Permanent 90/10 Rule Will Help States Continue Efforts to Modernize IT Systems

Although final publication of the 90/10 rule – providing generous, enhanced federal funding for Medicaid eligibility and enrollment systems – doesn’t quite bring the surprise of opening an unexpected holiday gift, it is still gives us many reasons to celebrate. If CMS had allowed the enhanced funding to expire as initially planned, states would have been worse off than those who end up on Santa’s naughty list and wind up with a lump of coal in their stockings. I shudder to think about how abruptly the end of enhanced federal funding would halt the momentum of state efforts in harnessing technology to transform Medicaid eligibility into a data-driven, consumer-friendly, modernized experience.

Implementing high-performing IT systems is paramount to achieving the ACA’s vision of seamless, streamlined access to coverage at enrollment and renewal. But let’s face it, building and implementing these systems is highly complex; much more so than anyone anticipated. Talk to any state official involved in launching a new system and you will quickly discover that it’s among the toughest challenges they’ve ever encountered. In announcing the decision, CMS explained that while it “expected that fundamental changes to states systems would be completed well before December 31, 2015”….“it is now clear that additional improvements would benefit states and the federal government” (not to mention consumers!).

States have known for some time that CMS was moving toward making the enhanced funding permanent. But that doesn’t diminish the joyful feeling we get from knowing this is a done deal! While it’s important that states continue to expand their system functionality to drive administrative efficiencies and ease of use, at least they don’t have to take short cuts or make hasty decisions before the funding runs out. Moreover, we should not see these systems becoming outdated in short order as technology, and how we use it, quickly evolves.

From our work with the Kaiser Family Foundation in conducting the annual 50-state survey on Medicaid and CHIP, it’s clear that while all states are making progress on the IT front, not all states are where they need to be. And in particular, as we reported in early 2015, many states delinked their human service programs as they built their new MAGI-based systems. Most would like to re-integrate these systems to the benefit of low-income families who qualify for additional work supports such as SNAP or childcare subsidies. But doing so would be challenging if HHS had not extended another sweet deal. Earlier this year, the agency announced that states would have an additional three years – through December 2018 – to take advantage of special rules that allow other human service programs to take advantage of the new Medicaid system functionality by paying only the incremental costs for additional requirements to integrate the non-health programs.

Altogether, these actions give us more reasons to be jolly this holiday season.

A special thanks to the Robert Wood Johnson Foundation for its support of our work on providing feedback to HHS and highlighting how ACA implementation is impacting consumers.

Read more about how ACA implementation is affecting consumers:
CMS Releases State-by-State Designations of Whether Certain Medicaid Categories Meet Minimum Essential Coverage Standards
1095B Forms May Cause Problems for Enrollees Who Transition from Marketplace to Medicaid Coverage
2016 Federal Poverty Levels Are Out; What Does This Mean for the Marketplace and Medicaid?
Little Known Provision Keeps Kids From Slipping Through Cracks Due to Differences in Eligibility Rules
Healthcare.Gov Promises a Snazzier Production for OE3
Wondering What Marketplace Rate Increases Mean for Consumers?
Consumer Assistance and Tools Needed to Ensure that All Eligible Marketplace Enrollees Get Cost-Sharing Reductions Fixes System Glitch in Counting Social Security Income for Certain Tax Dependents
Critiquing the Performance as the Curtain Closes on OE2
Tricia Brooks is a Research Professor at the Center for Children and Families (CCF), part of the McCourt School of Public Policy at Georgetown University.