Unwinding Wednesday #16: Are State Eligibility Systems Ready for the Unwinding?

As we approach the starting line for unwinding the Medicaid continuous coverage protection on March 31, 2023, states are busy finalizing their unwinding plans and making sure their systems are ready to go. Medicaid IT systems are complex, and yet they are at the heart of eligibility and enrollment. Done well, systems can greatly streamline and simplify the application and renewal processes, replacing outdated paper-driven manual processes, and thereby reducing the administrative burden on the state eligibility enterprise while removing red tape barriers to coverage for children and families. But systems are only as good as the design and programming on which they are built. And testing all aspects of system performance is essential to identifying and resolving unexpected glitches that inevitably arise when major changes are made.

To ensure system readiness for the unwinding of the continuous coverage protection, CMS is requiring states to provide three system readiness artifacts (as they are known in the IT world) for CMS’ review. These include a configuration or implementation plan, a test plan, and test results. In this unwinding Wednesday blog, we provide a high-level overview of this critical aspect of preparing for the unwinding. Keep in mind that system readiness is much further downstream of planning for system changes and programming those changes into the system. But testing readiness is where the rubber meets the road. If testing is skipped or skimped, undetected system problems are likely to occur that can impact beneficiaries’ eligibility and enrollment and result in more work for states to fix the problem.

Configuration or Implementation Plan

This plan identifies how the state will test the changes made to the system. It should also include any PHE-related flexibilities the state intends to end or extend during the unwinding.

Test Plan

The test plan documents how the state will test each system component or module. It should include a minimum number of testing stakeholders (wonder who they mean by this, because I’d raise my hand!), the types of testing, testing data requirements, the testing schedule, and other technical tests that few of us are likely to understand.

Test Results

As the name implies, this document reports the results of the testing. It should include summary metrics indicating a percent pass rate and a percent fail rate that occurs during testing. It must also document any defects and the state’s schedule for resolving such defects.

To go any deeper into the technical aspects of system readiness would likely have most Say Ahhh! readers’ eyes glazing over. So, I’ll spare all of us those details. But it’s reassuring to know that CMS is monitoring system readiness, which will be essential to the success of any state’s unwinding efforts.

[Editor’s Note: For more information, visit our PHE Unwinding resource page where you’ll find other blogs in this series, reports, webinars and the 50-state tracker.]


Tricia Brooks is a Research Professor at the Georgetown University McCourt School of Public Policy’s Center for Children and Families.