Editor’s Note: At the end of the public health emergency (PHE), people currently enrolled in Medicaid and the Children’s Health Insurance Program (CHIP) are at risk of losing their coverage unless state Medicaid/CHIP agencies take steps to update enrollee mailing addresses and other contact information. In a new expert perspective for the Robert Wood Johnson Foundation’s State Health & Value Strategies program, summarized below, Manatt examines the information technology (IT) system, policy and operational strategies states can consider to update key enrollee contact information and ensure eligible enrollees are able to keep or transition to new affordable health coverage at the end of the PHE. Click here to read the full expert perspective.
Currently, states are maintaining continuous enrollment of all Medicaid enrollees as a condition of receiving enhanced federal funding under the Families First Coronavirus Response Act (FFCRA).1 Many states have also paused renewals and disenrollments for their CHIP enrollees.2 States’ authority to maintain continuous coverage for Medicaid/CHIP enrollees is currently slated to expire at the end of December 2021, when the federal COVID-19 PHE ends.3
State eligibility renewal processes rely heavily on communication with enrollees by mail.4 Long-standing challenges with maintaining accurate enrollee mailing addresses will be particularly acute at the end of the PHE because, in most states, enrollees have not had contact with the Medicaid/CHIP agencies in over a year and therefore had no opportunity to update address information. Additionally, housing instability has become more prevalent among lower-income individuals and families during the pandemic.5
The following are strategies that state Medicaid/CHIP agencies can consider to improve communications and coverage retention for eligible enrollees at the end of the PHE and beyond.
IT System Strategies
States may consider adopting a number of IT system enhancements to help obtain the most up-to-date contact information, including:
- Adopt More Effective and Efficient Use of Data. During the PHE, Medicaid/CHIP enrollees may have engaged with multiple programs through which they provided updated address information, mobile phone numbers and email addresses. To optimize contact information access and validation, states may want to combine several data sources on their enrollees. States could start by identifying high-impact supplemental contact data sources, such as unemployment insurance, Medicaid managed care organizations and the immunization registry. States could then estimate what percentage of their enrollees have interacted with these programs since March 2020 and whether those interactions involved providing current contact information. States could also establish a hierarchy of verification data sources (e.g., which sources are going to be the source of truth based on recency or reliability).
- Expand Capabilities and Capacities of Online Portals. Mobile access to applications and online accounts not only facilitates engagement with enrollees but also can significantly reduce the workload for state and county agencies. Online portals may be particularly important for collecting up-to-date mailing addresses, emails, mobile numbers and other critical information/documentation for redeterminations. The portal account should be easy to create and access, as well as supported by an IT infrastructure capable of handling high volumes of traffic.
Operational Strategies
States can also consider implementing the following policy and operational strategies to help mitigate coverage loss for eligible individuals who experience an address change before the end of the pandemic:
- Communicate with Enrollees Now. In advance of the end of the PHE, states can communicate with enrollees to encourage them to inform Medicaid agencies of a change in address, provide an email or mobile phone number, and set up an online account. Additionally, states can remind consumers that they may need to renew their coverage soon and to be on the lookout for communications regarding their renewal. As part of these communications, states could provide a helpline number that enrollees can call if they have questions. When states receive returned mail after they send initial notices, they will have better insight into which enrollees have outdated mailing addresses and can then target additional outreach to those enrollees through alternate modes of communication. States can review their current consumer communications and website language to be sure they are clear about the upcoming renewal process and to encourage enrollees to update their contact information. States can also work with their call centers and enrollment brokers to update their scripts to ask for updated contact information whenever there is an enrollee contact. Finally, states can consider embarking on an “Update Your Address” media campaign through local newspapers, radio stations and public transportation.
- Conduct Outreach on Returned Mail via Other Modalities. When states receive returned mail, they can leverage other contact information, such as email addresses and phone numbers, to conduct additional outreach.
- Stand Up Specialized Eligibility and Enrollment Units/Processes to Address Returned Mail. States may consider standing up specialized units or processes dedicated to “working” returned mail before and during the PHE unwinding period. Resources could be secured through hiring additional full-time equivalents (FTEs), subcontractors or county/regional offices that can handle overflow processes.
- Leverage Managed Care Plans. States with Medicaid managed care contractors can consider leveraging their health plans to conduct outreach to update member mailing addresses, telephone numbers and email addresses, as well as to reiterate the need to complete the renewal process in a timely manner.
- Partner with Community-Based Organizations (CBOs) and Application Assisters. Beyond managed care plans, states can look to enrollment brokers, CBOs and navigators to get the word out about updating contact information.
Next Steps
At the end of the PHE, eligible Medicaid/CHIP enrollees will face unprecedented challenges maintaining their coverage. States will likely need to plan for and implement strategies, such as updating consumer contact information, to retain the coverage gains of the past two years.
1 Families First Coronavirus Response Act, HR 6201, § 6008(b)(3).
2 Centers for Medicare & Medicaid Services (CMS), Example of CHIP Disaster Relief State Plan Amendment.
3 The Secretary of the United States (U.S.) Department of Health and Human Services (HHS) sent a letter to Governors informing them that “the PHE will likely remain in place for the entirety of 2021, and when a decision is made to terminate the declaration or let it expire, HHS will provide states with 60 days’ notice prior to termination.” The Biden Administration may further extend the PHE in light of the continued spread of the COVID-19 Delta variant.
4 42 C.F.R 435.916.
5 AP News, Biden to allow eviction moratorium to expire Saturday.