In January 2020, the Secretary of Health and Human Services (HHS) declared a COVID-19 public health emergency (PHE), which has recently been extended to January 11, 2022. During this time, Floridians enrolled in Medicaid and the Children’s Health Insurance Program (CHIP) have been able to keep their coverage without having to re-enroll, a rule referred to as “continuous coverage.” Widespread job loss during the initial phases of the pandemic led to increases in the number of people enrolled in Medicaid and CHIP. According to Florida’s Agency For Healthcare Administration (AHCA), the state’s Medicaid agency, an additional 826,000 people enrolled in the program between March 2020 and January 2021, bringing the total number of enrollees to 4.56 million during that time frame. As of October 2022, there were over 5.5 million people enrolled in Medicaid in Florida. None of these newly enrolled individuals have had to go through the process of re-enrolling: this is concerning, as they might not know to submit renewals once the PHE ends. Additionally, people who have been enrolled in Medicaid since before the pandemic may have moved or not updated their contact or financial information, which could cause them to lose coverage — even though they remain eligible. This “churn” has the potential to affect the millions of Floridians who rely on Medicaid for their health care.
Floridians will face numerous barriers to keeping their Medicaid coverage once the PHE ends.
Under the Centers for Medicare and Medicaid Services (CMS), a branch of HHS, every state is required to release a plan to make the process of re-enrollment easier and minimize the amount of people that will lose coverage because of churn. According to Kaiser Family Foundation (KFF), as of January 2022, only 27 states had determined their approach, and as of November 2022, Florida’s Department of Children and Families (DCF), which is responsible for administering Florida’s Medicaid, SNAP, and TANF programs, has not formally released its plan for when the PHE ends.
What steps is the state of Florida taking to streamline Medicaid and CHIP eligibility and enrollment in advance of the PHE ending?
Renewal and Eligibility Notices
Advocates have expressed concern that the renewal and eligibility notices DCF was mailing out before the COVID-19 pandemic were difficult to understand, and individuals have stated that these notices often felt threatening or were too long, or that the language was not accessible. When the PHE ends, it will be important for both Floridians who had to renew in the past and those who will be renewing for the first time to understand their eligibility and options to apply for Medicaid. They may also need assistance finding alternative coverage if they no longer qualify.
Modes for Submitting Applications
In Florida, Medicaid applications can be submitted online through DCF’s ACCESS portal, in person, by mail, and by telephone under certain circumstances. The same Medicaid application can be submitted for other benefits too, like SNAP and TANF. The ACCESS portal allows individuals to review their application status, report changes in income and address, view notices from DCF, renew coverage, upload verification documents, and receive electronic notices. There is not a mobile-friendly format for the ACCESS portal, so individuals who would need to apply via smartphone or tablet may face barriers.
Most states use a process called ex-parte renewal to automatically determine whether individuals are still eligible for Medicaid. This renewal process is beneficial because it ensures that eligible people retain their coverage without added barriers of having to re-apply for Medicaid. This is done through confirming income by using data that is already available. Florida’s ex-parte renewals are verified through the Federal Data Services Hub, the State Wage Database, State Unemployment Database, and other commercial databases.
Although Florida uses the ex-parte process, less than 25 percent of renewals are completed in this format. This is very low compared to other states. When the state is unable to process ex-parte renewals, individuals are sent renewal forms to fill out, which can create more barriers if individuals have moved or not updated their contact information. There is room for Florida to improve its ex-parte process and decrease the number of people who have to submit renewal forms for Medicaid.
Medicaid Renewal Communications
It is anticipated that Florida will have a high number of people who need to submit Medicaid renewal applications. According to data from AHCA, as of October 2022, there are approximately 5.5 million Floridians enrolled in Medicaid, which is up from the 3.8 million individuals who were enrolled in January 2020 at the start of the PHE. Over 1 million of these enrollees may not have previously undergone the process of renewing Medicaid. Many states have adopted follow-up plans to contact those who need to renew. While these plans recommend contacting individuals who need to enroll by mail, individual phone call, automated phone call, text message, or email, DCF has opted only to contact individuals via mail or email. This is problematic because if an individual does not respond, they will lose coverage. Florida is not taking advantage of the opportunity to contact via phone or text, and if an individual has recently moved, attempts to contact via mail will be ineffective.
The state must take action to ensure that the renewal process is streamlined so that Medicaid recipients are seamlessly renewed or supported to find alternative coverage.
Some states have adopted measures to update mailing lists before the end of the PHE by using electronic data matches from the U.S. Postal Service’s National Change of Address Database. Other methods to update mailing addresses include asking the agencies responsible for providing care to contact enrollees, checking for updated addresses in SNAP or other programs, conducting outreach, or accepting updated addresses on behalf of enrollees from navigators/assisters and Medicaid providers. According to KFF’s survey, the state plans to use two of these seven possible measures – requesting that MCOs contact enrollees and conducting “update your mailing address” outreach.
According to KFF’s 50-State Unwinding Tracker, many state agencies have expressed concerns about the staff capacity that will be needed to successfully complete new processes at the end of the PHE. Part of Florida’s plan to mitigate this concern is to increase the number of staff who can assist with determining eligibility for Medicaid enrollees. In KFF’s survey, it was noted that Florida plans to do this by approving overtime, hiring new workers, borrowing from other staff agencies, and hiring contractors.
Room For Improvement
Floridians will face numerous barriers to keeping their Medicaid coverage once the PHE ends. The state must take action to ensure that the renewal process is streamlined so that Medicaid recipients are seamlessly renewed or supported to find alternative coverage. In order to reduce coverage losses for eligible individuals, Florida can improve the language on renewal notices and make them easier to understand, increase the ex-parte renewal rate by adopting more database searches to determine eligibility, improve communication with those who do have to renew, and increase staffing at DCF. As of November 2022, the state has not released a formal plan for the end of the PHE. Advocates in the state of Florida should continue to request that these plans be released by DCF to ensure that eligible people do not unexpectedly lose their health insurance.