Last week CMS announced plans to replace the technology and processes used to coordinate eligibility and enrollment through electronic accounts between the federal marketplace (healthcare.gov) and states that use the federal platform. The account transfer (AT) process, although riddled with glitches, has been in place since the Affordable Care Act’s coverage expansions began in 2014. The goal of the Account Transfer 2.0 initiative is to fully implement the ACA’s “no wrong door” policy where individuals can seamlessly access Medicaid, CHIP, the Basic Health Plan, or Marketplace subsidies by completing a single, streamlined application, or when there is a change in eligibility.   

The account transfer process is essential to ensuring coordination across public coverage options, also known as the “insurance affordability programs” (IAP) The purpose is to exchange all information provided by new applicants and by enrollees at renewal or with a change in circumstances that results in eligibility for a different IAP. The federal AT process impacts the 32 states that use the federal marketplace for eligibility and enrollment. States that operate their own state-based marketplace eligibility systems use their own processes to coordinate eligibility. A quarter of the 32 states using the FFM (which screens eligibility based on a state’s specific rules) accept the FFM’s eligibility review as a final determination. Other states use the FFM’s “assessment” of eligibility and treat the account as a new application. But if states receive incomplete or inaccurate data, they may not be able to take action to enroll eligible individuals.

Lost, incomplete, or inaccurate ATs often result in the individual having to submit a new application to a different program. By the time they figure out that they need to contact or newly apply to another agency, they are likely to experience a gap in coverage. Individuals losing Medicaid, who are potentially eligible for subsidized Marketplace coverage, may miss limited open or special enrollment periods and risk becoming uninsured.

So, Account Transfer 2.0 can’t come soon enough. But we’ll have to be patient as these technology builds and process improvements take time to design, test, refine, and deploy. This will be a multi-year initiative to overhaul the legacy AT service, but the end goal is to provide eligible individuals with a better chance of maintaining continuous coverage as they move between public coverage sources. AT 2.0 services are expected to include enhanced technical assistance to states and reduced state burden and cost for eligibility and enrollment systems.

There are some techie details included in the information bulletin worth looking into for those who are proficient in that field. If a JavaScript Object Notation (JSON)-based data model means anything to you, it might be worth a full read. But otherwise, you can skip that to where the bulletin talks about state engagement and state agency and CHIP responsibilities. Manatt Health reports that “a group of six states (Alaska, Hawai’i, Iowa, New Hampshire, South Carolina, and Tennessee) have volunteered to provide early input into the data elements, definitions, and data quality controls of AT 2.0. Throughout the multiyear development process, all states will be invited to weigh in on the feasibility, development, and implementation of AT 2.0’s structure and rollout. Early adopters will launch the new system in 2027.”