Presenting on a panel at the 2023 Texas State of Reform Health Policy Conference in Austin on Thursday, senior officials from the Texas Health and Human Services Commission (HHSC), Texas Association of Community Health Centers (TACHC), and Every Texan outlined the statewide coordination that was the start of Medicaid redeterminations next month.
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When the Public Health Emergency’s continuous Medicaid coverage provision ends on April 1st, HHSC is required to evaluate the entire state Medicaid population of 5.9 million members over a 12-month period for eligibility. Valerie Mayes, HHSC deputy chief program and services officer, said the agency would be dividing the Medicaid population along two parallel tracks: those who remain eligible for Medicaid and those who benefited from continuous coverage provisions and might not be eligible anymore.
The 2.7 million people estimated to be in the latter group will be further divided into three cohorts based on the information that was available and their likelihood to maintain coverage after the process.
“So the first cohort is made up of people who we believe are most likely to no longer be eligible,” Mayes said. “So children who may have aged out, adults who no longer have a dependent child in their household, pregnant women who are past their postpartum coverage period, etcetera.
The second group are those that we believe are more likely to move to a different type of Medicaid coverage or we know we need more information to be able to verify their eligibility. And then the third cohort is made up of those who we believe are most likely to still be eligible. So it may be older adults, people with disabilities, [and] children who are still of age for children’s Medicaid.”
Mayes said the agency would first check electronic data sources to attempt an ex parte or administrative renewal. If it is unable to make a determination based on that information, the client would be sent a request-for-information packet, which they will then have 30 days to return.
Once received, the members will then enter an eligibility queue for workers to process where the case will be reviewed and issued a final determination, either a new certification period or a denial notice.
Molly Lester, HHSC deputy commissioner of policy and quality for Medicaid and CHIP services, said the state has been coordinating with the health plans on outreach, especially for those patients already accessing services.
“One of the things that we have been doing has been providing our health plans [with] specific files for their members that are becoming due for renewal because [plans] do have an obligation to assist folks in renewing their coverage when possible,” Lester said. “And so as we’ve been sort of rolling out the stages of this process, and starting last year when we started this outreach campaign, we’ve been arming them with the same information and messaging that we’ve been using.
And our primary message to date has really been about updating contact information. We recognize that folks may have moved, [and] circumstances may have changed. Lots of things have changed for a lot of us and so really making sure that we have the best contact information for them, and how we can push that messaging out.”
The agency has been conducting various outreach efforts and issuing guidance to its community and provider partners on administering member communication and consent.
HHSC will be offering a grace period on enrollment fees for Medicaid and CHIP during the unwinding.
TACHC, which represents all 73 federally qualified health centers (FQHCs) in the state, serves 12% of the state’s Medicaid population.
Sonia Lara, TACHC director of outreach and enrollment, said since last summer the association has distributed communication materials on eligibility across its 650 sites and situated some 400 staff at 250 sites to assist with outreach services.
“One of the other things that we’re doing also is encouraging at the state level, all of our health centers to please make sure that they sign up for what they call [a] Level Three Community Partner Program contract,” Lara said. “What level three does is it allows our health centers to actually update the client’s contact information directly on [Your Texas Benefits] through their accounts, and that is not something that’s extended to everybody unfortunately. HHSC has been piloting this level three access with just federally qualified health centers.”
Lara said so far 44 of the 73 FQHCs were signed up as level three, but that efforts to raise that profile are continuing. TACHC has been providing training to engage the media and get its messaging on issues, such as updating personal information and responding to the yellow renewal notices in the mail, out into the community.
The Kaiser Family Foundation estimates up to 14 million Americans across the country, including those who are eligible, could lose Medicaid coverage during the unwinding period. Stacey Pogue, senior policy analyst at Every Texan, said one of the big risks is that eligible Texans, including children, can lose coverage during this process.
“That’s because people can be disenrolled for procedural reasons,” Pogue said. “So not because the state found them ineligible—because they didn’t complete every step of the renewal process or the application didn’t go to the right address, or all sorts of reasons.
But those barriers that families hit in the process don’t fall evenly, so kids are much more likely to lose Medicaid and remain eligible, and Hispanic and Black Texans are much more likely to lose coverage even though they remain eligible.”
Pogue said there are steps the Texas Legislature can take to prevent loss of coverage. One would be to adequately fund the state’s eligibility enrollment system. Senate Bill 1496 would authorize certain health benefit exchanges to make eligibility determinations under Medicaid and CHIP programs. The bill has yet to receive a hearing in the legislature.
“And the other big risk here is that people can face long delays or waits for benefits just because of the size—of the scope—of the task in front of Texas and every other state. [An] efficient eligibility system is the foundation for making sure we meet food and healthcare needs for eligible Texans. But our eligibility system has really been struggling for the last year and that’s not just in Texas, that’s in [many] states due primarily to staffing issues.”
HHSC has hired more than 1,000 workers in the last year to prepare and worked with its 211 vendor on staffing and resources to meet the projected call volumes. The panel expects the vacancy rate for eligibility staffing to be around 2% heading into next month.
While the in-progress state budget addresses permanent and temporary staffing at HHSC, the agency has looked at ways it can innovatively utilize data and data-driven processes to inform when people are income eligible during renewals. It plans to launch an online automated process later this spring to assist with information updates.