Enhanced Medicaid Funding Available to Support Unwinding-Related Eligibility and Enrollment Functionality

Manatt Health

On August 30, the Centers for Medicare & Medicaid Services (CMS) issued a State Medicaid Director Letter (SMDL) instructing states to assess whether they are in compliance with federal Medicaid regulations that require all renewal processes be conducted at the individual level (see the State Health and Value Strategies expert perspective summarizing the SMDL and accompanying diagnostic assessment tool). In response to the letter, states have begun identifying areas of non-compliance and planning for necessary eligibility and enrollment process and systems fixes to address such issues. The SMDL reminds states that a, “90 percent matching rate for [Federal Financial Participation] FFP is available to States for approved processes, systems, and activities necessary to ensure compliance,” with the Medicaid and CHIP renewal requirements. More specifically, states may receive:

• A 90% match for design, development, installation, or enhancement of systems necessary to ensure eligibility compliance (including systems fixes to conduct renewal processes at the individual level). States may also claim 90% match for planning activities, such as conducting impact assessments, gap analyses and convening workgroups to identify potential system enhancements.
• A 75% match for systems-related maintenance and ongoing operations—including security updates, software leasing or licensing, production of notices, activities related to utilizing the eligibility system to make data verifications or maintain the member’s case file, and training of personnel directly engaged in the operation of a system, to include workers processing claims or determining eligibility. Call center customer service and provider relation functions are eligible at this match rate if they are directly related to system operations.
• A 50% match for activities preceding and subsequent to eligibility determination, such as outreach (to include mailing of notices), member education, marketing, community-based application assistance and plan-choice counseling.

The applicable federal match should apply regardless of whether state, county, or vendor staff are conducting the work. State Health and Value Strategies’ experts are available to support states as they work to come into compliance with federal renewal requirements, and the individual level ex parte requirement in particular. For additional information, see this resource.