State Policy and IT System Strategies to Prepare for PHE Unwinding: Updating Medicaid Enrollee Address Information and Responding to Returned Mail
Kinda Serafi and Patricia Boozang, Manatt Health and Jess Kahn, McKinsey & Company
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. This expert perspective examines the information technology (IT) system, policy, and operational strategies states can consider to update key enrollee contact information to ensure eligible enrollees are able to keep or transition to new affordable health coverage at the end of the PHE.
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). Many states have also paused renewals and disenrollments for their CHIP enrollees. Both of these actions aim to ensure continuity of coverage and access to healthcare services for low-income people during the pandemic. 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. At that time, states will resume normal eligibility and enrollment processes, including redetermining eligibility.
Currently, state eligibility renewal processes rely heavily on communication with enrollees by mail. If Medicaid agencies are unable to redetermine eligibility based on available data sources, states routinely mail notices with renewal forms to enrollees [prepopulated forms are required for the Modified Adjusted Gross Income (MAGI) population], and enrollees return forms and other required paperwork by mail. If an enrollee has changed addresses or is experiencing homelessness or housing instability, these critical notices will be returned to the Medicaid/CHIP agency. Many state Medicaid/CHIP agencies do not follow-up on returned mail but rather terminate eligibility for individuals whose addresses no longer appear valid. These longstanding challenges with maintaining accurate enrollee 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 no opportunity to confirm or update address information. Additionally, with the end of the federal eviction moratorium and most state-based eviction protections, housing instability has become more prevalent among lower-income individuals and families who may have moved one or more times during the course of the pandemic.
There are steps state Medicaid/CHIP agencies can consider taking to improve successful enrollee communication and coverage retention for eligible enrollees at the end of the PHE and beyond.
IT Systems Strategies
States may consider adopting a number of IT systems enhancements that will help to obtain the most up-to-date contact information and improve the user experience. Two of these strategies—adopting a more effective and efficient use of data and expanding capabilities of online portals—are described below and in more detail in a companion issue brief focused exclusively on state Medicaid/CHIP IT systems strategies to prepare for the end of the PHE.
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, including new data sources, on their enrollees. States could start by identifying high impact supplemental contact data sources [e.g., via the immunization registry, Supplemental Nutrition Assistance Program (SNAP), Pandemic Electronic Benefit Transfer (EBT), Health Information Exchanges (HIEs), Medicaid managed care organizations (MCOs), Unemployment Insurance (UI)]. States could then estimate what percentage of their enrollees have interacted with these programs and whether that interaction since March 2020 may have involved providing current address and other contact information in order to pursue new verification data sources likely to be most fruitful. States could also establish a hierarchy of their verification data sources [e.g., which sources are going to be the source of truth over others based on recency or reliability]. A best practice would be to include both program and data/IT experts in this decision to ensure the right mix of familiarity with the program data and feasibility of establishing the right hierarchy.
Expand Capabilities and Capacities of Online Portals. Mobile access to applications and online accounts not only facilitates engagement with enrollees (e.g., enrollees can complete case maintenance functions such as uploading documents, reporting changes, and completing renewals), 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. 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 to facilitate consumers proactively updating contact information fields. Given the unprecedented volume of redeterminations, portals will need to be supported by an IT infrastructure capable of handling high volumes of traffic.
States can also consider implementing the following policy and operational strategies to help mitigate coverage loss for eligible individuals who may have experienced (or will experience) an address change before the end of the pandemic.
Communicate with Enrollees Now. Over the next few months, in advance of the end of the PHE, states can communicate with enrollees—through mail, telephone, online account and text—to encourage them to inform the Medicaid agency of a change in address, provide an email or mobile phone number as part of their case record, and set up an online account (if available and they have not already done so). Additionally, states can remind consumers that they may need to renew their coverage soon and be on the lookout for mail and other communications regarding their renewal. As part of these communications, states could provide a helpline number that enrollees can call if they have questions about their Medicaid/CHIP renewal. When states receive returned mail after they send initial notices, they will have better insight into which enrollees have outdated mailing addresses and can target additional outreach to those enrollees through alternate modes of communication. States can review their current consumer communications (e.g., notices, email and text content, renewal forms) as well as Medicaid/CHIP and social service agency website language to be very clear about the upcoming renewal process and to encourage enrollees to update their contact information. States can also work with their call centers/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 (as a lead up to a “Renew Your Coverage” campaign) that leverages the same channels—local newspapers, radio stations, public transportation—that states use for other enrollment and public health campaigns.
Outreach on Returned Mail via Other Modalities. When states do receive returned mail, they can leverage other contact information, such as email address and phone numbers, to conduct additional outreach. States can outreach to enrollees via email, text, or phone call to follow-up on returned mail, non-response to renewal forms, and requests for information.
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. Timing matters in the event that the state Medicaid/CHIP agency requires additional authority or budget appropriations to expand staff for these purposes. Additionally, specialized workers might be a permanent change to Medicaid/CHIP agency operations to improve address accuracy beyond the unwinding period.
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. For example, a state can encourage or require health plans to remind members to report changes of address during every enrollee interaction. State eligibility workers focused on addressing returned mail can engage with plans to research updated addresses or other contact information.
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, providing direct assistance with obtaining updated contact information, and ensuring individuals respond to requests for information and renewal forms.
At the end of the PHE, whether in December or some future date, 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 last two years. For more information on state strategies to support Medicaid/CHIP coverage retention and plan for the end of the continous coverage requirements, see the resource page developed by State Health and Value Strategies.
 Centers for Medicare & Medicaid Services (CMS), Example of CHIP Disaster Relief State Plan Amendment.
 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.