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The Role of State-Based Marketplaces in Medicaid Unwinding

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While state Medicaid agencies are responsible for redetermining eligibility for millions of individuals with the end of the Medicaid continuous coverage requirement, state-based marketplaces (SBMs) have been actively partnering with Medicaid agencies to ensure individuals are informed and can have smooth transitions to other coverage if they no longer qualify for Medicaid.

As part of the three M’s (Medicaid, Marketplace, and Medicare) of coverage, the marketplaces will be a critical source of coverage for individuals who no longer qualify for Medicaid. These individuals should understand what other coverage options exist and what steps they need to take to access such coverage. States that operate their own health insurance marketplaces or those that do so in partnership with the federal government, which is currently 21 states, have extensive experience in engaging individuals through their marketplaces, coordinating with Medicaid agencies on eligibility and enrollment, building and maintaining the workforce for enrollment, and simplifying coverage transitions. The SBMs bring all of this experience in supporting Medicaid agencies with the Medicaid unwind process for millions of individuals across states.

Below are some examples of how SBMs are implementing a range of strategies and initiatives to help prevent unnecessary coverage losses during the Medicaid unwinding period.

Developing Effective Communication Strategies

SBM officials have developed communication and outreach materials to describe the unwinding of the Medicaid continuous coverage requirement, encourage individuals to update their contact information, and provide information about marketplace coverage. They also have been working closely with their Medicaid agency counterparts as well as community-based organizations and other partners to help ensure that these messaging and outreach strategies are effective and well coordinated.

  • Covered California, in partnership with the state Medicaid agency, has a multi-language outreach campaign and is translating consumer materials into 14 languages.
  • Like many other states, SBMs in both Idaho and Kentucky have informational webpages for individuals who are losing Medicaid coverage due to the end of the continuous coverage requirement.
  • Massachusetts convened focus groups in five languages to inform messaging strategies for outreach campaigns and resources for partner organizations. Informational materials about the state’s SBM, the Massachusetts Health Connector, will be translated into 24 languages and distributed to trusted community partners. Additionally, the Health Connector and the state’s Medicaid agency, MassHealth, jointly developed outreach materials specifically designed to inform and engage the employer community about Medicaid unwinding.
  • New Jersey developed an informational webpage and frequently asked questions to guide consumers who are losing Medicaid coverage due to the end of the continuous coverage requirement and may be eligible for coverage through the SBM.
  • In addition to conducting a robust outreach campaign through a variety of communication modes, New York’s SBM has created fact sheets about unwinding and the end of the public health emergency that are specific to each congressional district. The fact sheets contain data about the number of Medicaid, Child Health Plus, and Basic Health Program enrollees in each district that will have coverage redetermined, steps that individuals can take such as updating their contact information and signing up for text alerts, as well as an infographic that demonstrates step-by-step how an individual can renew their Medicaid coverage.
  • Pennie, Pennsylvania’s SBM, is working in close coordination with the Pennsylvania Medicaid agency to develop a seamless process of communications, including a co-branded mailer that is being provided to those losing Medicaid coverage for not replying to their renewal packet. Pennie is following Medicaid communications with notices, mailers, emails, and phone calls.
  • Vermont is using texting to remind members to update their mailing address and to respond to renewal notices. Vermont also has authorized call center staff to verify and update contact information when consumers call in to ensure that the marketplace has the most up-to-date contact information on hand.

Interagency and Partner Collaboration

Recognizing the importance of partnerships to ensure that the Medicaid unwinding process occurs as smoothly as possible, SBMs are coordinating closely with their Medicaid agency counterparts as well as with other state entities, managed care organizations (MCOs), agents and brokers, and community-based organizations.

