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As the Trump administration prepares to roll out work requirements in Medicaid, two organizations representing Medicaid managed care plans are offering a number of suggestions, from enabling data sharing to modernizing communications.
In a Nov. 3 letter sent to the Centers for Medicare and Medicaid Services, Dr. Mehmet Oz, Medicaid Health Plans of America (MHPA) and the Association for Community-Affiliated Plans (ACAP) said insurers should be able to play a role in referring members to resources and information about the program.
While acknowledging that Medicaid managed care organizations (MCOs) are not able to officially serve a compliance function, they contended that they can serve as a resource, and that this ability should be clarified and communicated by CMS.
"Medicaid MCOs can serve as an important resource for enrollees to ensure that eligible individuals who are compliant with community engagement requirements continue receiving Medicaid benefits," the groups wrote.
WHAT'S THE IMPACT
The One Big Beautiful Bill Act, which passed in July, mandates work requirements or job training for eligible adults.
The Medicaid managed care plans said they want more clarity as it pertains to the One Big Beautiful Bill Act's exceptions for people who are medically frail or who otherwise have special needs.
To provide this clarity, the organizations suggest that CMS work closely with states and health plans to ensure "clear, standard and consistent" definitions, with consideration for existing state and federal definitions.
The groups are also seeking guidance from CMS on best practices for states, health plans and providers regarding the sharing of substance use disorder (SUD) patient data, while remaining compliant with patient privacy protections.
Lag time when sharing data between the Social Security Administration and states can be an issue, according to the letter, and MCOs have raised concerns about how the delays might negatively impact enrollment and pose barriers to securing exemptions from community engagement requirements.
The letter calls on CMS to work with the SSA to support timely data sharing with states.
Avoiding procedural disenrollments, the groups contend, will require detailed guidance on new data sharing best practices for states, MCOs and federal agencies. For example, some demographic information, such as whether an enrollee is a caretaker of someone younger than 14, is unavailable to plans but could be identified through data sources for other programs, such as the Special Supplemental Nutrition Program for Women, Infants and Children. And claims data could potentially be used to identify people that meet the definition of medically frail, "but the sharing of that information would benefit from additional technical support and guidance," the letter read.
"Supporting the successful exemption of eligible enrollees is crucial, given both statutory intent and the severe risks of coverage loss for these populations," the groups wrote.
THE LARGER TREND
The letter also expressed concern that there could be downstream impacts on managed care plans' Medicaid rates, which are already being pressured by tariffs, rising pharmaceutical costs and design changes to the Medicaid program.
Additionally, the groups want CMS to allow self-attestations to be a valid way for states to determine compliance with the requirements. This would not be prohibited under the One Big Beautiful Bill Act, they said.