CMS claims 2.8 million Americans enrolled in duplicate plans

The Centers for Medicare and Medicaid Services conducted a recent analysis of 2024 enrollment data and claims to have identified about 2.8 million Americans either enrolled in Medicaid or the Children’s Health Insurance Program (CHIP) in multiple states, or simultaneously enrolled in both Medicaid/CHIP and a subsidized Affordable Care Act Exchange plan. 

CMS said it’s taking action to end the duplicate enrollments, claiming these efforts could potentially save taxpayers about $14 billion annually.

"HHS staff uncovered millions of Americans who were illegally or improperly enrolled in Medicaid and ACA plans," said U.S. Health and Human Services Secretary Robert F. Kennedy, Jr. “With the passage of the One Big Beautiful Bill, we now have the tools to strengthen these vital programs for generations to come."

WHAT’S THE IMPACT

CMS said that over the past several months, software engineers collaborated with the agency to examine historical program enrollment data and found that in 2024, an average of 1.2 million Americans each month were enrolled in Medicaid/CHIP in two or more states and an average of 1.6 million Americans each month were enrolled in both Medicaid/CHIP and a subsidized Exchange plan. 

Federal regulations require Exchanges to periodically examine data for dual enrollments in Medicaid to guard against improper enrollments in subsidized Exchange plans through a process called Medicaid Periodic Data Matching (PDM). These examinations were increased to at least twice a year during President Donald Trump’s first term. 

They were then paused under the Biden administration to ensure that continuous coverage was maintained during the PHE, in alignment with the statutory requirement on states to maintain continuous enrollment in Medicaid or CHIP throughout the COVID-19 public health emergency, said CMS.

The agency said it will work with states to reduce duplicate enrollments through a number of initiatives. For starters, CMS will provide states with a list of people who are enrolled in Medicaid or CHIP in two or more states and ask states to recheck Medicaid or CHIP eligibility for these individuals. CMS said it will work with states to prevent individuals from losing coverage inappropriately. 

Also, CMS notified individuals enrolled in both Medicaid or CHIP and an FFE plan with a subsidy, asking them to either disenroll from Medicaid or CHIP if they're no longer eligible, end their subsidy, or notify the Exchange that the data match is incorrect. After 30 days, the FFE will end the subsidy for individuals who still appear to be enrolled in both Medicaid or CHIP and an Exchange plan with a subsidy.

THE LARGER TREND

CMS said it will provide additional guidance to state Medicaid and CHIP agencies in early August with expectations for tackling concurrent enrollment. The agency will follow up with lists to each state of individuals concurrently enrolled in Medicaid or CHIP, and ask states to make their best efforts to recheck eligibility by late fall. 

Going forward, CMS will continue to work with states to provide support for their existing Medicaid/CHIP and Exchange data matching processes, it said.