of new federal resources.  This scaling effort will be particularly notable with member outreach. Medicaid programs used comprehensive, multi-media campaigns to reach members in the months leading up to and throughout the unwinding of continuous coverage. These campaigns were historic in nature and scope. They included door knocking campaigns, billboards, subway advertisements, and even TV commercials during NFL games. As we emerge from this period, Medicaid members are unlikely to continue seeing mass media messages about Medicaid eligibility and renewals, and instead should expect traditional modes of outreach, such as mail, phone, text, or email.  Programs will also need to scale staff and contractor resources to the state budget realities. For most programs, staff and contractor resources were temporarily scaled up to support the much higher volume of renewals, such as bringing staff out of retirement, temporarily detailing staff to Medicaid from other state agencies, and adding auxiliary call centers. These measures were intended to be temporary to address the emergent nature of unwinding. That means Medicaid programs will have to scale back operations and return to more sustainable levels of staffing and contractor resources ongoing.
3. Eligibility systems will be re-programmed. IT systems work may not be top of mind for many of Medicaid’s partners, but it is essential to ensuring members have a smooth experience in this bridging year. During the unwinding of continuous coverage, eligibility IT systems have been operating under special rules that reflect temporary federal flexibilities. For example, many systems were reprogramed to allow additional sources of data to support automatic renewals, like data from SNAP and TANF, two human services programs that also have income-based eligibility. Under current guidance, these flexibilities will extend through at least December 31, 2024, and some flexibilities may continue longer. When these flexibilities end, Medicaid eligibility systems will have to be reprogrammed to follow normal federal requirements. Once this occurs, states will pressure test the systems and make sure eligibility workers are trained on the changes. This systems programming, testing, and training will take many months, and will need to be carefully layered with systems changes required to come into compliance with other federal requirements. For members, this return to normal federal requirements may mean that more people could have to complete a renewal next year, rather than having their eligibility automatically continued on an ex parte basis.
4. Policies and operations will evolve to meet new and recently illuminated federal requirements. The unwinding of continuous coverage surfaced areas of complex Affordable Care Act (ACA)-era eligibility policy where additional work is needed for programs to achieve full compliance. Most Medicaid programs will have to work with CMS to implement these compliance plans in the months and years after unwinding. This work will occur alongside efforts to implement new federal eligibility regulations, which CMS is releasing in two parts: part one was released in 2023, and part two is expected in spring 2024. These efforts are broadly aimed at streamlining the eligibility experience for Medicaid members, but they will require a significant investment of Medicaid programs’ resources to execute. Specifically, it will take time and financial resources to make the required IT system upgrades, as well as conduct the system testing and training that goes along with any such changes. Advocates and partners can expect Medicaid agencies’ efforts to start shifting to these priority areas of eligibility work.

This bridging year will look different than the flurry of public-facing activity we saw over the past year of unwinding. But the work Medicaid programs will be doing in 2024 and 2025 will be just as important as the work done to date to ensure eligible individuals retain their Medicaid coverage. Most importantly, in the return to the new normal, Medicaid programs will need the continued partnership of advocates, providers, plans, policymakers to ensure the front-door of Medicaid works effectively and efficiently for the members Medicaid serves.