The End of the COVID-19 PHE: Data and IT ‘Table Stakes’ for Retaining Coverage Gains

Health Highlights

By Patricia M. Boozang, Senior Managing Director, Manatt Health | Jess Kahn, Partner, McKinsey & Company | Ashka Dave, Associate Partner, McKinsey & Company

Editor’s Note: In a new issue brief prepared for the Robert Wood Johnson Foundation’s State Health and Value Strategies program, Manatt Health reviews state Medicaid and Children’s Health Insurance Program (CHIP) agency data and information technology (IT) system “table stakes”—strategies that will have the highest impact for states seeking to ensure that eligible enrollees are able to keep or transition to new affordable health coverage when the federal continuous coverage requirements end. If adopted, these strategies will also enable states to dramatically improve Medicaid/CHIP enrollment and coverage retention in the longer term for people eligible for government-subsidized health coverage. Highlights of the issue brief are summarized below. Click here to download a free copy of the full brief.

Following the expiration of the continuous coverage requirements, states will resume normal eligibility and enrollment activities for all enrollees in Medicaid and CHIP. The volume of expected redetermination activity at the end of the public health emergency (PHE) is unprecedented. Throughout the pandemic, every state has experienced increased enrollment (totaling 10.5 million new Medicaid/CHIP enrollees, a 14.7 percent increase from 2019),1 while having paused regular eligibility and enrollment operations for the over 70 million people that already had health coverage through Medicaid/CHIP. As a result, many enrollees have not gone through the redetermination process in nearly two years, and some have never had to redetermine their Medicaid eligibility because they enrolled during the pandemic.

The triple threat of unprecedented volume, a condensed time period, and customers unfamiliar with redetermination processes paired with existing IT and data limitations poses a considerable risk of coverage loss following the end of the PHE. State and federal operators and administrators have options to pursue the following set of “table stakes” strategies now to upgrade and improve data quality and IT system capacity to prepare for this major coverage event and ensure coverage retention and continuity.

State IT Table Stakes Strategies

Effective redetermination begins with complete enrollee contact information, user-friendly ways for individuals to update critical information, and standardized data definitions with partners. Three IT efforts are table stakes to meeting these needs: adopt more effective and efficient use of data, improve account transfer data quality, and expand capabilities and capacity of online portals. States that have not pursued these efforts, or have more to do to enhance functionality, can undertake system enhancements now and execute in a way that enables receipt of the 90 percent federal match for Medicaid IT investments.

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 any additional information from the individual.2 However, given the increase in new enrollees and the nearly two-year pause on redetermination activity, it is likely that state Medicaid agencies will not have the most current information about their enrollees. Accessing data through new partners and sources can help bridge these gaps.

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

Sourcing of the most up-to-date information may require states to consider nontraditional partners and data sources within departments of health or social services, with managed care partners, or with other external data sources. Expanding the master data management approach in this moment leading up to the end of the PHE could allow states to broaden the aperture of where data are sourced and move toward a more modern foundation that can integrate both structured and unstructured data.

Table Stakes Strategy #2: Improve Account Transfer Data Quality

As states redetermine eligibility, it is likely that a higher volume than usual will need to be transferred to the Federally Facilitated Marketplace (FFM) due to changes in eligibility or circumstance. To minimize gaps in coverage and better manage casework action, states will need to ensure transfers not only work from a technical perspective but also contain sufficient information for processing. Additionally, even while the data currently provided may pass the account transfer technical schema at the Federal Data Services Hub, optional fields, such as consumer email and mobile phone number, will be critically important to include where possible. In fact, Centers for Medicare & Medicaid Services (CMS) guidance requires states to “include all of the 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 an opportunity to identify and improve account transfer data quality issues across two dimensions:

  1. Address data completeness: For accounts to be successfully transferred to the FFM, a minimum data set must be present.4 States can assess outbound accounts that historically failed initial account transfer, identify the data elements that most commonly drove this failure and prioritize fixing those inconsistencies. 
  2. Update systems to include additional contact information fields: Some states may not have updated their IT systems to include optional contact information with outbound account transfers, such as mobile phone numbers and email addresses. Resolving gaps in these fields may be simpler technical changes for states that already collect this information and could enable faster casework action by the FFM to contact individuals transferred after a determination of being over-income for Medicaid/CHIP. 

Table Stakes Strategy #3: Expand Capabilities and Capacity 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, allowing caseworkers to focus on enrollees that need more intensive in-person/live assistance. A growing number of states offer mobile access to applications and online accounts, funded at least in part by the Medicaid enhanced matching funds. As of January 2020, individuals can submit online applications through a mobile device in 44 states, compared to 28 states in 2017.5 Recognizing the importance of this digital tool at the end of the PHE, states may want to ensure their portals meet three key criteria:

  1. Portal accounts are easy to create and access.
  2. Portals have the most critical eligibility and enrollment functionality, including two key online portal functions—the ability to upload verification documentation and view member notices.
  3. Portals are supported by an IT infrastructure capable of handling high volumes.


While challenging, the end of the federal continuous coverage requirements and unwinding of related policies may afford states a unique opportunity to not only address the challenge at hand and retain coverage gains experienced over the pandemic period, but also take a seismic step toward an evolved and modern Medicaid eligibility and enrollment technological approach that better serves individuals through more effective 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 Informational 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 Hub (Federal DSH).

5 Kaiser Family Foundation, Medicaid and CHIP Eligibility, Enrollment, and Cost Sharing Policies as of January 2020: Findings from a 50-State Survey.



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