  • Staff from Colorado’s SBM, Connect for Health Colorado, meet with Medicaid agency staff each week on issues related to Medicaid unwinding and have conducted tabletop exercises of their planned unwinding processes to help identify operational issues that need to be addressed.
  • Access Health CT, Connecticut’s SBM, has been working closely with Medicaid officials and other state agencies to coordinate a statewide marketing and outreach campaign and are connecting with a broad range of partners on ways to improve communication and outreach strategies. They have also met with and provided information to state legislators and other partners about the planned interagency collaboration efforts during the Medicaid unwinding period.
  • Staff from DC Health Link, Washington, DC’s marketplace, meet weekly with the state Medicaid agency to coordinate outreach, enrollment, and communication strategies. This includes working with Medicaid MCOs to strategize a warm hand-off for those becoming eligible for marketplace coverage, reviewing eligibility determination notices, and planning joint educational events.
  • Kentucky’s SBM, the Kentucky Health Benefit Exchange, has daily rapid response meetings that include leadership and key individuals from Medicaid, the SBM, IT systems, communications, and sister agencies. Partner meetings have been held and will continue each month to provide the most up-to-date information during the unwinding period. 
  • Maryland Health Connection is convening weekly meetings with the state Medicaid agency as well as working closely with other state agencies and MCOs that serve Medicaid enrollees to coordinate messaging and activities. This includes working with the state Department of Human Services to ensure that individuals receiving Supplemental Nutrition Assistance Program (SNAP) benefits have Medicaid coverage automatically renewed, collaborating with their state Department of Education to conduct outreach to families, and teaming up with liaisons from their Hispanic outreach agency and other community leaders to ensure specific populations understand how the process will work. Similar to other states, Maryland’s SBM has also tasked specific staff with overseeing their Medicaid unwinding-related actions.
  • Minnesota’s marketplace, MNsure, is working closely with the state’s Medicaid agency, which also administers the state’s Basic Health Plan (BHP), and the navigator network to coordinate communications to families who will soon go through eligibility redeterminations. This collaboration will also help improve reporting among the agencies to allow targeted outreach and messaging aimed at smoothing the transition from public program coverage to enrolling in private plans for families who will no longer be eligible for Medicaid or BHP. 
  • NY State of Health, New York’s integrated marketplace across public and commercial coverage, will redetermine over 80 percent of the state’s public program enrollees during the unwind. NY State of Health has partnered with Ichor Strategies to identify specific neighborhoods and communities most at risk of losing coverage to prioritize throughout the Medicaid unwind. This included studying enrollment patterns and market need, determined by scoring neighborhoods based on quantitative variables such as the Social Vulnerability Index. Through community dialogues and research, the state gained an understanding of local challenges to re-enrollment and identified partnership opportunities and communications strategies that will help the state expand its reach and support more seamless renewals.
  • Pennie, the Pennsylvania SBM, has been meeting with the Pennsylvania Medicaid agency on a weekly basis, working together to develop co-branded communications, data sharing agreements, and coordinating on press tour events as well as partner toolkits and presentations. Pennie also participates in regular meetings with Medicaid MCOs, agents and brokers, and consumer advocacy organizations to ensure alignment of unwinding policies and communication efforts.
  • Vermont’s marketplace is part of the state Medicaid agency and is able to ensure coordination from a structural perspective, thanks to the flexibilities inherent in implementing an SBM.

Strengthening the Workforce

SBM officials are implementing strategies to help manage the anticipated influx of consumers navigating the qualified health plan (QHP) enrollment process and maintain a reasonable workload for their staff.

  • The DC SBM has maintained open enrollment staffing levels at their contact center, retaining experienced and trained staff in anticipation of increased call volume.
  • Massachusetts has recruited and trained additional call center staff to help manage increased consumer demand, as have many other SBM states. Also, both Colorado’s and New Mexico’s SBMs have call center staff models that will allow them to expedite the hiring of contract staff as needed.
  • In anticipation of an increase in call volume during the Medicaid unwinding period, Minnesota’s SBM will staff the call center similar to the surge staffing structure that they employ during their open enrollment period, and they will adjust this as needed during the unwinding period.
  • Nevada’s marketplace will leverage funding from a Centers for Medicare & Medicaid (CMS) State Exchange Modernization Grant to support additional customer service representatives to reach out to former Medicaid enrollees who may be eligible for exchange coverage. These staff will be trained in specific Medicaid transition plans to help connect consumers to plans on the marketplace offered by their MCO carrier to help make the transition as easy as possible.
  • In anticipation of an increase in call volume during the Medicaid unwinding period, Pennsylvania’s SBM’s call center staffing levels are similar to the surge staffing structure that they employ during their open enrollment period, and they will adjust this as needed during the unwinding period.

