Request a Demo

The Return to Normal: Medicaid Redetermination Edition

By the time the end of March rolls around, we will have seen just over 1,100 days of continuous Medicaid and CHIP enrollment. Federal guidance within the 2023 Consolidated Appropriations Act effectively decoupled continuous enrollment provisions from the Public Health Emergency (PHE) and will allow states to resume their redetermination process as soon as April 1st. 

Most states and many plans have already completed the first phase of the unwinding by encouraging enrollees to update their contact information to ensure they receive their renewal paperwork when it arrives in the mail. And while most all of us reading this piece are well aware of where we’ve been over the last year and what the next one might look like, a recent Urban Institute study in December 2022 found 6 in 10 adults in Medicaid-enrolled families were not aware of an upcoming return to the regular Medicaid renewal process.

You’re probably thinking, “How is this possible? It’s all we’ve been talking about and planning for months and months!” Well, maybe we shouldn’t be so surprised. Medicaid/CHIP enrollment increased by 20 million individuals since February 2020 accounting for nearly 30% of all covered lives. That’s 20 million individuals who likely have never completed a traditional or pre-pandemic redetermination and three years since the last time everyone else has. Lest we forget a lot has changed and occurred over the last three years in general.

Stats and surprises aside, we still have a long road ahead of us and a lot of work to do. Thankfully our regulatory friends like CMS and the FCC have stepped up to help keep individuals from slipping through the cracks. CMS has provided a strategic toolkit calling for states and plans to work together in timely sharing of enrollment data and contact information, for states to expedite content approvals or provide pre-approved language for member outreach, and for enhanced processes for moving individuals who no longer qualify for state-based programs to marketplace offerings. The FCC’s recent declaratory ruling that clearly states the provision of a phone number on an enrollment form constitutes as express consent allowing federal and state agencies and their partners to make Medicaid enrollment calls and send text messages without violating call or text prohibitions. Plans should take full advantage of the resources provided to them by incorporating each toolkit and clarified regulation into their overall member engagement strategy.

Learn more about outreach strategies for the end of continuous enrollment by viewing our redetermination webinar series featuring Kaiser Permanente and Mostly Medicaid »

Key Engagement Factors for the Return of Redetermination

Now let’s talk engagement strategy. Most plans will be using CMS or state-approved content and timelines are tight, so there may not be as much room for the creativity we see when dealing with other engagement topics like closing gaps in care or encouraging timely rx refills. That doesn’t mean, however, that you can’t still take a strategic approach in areas where you can still have an impact, such as channels, personalization, and branding. 

Channels: We know one single communication channel isn’t going to be enough, and it’s just not how people are consuming information or connecting to resources. Adult Medicaid beneficiary smartphone or tablet ownership rates are similar to the general US adult population, and 47.4% of dually eligible Medicare beneficiaries report using the internet to get information. An effective and successful engagement strategy is delivered through multiple channels by combining digital outreach like SMS and email with traditional modes of communication like mail and phone calls. mPulse is currently working with over 30 Managed Care Organizations across more than 20 states within different phases of their redetermination efforts to support engagement on all channels and channel combinations.

Personalization: After selecting your channels, be sure the messages you are sending are personalized and relevant to the member. Even if you are using pre-approved language for your redetermination outreach, make sure your salutation and any other merged fields are in the proper case and not all caps. Even an Excel novice can easily convert cells in all caps to proper case by applying a =PROPER formula to your selected cells. Proper case is easy, but what about language preferences? Reaching your Limited English Proficient (LEP) members can be difficult, especially when you don’t know who they are or what their preferred language is. For example, mPulse technology allows for you to go beyond typical language challenges or compliance required taglines by automatically transitioning between English and Spanish in our two-way SMS conversations.

Branding: Brand awareness and recognition leads to trust. You want your members to automatically know who all messages are coming from so they will not only trust it but also complete the desired request or action. Consider other communications that may be coming from your organization around the same time and coordinate your naming conventions to maximize brand awareness. Help get your brand on the right side of the inbox or in their known contacts by encouraging your members to store your phone number or SMS short code on their device or enhance those efforts by deploying mPulse Virtual Contact File (VCF) messages. 

