Medicare Advantage plans: What are you doing to plan for the end of the PHE to minimize Medicaid disenrollments?

Like so many individuals and organizations, state Medicaid agencies have experienced challenges during the COVID-19 public health emergency (PHE).  These have been caused by staff transitions to telework, increased volume of applications, adjusting recertification processes to meet the PHE requirements, and the need generally to modify policies and procedures to facilitate access to coverage and care. 

The old saying regarding Medicaid administration is “if you have seen one state, you have seen one state!”  This continues to hold true when it comes to Medicaid recertification during the Public Health Emergency/Covid-19 Pandemic. 

In the midst of all these challenges from the pandemic, Medicaid enrollment has grown to record levels.  Georgetown University Health Policy Institute recently published an article showing the significant increases in Medicaid membership.  Of course, this comes at a time when states have fewer resources available for routine eligibility processing.  Enrollment has been increasing for numerous reasons, including the economic downturn during the pandemic, recent Medicaid expansion for adults in a few states, and the disenrollment freeze that began in March 2020. 

There have been a variety of different approaches to the processing of Medicaid renewals adopted by state agencies. Initially, most states delayed processing renewals in order to focus on the pandemic response.  Some continue to do so.   However, the majority of states are now actively processing recertification applications, but holding in abeyance the termination of coverage for anyone who no longer qualifies unless they move to another state or specifically request their coverage to end.

CMS released a State Health Official (SHO) letter in December that outlines how state are expected to unwind emergency authorities and resume normal eligibility processing after the PHE ends.   According to that guidance, CMS expects states to process renewals to the extent possible during the PHE and to clear the backlog of Medicaid eligibility renewals within six months after the PHE and termination freeze ends. 

In order to help distribute workloads in future years, states will have the option to retain a member’s original eligibility period instead of beginning a new 12-month period when the renewal is actually completed.  This will result in certification periods that are shorter than 12 months.  CMS also explained the circumstances under which states don’t have to attempt to complete another renewal before terminating coverage for individuals who failed to complete the renewal during the PHE.

In addition, some individuals gained eligibility due to state-adopted emergency authorities that expanded eligibility, so eligibility for these members will need to be redetermined if the state reverts to prior rules after the PHE ends. 

All of these factors create the potential for payers to have a high volume of Medicaid disenrollments in the year after the PHE ends.  Medicaid renewal can be a complicated process even without a pandemic.  Each state must periodically complete eligibility redeterminations for all beneficiaries enrolled in Medicaid or CHIP. The state agency must begin the renewal process early enough to complete a redetermination prior to the end of the eligibility period.  States are required to attempt to redetermine eligibility based on reliable information available to the agency without requiring information from the individual.  However, when available information is insufficient to determine continued eligibility, Medicaid agencies require additional information from the beneficiary. Many also require proof of income and/or assets and a few also require a telephone interview. 

BeneLynk tracks the renewal policies and procedures in each state for every category of Medicaid.  For example, which states are currently requesting and processing renewals, the circumstances under which eligibility can be passively renewed and what grace period (if any) is available for late renewals after a member loses coverage for failure to complete the renewal on time.  Our system also allows our advocates to present all renewal options available to the member based on where they live and their Medicaid category, and ensures that our communication uses the same terminology as the state Medicaid agency to avoid confusion.   We also track each member’s eligibility and work with the state Medicaid agencies to ensure that every application and/or renewal is processed timely, and assist members as needed to follow up on any additional information requested.  As the member’s authorized representative, we can request a fair hearing to review any erroneous denials or closures that perhaps should be overturned.  

At BeneLynk, we offer customized retention solutions for Medicare Advantage and Managed Medicaid plans.  Many of our customers have continued to communicate with their Dual and Medicaid-only members to keep them informed of changes by their state.  Most have continued to assist them with any renewal requirements in their state and others have added our Community Lynk program to screen members for SDoH barriers and assist them with enrollment into valuable programs to improve their lives. 

This is our business!  We have the experience and expertise to improve your Medicaid retention.  How are your thinking about the return of Medicaid renewals?   We would love to hear your ideas.