Penrod Blog

The Medicaid Continuous Enrollment Provision Dilemma

Impacts, Contributing Forces, and Possible Solutions

Now that the Medicaid Continuous Enrollment Provision rollback is in full swing, we’re only beginning to witness the impacts it has on enrollment numbers, member satisfaction, and payer revenue.

At its core, the problem started and ended with COVID. With the end of the federal Public Health Emergency (PHE), Medicaid members need to undergo redetermination to prove eligibility for the first time in 3 years. This follows a sharp increase in Medicaid enrollments, which skyrocketed by 21.2 million members since the beginning of the COVID pandemic in the United States around February of 2020.

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The consequences of redetermination land directly in the laps of states and payers, not to mention the significant impact on members. Without a coordinated effort to engage, inform, and educate members, significant member attrition and the associated revenue loss is at stake. According to the Kaiser Family Foundation, between 8 and 24 million people could lose Medicaid as the provision unwinds, either due to means-based determinations, inaction, or procedural challenges such as incorrect member contact information.

In this blog post, we’ll discuss the potential impact of this decision, the factors contributing to the problem, and possible solutions.


Expiring Coverage

The Medicaid continuous enrollment provision rollback is likely to impact the Medicaid-enrollee population size for a variety of reasons.

First, some members may no longer be eligible for coverage due to means-based testing. While eligibility rules differ by state, even a wage increase of $0.25 cents per hour since original enrollment can impact a person’s eligibility for Medicaid coverage if their income is now over the set limit.

Second, many members will have their coverage terminated if they fail to undergo redetermination – and it’s not necessarily because they refuse to participate or don’t qualify. In the first month of the redetermination process in Florida, 82% of all unenrolled recipients lost coverage due to procedural reasons – such as members not completing the required forms to continue on Medicaid or not having the correct contact information for the person.

According to a study published by the Robert Wood Johnson Foundation, the majority of Medicaid members are unaware they could lose coverage. In this case, they may not learn that their coverage lapsed until the point at which they need healthcare.


There are two primary factors contributing to this problem that payers must address. The first is data inaccuracy, primarily due to outdated member data emanating from the states, much of which has not been updated in 3 years. The second is purely an engagement challenge.

Inaccurate Data

Even if an insurance company has solid outreach strategies, data accuracy issues may prevent engagement from ever happening. Because members haven’t been redetermined in three years, things like addresses, contact details, and more are probably out of date. In fact, research indicates that 60-80% of member data elements can be inaccurate. This only adds to the engagement challenge, and makes it virtually impossible for payers to contact members to inform them of the need to redetermine.

Payers need to find accurate contact information to address this issue effectively. More on that later.

Engagement Challenges

The second factor that payers must address is a lack of engagement between members and their insurance providers. Effective communication is essential but challenging given the diverse ways members like to be contacted.

For instance, some payer feedback has indicated that only 6% of Medicaid recipients responded to email.

Some may prefer texting, calls, letters, or combination of all three; understanding how to reach each individual is critical. A tailored approach can help engage members more effectively and improve outcomes.

Additionally, payers must find ways to reach members who have become disengaged with the process. This could be through targeted marketing campaigns, incentives, or outreach by community organizations. Reaching out to these members may be more difficult, but preventing eligible members from losing coverage will be essential.

Tips and Tricks

Health insurance companies can mitigate risks with a variety of engagement and data strategies.

Tips for Engagement

  • Obtain updated member demographic information
    You can’t engage with people you can’t reach. It is imperative to have complete demographic information, and find and fix any errors as early as possible.
  • Choose the right engagement platform
    Insurance companies must have a marketing automation platform capable of omni-channel communications, like email, snail mail, SMS texting, and phone in order to deliver experiences that meet an individual member’s communication preferences. Additionally, keep in mind that this platform must be HIPAA compliant, as it will likely be storing some form of PHI.
  • Provide clear and concise communication
    Many Medicaid enrollees may not have a strong understanding of health insurance terminology or how to navigate the healthcare system. It’s important for health insurance companies to communicate in plain language and provide easy-to-understand resources that explain benefits, coverage, and how to access care.
  • Offer personalized support
    Medicaid enrollees often have complex medical needs and may require additional support to manage their health. Health insurance companies should offer personalized support services, such as care coordination, health coaching, and disease management programs.
  • Use multiple communication channels
    Not all Medicaid enrollees have access to the internet or email, so it’s important to use multiple communication channels to reach them. This may include mail, phone calls, text messages, and in-person outreach.
  • Address social determinants of health
    Many Medicaid enrollees face barriers to accessing care, including lack of transportation, inadequate housing, and food insecurity. Health insurance companies should work to address these social determinants of health by connecting enrollees with community resources and providing support services.
  • Continuously evaluate and improve engagement efforts
    Health insurance companies should regularly evaluate their engagement efforts to ensure they are effective and meeting the needs of Medicaid enrollees. This includes collecting feedback from enrollees and making changes to improve communication and support services as needed.

Tips for Data Accuracy

To keep Medicaid data accurate, an insurance company can take the following steps:

  • Use electronic verification tools
    Electronic verification tools can help insurance companies verify Medicaid eligibility in a snap. Platforms offered from companies like our partner FrontRunner HC can find and update member demographic information automatically. Plus, their data automation software can verify insurance information or discover changes in the information. They can also provide insights into patients’ financial situations, allowing payers to risk stratify and target members for Medicaid or ACA plans. With an intimate understanding of the Medicaid Redetermination issue and using these robust tools, FrontRunnerHC is helping payers solve data challenges and engage more members with the vital information needed.
  • Train staff on Medicaid eligibility criteria
    Insurance company staff should be trained on Medicaid eligibility requirements and how to accurately verify that an individual is eligible for coverage.
  • Regularly review and update data
    Insurance companies should regularly review and update their member data to ensure it is accurate and up to date. This includes verifying enrollment information and making sure that all data is complete and error-free.
  • Monitor changes in Medicaid policy
    Medicaid policies and eligibility requirements can change frequently, so it’s important for insurance companies to stay up to date on any changes and adjust their data accordingly.
  • Develop quality assurance processes
    Insurance companies should have quality assurance processes in place to ensure that their data is reliable and accurate. This can include regular audits, data checks, and error correction.
  • Communicate with Medicaid agencies
    Insurance companies should communicate regularly with Medicaid agencies to ensure that their data matches the agency’s records and to address any discrepancies or errors that may arise.

By taking these steps, insurance companies can help ensure that their Medicaid data is accurate and up to date, which is essential for engaging members during the Medicaid Continuous Enrollment Provision rollback.


The Medicaid Continuous Enrollment Provision rollback has created a substantial challenge for payers nationwide. With between 8 and 24 million people at risk of losing their coverage, it’s essential to leverage solutions that can help combat this problem.

Accurate data and effective engagement strategies are critical to addressing these issues effectively, particularly for members who may have become disengaged from the provider.

While these challenges may appear daunting, we must continue to work towards protecting the health coverage of the millions of Americans who rely on Medicaid. By working together and taking a targeted approach, payers can rise to the challenge and overcome these obstacles.

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