States Can Make Applications More Accessible During COVID-19 Crisis

The COVID-19 crisis is presenting challenges to people applying for Medicaid and SNAP (food stamps) and — while states have limited ability to substantially modify their systems during the crisis — they can take some steps to make applications more accessible.

Because people can’t apply for Medicaid and SNAP in person due to office closures and social distancing, many people must adapt to a new way of interacting with social service agencies by submitting applications online, through agency call centers, or with the help of community assisters.

States can help them by:

Making online applications and systems more accessible. All states have online applications for Medicaid, and 46 have them for SNAP. Nevertheless, not all users can access the application. To be fully accessible, online applications must be mobile-responsive so that people can use them from mobile devices — the main way that many families use the internet. States should also remove barriers that make it hard for people to use online systems, including burdensome account setup processes and unnecessary remote identity proofing procedures that block people’s access.

Addressing signature requirements for telephonic applications. Many people who are homebound during this crisis may struggle to submit applications because they don’t have access to in-person support, have limited internet access, and can’t obtain paper applications. These individuals need to apply for benefits over the phone, either directly through state agencies or through community partners who help them submit applications. Requiring them to sign applications and mail in signed forms is burdensome and delays benefits. Under existing policy, individuals can sign an application over the phone if the state agency or community partner records and stores their telephonic signature. But with both eligibility staff and community partners working from home, this requirement becomes hard to meet.

The Agriculture Department’s Food and Nutrition Service (FNS) has issued temporary SNAP waivers that let eligibility workers document the household’s attestation as a signature without requiring an audio recording, which enables eligibility staff to take applications over the phone even if they’re working from home and can’t record the signature. At least 18 states have taken advantage of this waiver. FNS has also issued temporary waivers to let community partners get verbal consent from applicants to act as their authorized representatives and sign an online or paper application for the individual.

Similarly, the federal Centers for Medicare & Medicaid Services (CMS) is temporarily letting application assisters get permission by phone to serve as an individual’s authorized representative to submit an online application, which mirrors the process that assisters use to help people apply on HealthCare.gov by telephone. While CMS hasn’t issued formal guidance waiving the requirement for Medicaid agencies to record a telephonic signature, some states are documenting applicant attestation without making a recording.

Many states have laws governing electronic signatures, including telephonic signatures. Governors may be able to temporarily waive state requirements through executive orders or other disaster authorities. And because serving as an authorized representative is an important responsibility and creates risk for both the applicant and community partner, states may wish to limit authorized representatives to those who receive training and abide by certain quality standards, and to establish monitoring procedures to ensure client protections.