Simplifying Coverage Transitions

For individuals who are no longer eligible for Medicaid, SBMs are focused on facilitating transitions for those who qualify for QHP coverage.

Enhanced Consumer Outreach

  • Colorado enacted legislation in 2022 that provides funding for the SBM to develop and implement a consumer outreach campaign, which includes hiring agents to conduct outbound calls to individuals who lost coverage and do not have email addresses.
  • DC’s SBM will receive a monthly report from the state Medicaid agency detailing the Medicaid beneficiaries who are newly eligible for marketplace coverage. This report will be used to direct an outreach campaign, including direct calls by DC Health Link assisters, to help enroll those transitioning to coverage on DC Health Link.
  • Idaho’s SBM, Your Health Idaho, conducts outreach to individuals losing Medicaid coverage through a variety of channels, and notifies agents and brokers about their clients. To facilitate enrollment into marketplace coverage, the SBM is allowing for self-attestation of eligibility for a special enrollment period and is only following up with individuals when additional information is needed.
  • For those no longer eligible for Medicaid, SBM staff in Kentucky are providing additional support to help transition individuals to other sources of health care coverage, including a QHP through the state’s integrated eligibility system.
  • Individuals found ineligible for MaineCare (Maine’s Medicaid program) during their renewal process will have their account transferred automatically to Maine’s SBM, CoverME.gov, which will be conducting targeted outreach to those consumers. The outreach campaign includes a series of three “Welcome to CoverME.gov” marketing materials via postal mail, along with outbound calls, emails, and text outreach.
  • Maryland is using certified navigators and brokers to contact consumers directly who qualify for QHPs, as well as implementing robocalls from its call center.
  • Oregon, which operates its marketplace as a partnership that uses the federal platform, will regularly receive files from the Medicaid agency about disenrolled individuals during the Medicaid unwinding period. These files will be used to target outreach efforts to provide individuals with information about the potential amount of financial assistance they would receive via the marketplace. Notices are in plain language and specific to the individual and are sent in one of 14 languages by preference to promote equitable access to coverage. SBM staff will also send reminders to these individuals if they have not selected a plan about 30 days before the end of their Medicaid benefits.

Special Enrollment Periods

  • To ensure ease of enrollment, there is a rolling special enrollment period (SEP) for the Covered Connecticut program. Access Health CT is also extending the time period for consumers who may lose eligibility for Medicaid as part of the unwinding process to enroll in a QHP from 60 days to 120 days, and will be hosting in-person enrollment events throughout the state during the unwinding period.
  • DC’s SBM implemented a “loss of Medicaid coverage” SEP to mirror the SEP instituted by the federally-facilitated marketplace. This SEP allows for the attestation of the loss of Medicaid coverage at any point between March 31, 2023 and July 31, 2024 for a 60-day period, and provides an enrollment date of the first of the month reported or the first of the following month. To maximize the flexibility, if an individual wants an earlier effective date, the person can work with a case manager to obtain an effective date retroactive to the month in which their Medicaid was terminated.
  • MNsure, Minnesota’s SBM, will provide consumers with additional time to transition to a QHP through an extension of the “loss of other coverage” SEP. The extended SEP will be available for 90 days after losing Medicaid coverage, which is 30 days longer than consumers traditionally have to shop and enroll in a QHP. In addition, the state will allow individuals and families to select an earlier effective date for the first 60 days of their SEP window.
  • New Jersey is assisting residents with the transition to marketplace coverage by offering an extended SEP to those who lose Medicaid coverage. Eligible consumers can enroll in a QHP through Get Covered New Jersey using the “loss of NJ FamilyCare, Medicaid, CHIP, and/or Medicare” SEP qualifying life event. Consumers will have 120 days to enroll in coverage through Get Covered New Jersey after their Medicaid coverage ends and the ability to select an earlier effective date. The state also offers an SEP called the Expanded Access Special Enrollment Period, which allows consumers with an annual income up to 200 percent of the federal poverty level to enroll any time of the year with access to plans with low or no monthly premium.
  • Pennie will provide consumers with additional time to transition to a QHP through an extension of all “loss of coverage” SEPs. The extended SEP will be available for 120 days after losing Medicaid coverage, which doubles the amount of time that consumers traditionally have to shop and enroll in a QHP. In addition, the state will allow individuals and families to select an earlier effective date for the first 60 days of their SEP window specifically for the unwinding period to avoid gaps in coverage.
  • Washington has a year-round SEP for individuals with income up to 250 percent of the federal poverty level.

