CMS, FNS Announce Additional Demonstrations to Evaluate Impacts of Data Sharing

On Friday, the Centers for Medicare & Medicaid Services (CMS) posted a Center for Medicaid and CHIP Services (CMCS) Informational Bulletin to notify state Medicaid agencies of an additional demonstration to encourage and analyze interagency data sharing to help eligible students access free and reduced-price school meals. The new demonstration, issued by the U.S. Department of Agriculture Food and Nutrition Services (FNS), builds upon previous demonstrations conducted in 2012 and 2016 to evaluate the impact of using eligibility data collected by Medicaid to directly certify new and currently enrolled students in free and reduced-price school meals.

Who is eligible for the demonstration and how do they apply?

State nutrition agencies that administer the National School Lunch Program and School Breakfast Program– which house the free and reduced price school meals program– may apply to participate in the demonstration project for a portion of their local education agency (LEA), or to cover the entire state. Eligible agencies must not be approved to participate in existing demonstration projects that started prior to the 2020-21 school year. States that are participating in existing free price meal demonstration projects, but are specifically interested in conducting direct certification for free and reduced-price meal eligibility in all or a portion of their LEAs are also eligible.

To ensure optimal partnership between agencies, state nutrition agencies must have an agreement in place with their Medicaid agency prior to the start of the data matching process to FNS, alongside a letter of commitment from the Medicaid agency. If a data sharing agreement already exists between the two entities, Medicaid agencies can supplement the application by submitting copies of the agreement. More information on how states can apply for the demonstration program including application package information and templates can be found through FNS here.

The due date to apply to participate in the demonstration and for funding to cover project costs for the 2022-23 school year is September 30, 2021, and September 30, 2022 to participate in the following school year.

What students are eligible for direct certification in this demonstration?  

In order to be eligible for direct certification, a student must (1) receive Medicaid themself or live in a household with a child that receives Medicaid, and (2) have a household income that is equal to or below 130% of the federal poverty level (FPL) to qualify for free school meals or 185% FPL for reduced-price meals. Eligibility in separate CHIP programs will not be considered for direct certification in this demonstration. However, eligibility determinations from direct certification cannot negatively impact enrollment for any child already deemed eligible for free and reduced-price meals. 

Why does this matter?

While this demonstration shows continued support at the federal level for utilizing data sharing as a tactic for streamlining eligibility, it is not the first of its kind. A similar policy in the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), known as adjunctive eligibility, simplified the application process using eligibility data from three of the most prominent anti-poverty programs: Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF) and Medicaid. According to the National WIC Association, nearly 75% of WIC participants apply using adjunctive eligibility, saving a majority of the families that apply the burden of providing multiple, and often duplicative, documents and forms of verification to WIC clinics. As such, adjunctive eligibility has the benefit of streamlining paperwork, reducing administrative error, and increasing coordination between WIC and other programs. Using adjunctive eligibility as a baseline for what we could see at the end of this demonstration, direct certification using Medicaid data would be advantageous. This would not only be helpful to busy families but to LEAs, many of which already face difficulties with billing and other administrative needs from other public programs.

Given that Medicaid already provides key health services within schools, taking advantage of these demonstrations is a smart move for states that want to utilize agency coordination to its full potential, and address whole-child health. We look forward to seeing the results of these demonstrations!

Margaux Johnson-Green is a State Health Policy Analyst with the Georgetown University Center for Children and Families.