Say Ahhh! readers know that I’m bullish on using technology to move Medicaid and CHIP toward data-driven, real time eligibility and enrollment. But having worked through the implementation of a new system as a CHIP director, I know how challenging this task can be. On top of that, Medicaid and CHIP are undergoing a full makeover with the conversion to modified adjusted gross income standards (MAGI) and new requirements to verify eligibility through electronic data sources. Throw in some foot-dragging in states that hoped the ACA would go away (it’s not!) and you have varying degrees of readiness to conduct the first round of MAGI-based renewals. Recently, CMS announced new mitigation strategies for conducting renewals that will give states a little more time to fully develop their new systems.

First, CMS clarified that states may conduct ex parte renewals based on the Medicaid rules for determining household size for non tax-filers. Ex parte renewals have been a long-standing policy that relies on other sources of eligibility information (i.e., state quarterly wage data) to streamline the renewal process and reduce the paperwork burden on states and families. What the clarification means is that states can renew eligibility by using family relationships to determine the household size rather than requiring (at least temporarily) families to provide additional information about their tax dependents. It’s important to note that the number of people in the tax household is quite often the same as the number of people in the family. The caveat is that states cannot deny eligibility using non-filer rules. If it appears that an enrollee is not eligible, the state must conduct a full MAGI-based renewal.

Additionally, CMS announced two new mitigation strategies to expedite renewals:

• Similar to the targeted enrollment strategy, states can use SNAP-based income to renew eligibility for Medicaid for up to 12 months from the last SNAP renewal or determination. For example, if someone was determined eligible for SNAP in May 2014, and the state uses that information to renew Medicaid in August 2014, the next Medicaid renewal would be set for May 2015.

• States may also facilitate renewals for individuals who have no change in income or household size by sending a pre-populated form and allowing individuals to affirmatively attest to no change. This is not a passive process; the individual must respond to the notice, affirming that they want to continue coverage and attesting that the household size is the same and income remains below the Medicaid cutoff.

In presenting the new options, CMS urged state agencies to train application assisters, navigators and call center staff on the renewal process. States that use a managed care delivery system can also engage health plans in conducting outreach, providing assistance and sending supplemental notices.

The availability of these new strategies doesn’t mean that states can hold out forever. At a recent Medicaid conference in Denver, Cindy Mann, CMS director of Medicaid and CHIP, urged states to wean themselves off enrollment and eligibility mitigation plans and workarounds and challenged agencies to enact Medicaid enrollment systems “that we have all envisioned” by the end of this year. There’s also the pressure of funding. CMS is paying 90% of the cost of new system development but only through 2015.

Some states need to step up their game. High-performing systems bring a lot of advantages to states and beneficiaries: less churn, lower administrative workloads and costs, fewer gaps in coverage and, most importantly, timely access to health care.  While phasing in system functionality is a rational way to avoid system glitches that make it difficult for eligible children and families to enroll and retain coverage, straggling states should look to leader states for ways to accelerate their system deployment. Ultimately, all states should strive for the kind of gains that Louisiana achieved years ago: retaining virtually all eligible individuals at renewal while reducing red tape and administrative costs.