The New Normal for Medicaid

The return to normal, or rather the return to the new normal is here, and there is no slowing it down. This is still uncharted territory with a lot of work yet to be done, but if we have learned one thing here today, it is that working together, maximizing resources, and leveraging technology to provide a personalized member experience will be the key to successful redetermination efforts.

For more insights into how to deliver this experience to your medicaid population, view our on-demand webinar series for Redetermination.

Longest. Unwinding. Ever. The Continuous Wind Down of Continuous Enrollment

912 days sit between the beginning of the Public Health Emergency (PHE) and today, July 26, 2022. The PHE has been renewed 10 times, with the latest extension set to expire on October 13, 2022. There has been no shortage of speculation around the last two extensions, especially after the Biden-Harris administration committed to providing states with at least a 60 day notice prior to its plans to terminate or allow the PHE to end.

In March of 2020, the Families First Coronavirus Response Act (FFCRA) was signed into law. This particular piece of legislation focused on many programs impacting children and families, including but not limited to Supplemental Nutritional Assistance Program (SNAP), the Women Infants and Children (WIC) program, family and medical leave, school lunch, emergency paid sick leave, and state based programs for Medicaid and Children’s Health Insurance Program (CHIP) eligibility and enrollment requirements. The latter of these provisions effectively froze Medicaid disenrollment during the PHE allowing for continuous coverage for current beneficiaries. Prior to the pandemic, states were required to reprocess eligibility for most of its enrollees on an annual basis, this process is referred to as redetermination.  

Medicaid and CHIP enrollments have increased by approximately 19% or 13.6 million enrollees between February 2020 and September 2021 with an additional 1.2 million enrollees added to the roster since the September report. To offset increased program spending coupled with decreased state tax revenue, the FFCRA authorized a 6.2 percentage point increase in the Federal Medical Assistance Program (FMAP) and in return expected continuous enrollment. This FMAP bump will continue through the end of the first quarter in which the PHE ends. 

When the End Comes…

Now that we’ve covered some of the basics, let’s look what it means for the plan when the PHE and continuous enrollment ends, and redetermination resumes for its beneficiaries. The end of continuous enrollment is expected to create the single largest health coverage transition since the first Marketplace Open Enrollment. Due to the high volume of unprocessed eligibility renewals and the increase in membership, states have been given a 12-month unwinding period to manage this administrative task. The Department of Health and Human Services (HHS) has issued an Unwinding Toolkit and CMS has encouraged states to only process 1/9 of its total caseload in a single month; processing more than this creates an increased risk of people falling through the cracks and being unnecessarily disenrolled resulting in a loss of coverage and potential increase of additional administrative work to bring them back in.  

Keep in mind each state will have its own pathway and plan to work through this transitional phase. For example, some states have indicated they will target enrollees who appear to no longer be eligible first and others plan to conduct renewals on a monthly basis based on the individual’s initial enrollment month and some states have also reported they plan to process the backlog as soon as 3-6 months with others using the full 12 plus months.  

Projections for total Medicaid and CHIP growth during the pandemic and scenarios calculating total loss of coverage continue to shift and grow with varying levels of certainty and range from 5 to 14 million enrollees losing coverage. Even at the lowest end of the loss projections, five million people is an awful lot! While some loss may not be preventable, complete, and total disruption can be avoidable for those who be eligible for coverage on a Marketplace (aka Affordable Care Act or ACA) plan. This shift to retention will be more bearable and less burdensome if American Rescue Plan Act (ARPA) subsidies continue for the estimated 13 million Marketplace enrollees currently receiving a premium reducing subsidy.  

Planning for the Unwinding of Continuous Enrollment

So, we’ve covered some basics on what it means for the plan (a lot of work ahead), what it means for the member (a lot of uncertainty still remains), and now about what it means to everyone in between which in this instance is us, mPulse and that’s where I start to get excited. There are phased approaches and best practices from our friends in California who have been given the green light to reach members in just about any way possible even allowing plans to solicit opt-in consent for future updates by text message to the East coast where communications to CoverVA enrollees in Virginia are being encouraged to update their contact information by signing up for email or text alerts and following via social media.  