Automatic Enrollment/Information Transfers

  • California has implemented a program that automatically enrolls individuals in a marketplace plan when they lose Medicaid coverage. View California’s automatic enrollment toolkit
  • Rhode Island has also developed a program to automatically enroll some individuals losing Medicaid into a marketplace plan. Learn more about Rhode Island’s auto-enrollment program in the NASHP blog post “Rhode Island Looks to Auto-Enrollment to Ease Transitions from Medicaid to Marketplace.”
  • Maryland uses a shared Medicaid-Marketplace modified adjusted gross income (MAGI) eligibility system and is implementing a simplified process to transition individuals who lose Medicaid into QHPs. Individuals may be auto-enrolled or receive information on how to opt-in to QHP coverage.
  • In Massachusetts, QHP applicants will have an option to be automatically enrolled in zero-dollar premium coverage if they qualify, without needing to shop to find the lowest cost plan.
  • In Nevada, when Medicaid enrollees are reviewed and determined ineligible for the program, their information will automatically be sent to the state’s marketplace, where their available information pre-populates a QHP application. The consumer will be sent a unique code to claim their application and account.
  • Pennie, the Pennsylvania SBM, has implemented an automated eligibility system that provides individuals losing Medicaid who are account-transferred to Pennie with an eligibility determination and an automatic SEP. The only action needed from individuals is to claim their account and select a plan.
  • Vermont has added electronic data sources to facilitate Medicaid renewals and rescreening when a disenrolled member reapplies. Vermont has also streamlined enrollment policies to ensure there is no barrier to QHP enrollment for those who are no longer eligible for Medicaid.
  • In Washington, the state has a single streamlined application, Washington Healthplanfinder, for both Medicaid and QHPs. As a result, customers who are no longer eligible for Medicaid can easily shop for and enroll in a QHP without having to enter into a new system or create a new account. 

Retroactive Coverage

  • In Idaho, when consumers request coverage to be back-dated due to exceptional circumstances, the SBM has developed an expedited internal approval process, which enables a faster resolution for those who qualify before being directed to file an appeal.
  • New Mexico’s SBM also provides retroactive coverage, back dating enrollment to first of the month for an individual losing coverage mid-month to promote seamless transitions.

Additional Efforts

  • SBM officials in Connecticut anticipate that the Covered Connecticut Program will be helpful for individuals who are no longer eligible for Medicaid. In this state wrap program, the state pays for qualifying individuals’ monthly QHP premium payments and also cost-sharing amounts, providing no-cost coverage for individuals with income up to 175 percent of the federal poverty level. The program also includes dental and non-emergency medical transportation coverage.  
  • To assist individuals transitioning from Medicaid to marketplace coverage, New Mexico offers a Medicaid Transition Premium Relief Program which covers the cost of the first month’s premium for most individuals transitioning from Medicaid to a health plan on the state’s SBM, beWellnm.
  • In Oregon, if individuals disenrolled from Medicaid had been enrolled in a Coordinated Care Organization (CCO), the state will use any CCO claims data to try and match them to providers within QHP networks to help promote continuity of care.
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