Taking on Medicaid Community Engagement with Conflict-Free Contractors
With the passage of the One Big Beautiful Bill, states now face the complex task of modernizing and transforming their Medicaid programs in as little as 18 months:
Screen beneficiaries for community engagement eligibility — principally assessing whether they are "medically frail” or are otherwise at risk due to social determinants of health;
Enroll beneficiaries in education, employment, or volunteer opportunities; and
Verify that beneficiaries are meeting the new requirements as a condition of eligibility.
These added layers of compliance present State legislators and agency officials with significant new challenges, especially given the poor performance of previous community engagement programs executed under broad 1115 demonstration waivers in Arkansas and Georgia.
In those cases:
Tens of millions of dollars in administrative costs were spent with little or no resulting community engagement;
There was a broad failure to enroll eligible individuals; and
Many qualified beneficiaries were removed from the program solely because they failed to confirm their community engagement activities.
States now need an enhanced compliance framework that includes real-time data tracking and monitoring systems, allowing for immediate feedback on beneficiary engagement activities and work requirement compliance. This will help identify and resolve issues before they lead to incorrect disenrollment.
The significance of this kind of program overhaul may well require the hiring of independent, conflict-free private partners who both understand the complexity of the requirements of the legislation and have the technological and business process expertise to implement the necessary changes, including:
Accurate front-end independent assessment of beneficiaries
Integration of new and existing workforce systems
Identification of adequate social supports, such as transportation and internet access
New information systems to track and report on compliance with the new requirements
Importantly, these contractors should have no financial interest in the outcome. Conflict-free, independent contractors help states do more for less, achieve greater beneficiary community engagement, reduce administrative burdens, and ensure that qualified beneficiaries receive the support to which they are entitled. Conversely, ten years of HHS Inspector General reports have demonstrated the dangers associated with allowing conflicted parties (i.e., Managed Care Organizations, which have a vested interest in enrollment decisions) to perform this work.
Note: Enhanced federal match of 90/75 percent is available for enrollment system and program integrity modernization, which will help states pay for new investments in technology and business processes to implement the community engagement requirements. Ordinary federal Medicaid matching funds for administration are 50%; the enhanced match is 90% for initial investment and 75% for operating costs. States will need to collaborate through data-sharing agreements to reduce redundancy while enhancing overall program effectiveness.