I’m no math whiz, but this one is easy: X + 14 = Regular Redetermination Resumes 

With X being the unknown number of additional PHE extensions and 14 the number of total months allowed to manage the backlog at the end of the PHE you’ll find yourself back where you were before COVID-19 was a household name. Regardless of where you are in your own state’s phase approach, you can count on trusted partners like mPulse to engage the unengaged and reach the unreachable in your membership. Not sure where to start? Reach out to learn more about the power of SMS and find out how many of your contact numbers are mobile vs. land lines.

2023 Star Ratings: Experience Reigns Supreme as Equity Waits in the Wings

To say the events of the last two years had an unprecedented and unconventional impact on health plans would be an understatement. Fast forward from March of 2020 through the better of logic within The Extreme and Uncontrollable Circumstances Policy producing temporarily inflated 2022 Star Ratings to today. While we wait for either the end or extension of the current Public Health Emergency (PHE), the Centers for Medicare and Medicaid Services (CMS) continues to work tirelessly to further its pledge to put patients first in all programs.

To truly put patients first, however, you have to address their needs and provide support to the plans, practitioners, and communities who care for our most vulnerable populations. Back to the traditionally timed release of the 2023 Medicare Advantage and Part D Advance Notice Part II, CMS provided plan sponsors with a sneak peek at its next sizeable agenda with an emphasis equity! This takes me back to when we first read about proposed weight increased for CAHPS® and the other member experience measures. Back when it felt nearly impossible and so much more difficult than managing numerator compliance for HEDIS® and Adherence measures. But we started taking better care of our members and alas, here we are looking at all of those 4s in the weight column of 16 separate experience measures and hoping it all shakes out in favor and balances the expected deflation in post-pandemic performance metrics.

CAHPS® and the Member Experience

CMS makes good on its promise to lend a bigger voice to the beneficiary as it proceeds with the increased weight of its member experience measures, including the Consumer Assessment of Health Plans and Systems (CAHPS®) survey. The 2022  MA-PD CAHPS survey fielding began last week and I’m sure teams are eagerly awaiting even the earliest peek at performance from their survey vendors ahead of Westat reports later this summer while the rest of us will have to wait until public data becomes available in early October. Even the best and most robust regulatory and off-cycle surveys will only represent a small percentage of members at one moment in time. Plans need more experiential and real time data around common and frequently used benefits that scales not only the entire member population, but the entire member year. mPulse Mobile has developed an event-based check-in program that not only gathers valuable member experience and sentiment data, but also has the ability to address dissatisfaction and solve common pain points in real time using its patented natural language understanding and conversational messaging.

The Extreme and Uncontrollable Circumstances Policy

As expected, The Extreme and Uncontrollable Circumstances Policy provided additional COVID-19 relief and over inflated performance numbers that will feel like a one-time get out of jail free card with the ‘better of logic’ that will not be in play for 2023 Star Ratings. This ‘better of’ method produced inflated performance numbers that will be difficult to sustain in future years. As experience continues to reign supreme, plans should prepare everyone from members to senior leadership for potential disruption and work to find ways to offset the potential loss of the one-time inflated bonus payments.

No new measures for 2023 and some moving to the display page

With no new measures for 2023 and some moving to the display page for a few years, plans will have the opportunity to continue efforts to close gaps, connect members to appropriate care, and review their data for another year. Controlling Blood Pressure makes its return to the active page with a 1x weight while Plan All Cause Readmission remains on display for one more year before returning with a 1x for 2024 Stars. Two key HOS measures, Improving or Maintaining Physical Health & Improving or Maintaining Mental Health will see their time on the display page for 2022 & 2023 as they were too disrupted by COVID-19.

HEDIS and Telehealth

HEDIS and Telehealth seem to be here to stay and work together. According to the American Journal of Managed Care, telehealth claim lines increased 3.060 percent nationally from October 2019 to October 2020. As members seek care outside of the traditional office setting, providers and payers still have a need and obligation to capture the full burden of illness and these updates include additional code sets to be allowed for measure inclusion or exclusion when captured via telehealth visits alone. This is just another example of how members, plans, and providers are embracing digital technologies. We’ll keep an eye on these flexibilities as the House recently extended virtual care flexibilities beyond the public health emergency.

Is Health Equity the new Experience?

