CMS Offers New Details on Account Transfer 2.0
Manatt Health
The Center for Medicaid and Children’s Health Insurance Program (CHIP) Services (CMCS) explained the transition to “Account Transfer 2.0” (AT 2.0) in a CMCS Informational Bulletin (CIB) released on October 10, 2024. The CIB indicates significant federal investment in improving the process of transferring consumer application information between state Medicaid and CHIP agencies and the Marketplace in the states using the federal platform (HealthCare.gov).
While the Affordable Care Act requires program coordination between Medicaid/CHIP and the Marketplace, the “unwinding” of the Medicaid continuous coverage requirement exposed weaknesses in existing account transfers from state agencies to the federal Marketplace, which allow incomplete or unusable data to move through the system, requiring impacted consumers to complete the Marketplace application from the start even though they have already started an application with the state Medicaid/CHIP agency. The AT 2.0 initiative aims to reduce consumer friction by modernizing the data formats of the transfers and improving the data model to focus on a core set of well-defined data elements that are formatted to be reliably usable by the Marketplace and states (for example, by communicating data in a way that minimizes redundant verification or document requests). This will promote the goals of streamlining the application, reducing the burden on individuals to submit the same enrollment information multiple times, and helping agencies trace the transfer of accounts to produce reliable data and reduce duplicate enrollments.
A group of six states (Alaska, Hawai’i, Iowa, New Hampshire, South Carolina, and Tennessee) have volunteered to provide early input into the data elements, definitions, and data quality controls of AT 2.0. Throughout the multiyear development process, all states will be invited to weigh in on the feasibility, development, and implementation of AT 2.0’s structure and rollout.
Early adopters will launch the new system in 2027. No deadline is set for implementation by all states on the federal Marketplace platform, but CMCS does point to the need for states to build system changes into their multiyear information technology plans, identify necessary state updates to eligibility systems, processes, or state applications (and any needed appropriations), and plan to test and onboard AT 2.0 services. A 90/10 enhanced federal match is available for the design, development, and implementation of these initiatives, and a 75/25 enhanced federal match can be used for ongoing approved systems.