States Should Streamline Medicaid Enrollment and Renewal for Older Adults and People With Disabilities Ahead of Unwinding

As states prepare to “unwind” the COVID-19 pandemic-related Medicaid continuous coverage requirement and resume terminations of coverage as soon as April 1, they should streamline eligibility determinations for older adults and people with disabilities, who face unique challenges with the Medicaid enrollment and renewal process.

States have significantly streamlined processes for parents, caretakers, children, and newly eligible adults. These groups are often referred to as the “MAGI” population because their eligibility is based on a technical income standard called “modified adjusted gross income.” Federal rules require states to allow MAGI groups to submit applications and other forms online or over the phone and to renew their coverage no more frequently than every 12 months. They also prohibit states from conducting interviews for these groups during the application or renewal process.

But federal rules do not currently require these simplified processes for adults aged 65 and older and people with disabilities, known as the non-MAGI population. As a result, non-MAGI enrollees often need to take additional steps to enroll and stay enrolled in coverage — extra steps known as administrative burdens. Administrative burdens that non-MAGI enrollees experience include more cumbersome paperwork requirements, being subject to time-consuming and burdensome interview requirements when applying for or renewing coverage, and at times needing to renew their coverage more frequently than every 12 months. Administrative burdens disproportionately affect people of color and lead to churn, the process of eligible people losing coverage at renewal and having to reapply. They have also led to under-enrollment in many non-MAGI Medicaid programs.

Many of the streamlined procedures described above are expected to be required for non-MAGI groups when a proposed eligibility rule from the Centers for Medicare & Medicaid Services is finalized, likely later this year. The rule will better align non-MAGI and MAGI policies around eligibility periods, renewal processes, and submitting information online and over the phone. While states are not yet required to implement these streamlined processes, they should quickly assess which policies they can quickly implement now to reduce workload considering the enormous task ahead to redetermine eligibility for all Medicaid beneficiaries during unwinding.

Improvements to the enrollment and renewal process for the non-MAGI population that states should implement now include:

• Allow applications and renewals to be submitted through the same pathways available to MAGI groups, specifically online and over the phone.
• No longer require in-person interviews as part of the application or renewal process.
• Provide enrollees with a pre-populated form if they need to provide additional documentation to renew their coverage, with a minimum of 30 days for them to sign and return it. If they don’t return the paperwork on time and their coverage is terminated, states should provide enrollees a 90-day reconsideration period without having to complete a new application.
• Renew non-MAGI enrollee coverage no more frequently than every 12 months.
• Accept data from the Low-Income Subsidy program as sufficient for an application for Medicare Savings Programs (MSPs) and use that data to promptly determine MSP eligibility if additional information is not needed.

Those states that have not yet implemented all of these improvements should make these changes now ahead of unwinding to make the application and renewal process more accessible for non-MAGI groups and to reduce both agency and client burden.