CMS provided information on the potential development of five new equity related measures for Parts C and or D.

    • Driving Health Equity (Part C and D)
    • Stratified Reporting (Part C and D)
    • Health Equity Index (Part C and D)
    • Measure of Contract’s Assessment of Beneficiary Needs (Part C)
    • Screening and Referral to Services for Social Needs (Part C)

After two wild years of recycling data and rates due to COVID-19 to the temporarily over-inflated 2022 Part C & D Star Ratings due to the expansive extreme and uncontrollable circumstances policy, 2023 proposed changes seem to be minimal and mild in comparison. The last handful of years have had plans focusing heavily on improving their member experience with 2023 Stars rounding out the increased weights from 1.5x to 4x. Accounting for just over 50% of the plan’s overall Star Ratings weight, experience will remain top of focus for the foreseeable future. But no time to get comfortable because equity and social determinants are hot on experience’s heels with more than a handful of related measures and methodological enhancements. Proposed changes and new measure concepts must go through federal rulemaking and stabilize on the Display Page for a minimum of two years before becoming an active Star Ratings measure. mPulse Mobile has developed solutions to address and promote social determinants as well as stratify your member data within our engagement solutions to support and map to internal efforts.

It’s never too late to develop or enhance your member engagement strategy. How will you continue to wrap your arms around your members as we (hopefully) move from pandemic to endemic and beyond?

Reimagining CAHPS & HOS Engagement

When it comes to impacting and improving member experience measures, we can easily name more challenges than we can solutions. Blinded surveys, small sample sizes, black-out rules, and perception vs. reality are just a few of the historical challenges health plan partners have faced over the years. As if those weren’t enough, now we’re looking at new and increasingly difficult obstacles this year. Some challenges to keep in mind include the following:

  • 4x weighting for the 2022 CAHPS survey to round out the increased weighting for the member experience measures which will account for over 50% of 2023 Star Ratings. 
  • Recently released Westat reports revealed an upward trend in CAHPS cut-points making it even harder to attain and maintain top performance. 
  • The Extreme and Uncontrollable Circumstances policy which allows plans to use the higher of the current year or the previous year’s Star Rating is expected to leave over-inflated performance in its wake, which will be difficult to maintain over the next several Stars years. 
  • NCQA’s extension of its HOS black-out period from four to eight weeks before, during and after fielding left some plans in the lurch and forced them to pivot or scrap their planned outreach and educational strategies. 
  • The temporary removal of HOS’ two 3x weighted process measures, Improving or Maintaining Physical Health and Improving or Maintaining Mental Health from the active page and onto the Display page for both the 2022 and 2023 Star Rating years. While it might be welcomed as a breather, it should not be an opportunity to lose focus, but instead an opportunity to re-evaluate your overall HOS strategy.  

 CMS isn’t backing down on its promise to lend a bigger voice to the beneficiary and each year the Medicare population continues to embrace and adopt digital communication and technology. It’s time to ditch obsolete legacy outreach programs and reimagine CAHPS and HOS engagement using the modern innovative trends and technology your members interact with daily. What consumers expect from their favorite brands, they’ll expect from healthcare. 

 mPulse Mobile, the leader in Conversational AI solutions for the healthcare industry, drives improved health outcomes and business efficiencies by engaging individuals with tailored and meaningful dialogue. mPulse Mobile combines behavioral science, analytics and industry expertise that helps healthcare organizations activate their consumers to adopt health behaviors. 

 With over a decade of experience, 100+ healthcare customers and more than 400 million conversations annually, mPulse Mobile has the data, the expertise, and the solutions to support your CAHPS and HOS engagement strategy. 

 To ask a question or request a call, go to: mpulsemobile.com/contact

2022 Star Ratings: What We Know and What We Think We Know

To say the events of the last year had an unprecedented and unconventional impact on health plans would be an understatement. From early January 2020 when Health and Human Services (HHS) declared a Public Health Emergency (PHE) to aid the nation’s healthcare systems in responding to COVID-19 through the cancellation of the 2020 HEDIS and CAHPS collection and now with vaccines becoming vaccinations, the Centers for Medicare and Medicaid Services (CMS) has worked tirelessly to continue its pledge to put patients first in all programs.

