Medicaid Health Plans of America (MHPA) and the Association for Community Affiliated Plans (ACAP) have urged CMS Administrator Mehmet Oz to take several critical steps to ensure that states can successfully implement the community engagement requirements included in the OBBBA. In the November 3rd letter, MHPA and ACAP warn that without clearer federal guidance, modernized communication tools, and a stronger Medicaid data infrastructure, eligible Medicaid members could lose coverage for avoidable administrative reasons.
Clarifying the Role of Managed Care Plans
The letter underscores that although the OBBBA prevents managed care plans from serving as the official compliance entity for the new Medicaid work requirements. Plans remain the closest to members and play an essential role in Medicaid retention and member engagement. The letter asks the federal agency to confirm that plans may continue explaining the new rules, supporting individuals who qualify for exemptions, and connecting members to the resources they need to meet the requirements. This clarification is critical as millions of Medicaid enrollees depend on their plans for guidance during periods of Medicaid eligibility change, especially as states prepare for more frequent Medicaid redetermination cycles.
States and Counties Need More Support
The health plan associations note that frequent eligibility checks and continuous tracking of community engagement activities will put additional strain on state and county systems. The associations have asked the federal agency to offer technical assistance and clear direction on how states can use existing federal funds to strengthen staffing and upgrade technology. They raise concerns that increased churn among healthier adults in the expansion population could create financial challenges for managed care plans. The letter recommends that the federal agency direct states to review and adjust capitation rates more frequently and provide guidance on strategies to manage risk during this transition.
A Path to a Smoother Transition
Successful implementation of the OBBBA will depend on clear direction from the federal agency, modern communication, and data systems that support timely and accurate decisions. With that foundation in place, MCOs can do what they do best by guiding members through complex changes, reducing unnecessary churn, and helping members stay connected to the care they rely on.