AHIP Supports Using Texts, Calls for Medicaid Enrollment Processes

AHIP has expressed its support for a request from the US Department of Health and Human Services (HHS) and CMS to the Federal Communications Commission, which seeks confirmation of the agencies’ ability to use text messaging and phone communications to improve federal coverage enrollment processes.

An affirmation from FCC would kickstart a three-part plan to contact Medicaid enrollees over the course of a year and a half, AHIP summarized. The plan involves contacting the enrollees six to eight times via text or pre-recorded calls.

AHIP supported the HHS and CMS proposition that contacting enrollees through text and call would be an efficient way to connect with enrollees during a critical time for Medicaid enrollment processes. 

“AHIP agrees with the agencies’ approach and assessment that text messaging and automated, pre-recorded calls will provide more effective communication to alert enrollees to the need to update their contact information and respond to state requests for information, and enhanced opportunities to allow individuals to maintain uninterrupted and continuous health benefit coverage,” the letter explained.

Proponents of this plan, including AHIP, have pointed out that Medicaid programs will have to handle a high load of communications when the public health emergency ends because Medicaid redeterminations will restart.

However, the organization also argued that these methods of connecting with enrollees might become best practice more broadly.

“Depending on the outcome of this effort, we also agree that, consistent with the TCPA, the use of text messaging and automated, pre-recorded calls may become a best practice for reaching Medicaid, CHIP, BHP, and Marketplace enrollees, and both state and federal agencies may choose to incorporate them into future renewal work,” the letter stated.

AHIP supported the agencies’ arguments that enrollees have already consented to be contacted for eligibility and enrollment purposes by providing a cell phone number and that the government is the “maker” of the call, which eliminates any potential violations of the Telephone Consumer Protection Act.

FCC has approved telephone communication for healthcare outreach in other circumstances, AHIP pointed out.

“We strongly urge the Commission to confirm the agencies’ understanding. Doing so will provide state Medicaid, CHIP, and BHP agencies, managed care entities (including MCOs, their parent companies and contractors), and the Marketplaces serving each state the clarity needed to begin undertaking the measures needed to ensure millions of Americans maintain continued, uninterrupted coverage upon conclusion of the PHE,” AHIP said.

In the agencies’ request, HHS and CMS shared that there will be three types of text or call communications for the three phases of the renewal process. 

The first phase would involve sending out texts or pre-recorded calls to Medicaid, Children’s Health Insurance Program (CHIP), and Basic Health Program (BHP) enrollees to tell them to connect with their program in order to update their contact information. By reaching out to them in the first phase, the agencies will know whether or not they can connect with the enrollees.

When renewals are being processed in the second phase, the agencies will reach out via text or a pre-recorded call for redeterminations. An individual might receive more than one contact during this phase if the first attempt fails.

In the third phase, enrollees who are no longer eligible may receive texts or pre-recorded calls that explain the next steps to finding coverage.

In response, the Federal Communications Commission established a period for public comment, which closed on May 17, 2022 and the replies will be published May 24, 2022. 

Medicaid programs have been taking a variety of approaches to prevent coverage losses after the end of the public health emergency and the related flexibilities. 

For example, the Massachusetts Medicaid program, MassHealth, may leverage community-level outreach, make adjustments to its renewal verification process, partner with managed care organizations and accountable care organizations, revise its communications strategy, and hire more caseworkers.

Commercial payers have projected a drop in Medicaid enrollment in 2022 as the public health emergency flexibilities conclude.