To put patients first in all programs, you have to address their needs and provide support to the plans, practitioners, and communities who care for our most vulnerable populations. With the earlier than anticipated release of the 2022 Medicare Advantage and Part D Advance Notice Part II, CMS provided plan sponsors more time to prepare their bids during unprecedented times. While the better part of this Advance Notice focused on rate and payment policy, it provided plans with important updates and changes related to the Star Rating program which can have a tremendous impact on Quality Bonus Payments (QBP).

Following the earlier-than-anticipated Advance Notice in October 2020 came the equally early Final Rule in January 2021. Here are a few noteworthy changes that we discussed in the fall that are here to stay for 2022. For a deeper discussion, watch the 2021 Star Ratings panel with Rex Wallace, Jim Burke, and myself below.

  • CAHPS and the Member Experience. CMS is making good on its promise to lend a bigger voice to the beneficiary and will proceed with the increased weight of its member experience measures, including the Consumer Assessment of Health Plans and Systems aka CAHPS survey. While the 2021 CAHPS survey will still have a weight of 2x each (not including the flu measure) for the 2022 Star Ratings, the importance of member experience and perception is greater than ever as these measures will contribute to over 50% of the overall weight in 2023 Stars. Even the best and most robust regulatory and off-cycle surveys will only represent a small percentage of members at one moment in time. Plans need more experiential and real time data around common and frequently used benefits that scales not only the entire member population, but the entire member year. mPulse Mobile has developed an event-based check-in program that not only gathers valuable member experience and sentiment data, but also has the ability to address dissatisfaction and solve common pain points in real time using its patented natural language understanding and conversational messaging. Learn more about our CAHPS Solution.
  • Extreme and Uncontrollable Circumstances Policy was amended to note any additional COVID-19 relief under this policy for 2021 measurement year will have to come through future rule making. CMS adjusted its disaster policy and plans will be allowed to use the ‘better of’ between some of its 2021 and 2022 measure ratings. This ‘better of’ method may produce inflated performance numbers that will be difficult to sustain in future years. Plans should proactively identify their at risk areas and deploy a strategy at scale to offset a potential loss in QBP for future years.
  • With no new measures for 2022 and some remaining on the display for another year, plans will have the opportunity to continue efforts to close gaps, connect members to appropriate care, and review their data for one more year. Controlling Blood Pressure and Plan All Cause Readmissions will remain on display and likely return to the active page with a 1x weight for their first respective years. The potential introduction of a COVID-19 measure did not receive positive feedback during the open comment period and only time will tell if it was related to the reluctancy of accepting COVID-19 isn’t really going away anytime soon or the proposed collection and impact another vaccine measure may have on Stars.
  • HEDIS and Telehealth is here to stay and work together. According to the American Journal of Managed Care, telehealth claim lines increased 3.060 percent nationally from October 2019 to October 2020. As members seek care outside of the traditional office setting, providers and payers still have a need and obligation to capture the full burden of illness and these updates include additional code sets to be allowed for measure inclusion or exclusion when captured via telehealth visits alone. This is just another example of how members, plans, and providers are embracing digital technologies.
  • Part D measures, above all other measures for 2021 Star Ratings, got harder. Sure, some may think this could be attributed to CMS not having any CAHPS or HEDIS measures to use in their methodology calculations, but the increase in cut points should be attributed to an increase in performance across all of the eligible plans. Barriers to proper medication use and adherence are much greater than cost and access, especially as plans increased mail order access during the height of COVID-19. We often see poorer adherence and participation from members with the lowest cost share which tells us that what they really need is increased education and engagement. Simple one-way refill reminders for your adherence measures or offers to complete a Comprehensive Medication Review (CMR) for your Medication Therapy Management (MTM) program are no longer enough to compete with those top performing plans who are driving those cut-points higher every year. Learn more about our Medication Adherence Solution.

As shots go into arms and some semblance of normalcy begins to return, it’s still too soon to know the full impact the pandemic will have on members, plans, providers, technologies and so much more. CMS has equipped plans with a sneak peek of what’s to come and extra time to prepare for it in an effort to take better care of its members. It’s never too late to develop or enhance your member engagement strategy. How will you continue to wrap your arms around your members throughout the year and beyond COVID-19?