How States Can Evaluate, Improve Ex Parte Medicaid Renewal Processes

As states and payers prepare for coronavirus public health emergency waivers to end, experts are recommending redesigning the Medicaid renewal processes, specifically ex parte rates, according to a Manatt Health issue brief.

Ex parte renewals are renewals that do not require an enrollee to submit paperwork. There are multiple processes that could qualify as ex parte renewals.

“Federal regulations require states to attempt to renew Medicaid enrollee eligibility through an ex parte process using all available data sources,” the issue brief stated.

“If an individual’s eligibility is able to be verified ex parte, states are required to extend Medicaid coverage without any additional action from the enrollee. If the state is unable to determine an individual’s eligibility through an ex parte process, the state must send a new renewal form requesting additional information and/or documentation.”

Using ex parte renewal processes can benefit both enrollees and states. One of the key motivations behind why states implement these processes is that it may help more Medicaid beneficiaries keep their coverage, specifically in minority communities thereby improving health equity. Additionally, taking an ex parte approach to coverage renewals can improve states’ administrative workloads.

The issue brief invited states to ask themselves seven questions in order to hone their ex parte processes.

First, states should assess their Modified Adjusted Gross Income (MAGI) ex parte rates. By law, states have to include MAGI populations in their ex parte processes. 

If 60 percent or more of a state’s MAGI population is re-enrolled through an ex parte process, the state has an efficient ex parte system and should focus its efforts on outreach and communication. If the share is less than 60 percent, the state should review its ex parte processes using the remaining questions in the Manatt Health issue brief.

States that need to continue with the diagnostic tool to assess their ex parte processes should start with evaluating their data sources for earned and unearned income. Having more data sources is ideal. The tool suggested using the Internal Revenue Service (IRS) or state tax data to assess earned income and the Social Security Administration and social services data for unearned income.

Next, states can check whether or not their processes employ Supplemental Nutrition Assistance Program (SNAP) data, a useful source of eligibility information. States can also seek out a 1902(e)(14) waiver in order to automatically renew Medicaid coverage for certain SNAP participants or use an Express Lane Eligibility state plan amendment (SPA) or a Facilitated Enrollment SPA to re-enroll children or adults, respectively.

Fourth, states should ask if they lean on a strategic hierarchy of data sources. Under a strategic hierarchy of data sources, states would renew an individual’s coverage through an ex parte process if any income data source matches the requirement, instead of matching the highest recorded income against the benchmark. This approach may have a medium impact on ex parte rates.

Then, states can ask if they require consent for the ex parte process as part of their procedures. If so, this can present a barrier to the ex parte process’s ability to re-enroll qualifying beneficiaries. If there is a consent requirement, the issue brief tool suggested eliminating it.

Sixth, states should assess whether their ex parte processes leave out certain groups, such as groups that have reported self-employment income or non-MAGI populations.

Finally, states should review all of their business rules to ensure that no other rules conflict with the ex parte process, rules such as narrow timeframes for data viability or limiting an individual’s ex parte redeterminations.

Experts have been warning that the end of the public health emergency will mean the end of certain flexibilities that have ensured continuity of coverage for many Americans.

Medicaid re-enrollment is just one of at least four Medicaid processes that will be impacted by the end of the public health emergency.

Some payers are already taking steps to be ready for the onslaught of responsibilities once the emergency is over.