CMS has provided flexibility for states to perform ex parte renewals through the 1902(e)(14)(a) process. However, many states may have struggled with the implementation of these waivers, or may not have the most efficient implementation possible.
Waivers that states may be struggling with:
In some states, the implementation of these waivers may be manual (meaning that eligibility workers are determining who falls under these rules). This process is often inefficient and can lead to a backlog of individuals to be verified.
When the implementation is automatic, the new logic may be at the end of the renewal, meaning that there are logic and checks being run prior to the waiver logic being run. This may result in a person being excluded before they get the chance to be considered for the waiver logic.
A key sign that the implementation may be inefficient is a mismatch between estimates and measurements. Ask the state: how many people did we estimate to be caught by this logic? Ask the vendor: how many actually were? Are the numbers close?
In states where waivers are implemented manually, explore the opportunity to automate.
In states where waivers may be implemented inefficiently, recommend they be optimized by moving them up in the renewal process or expanding them to the largest group possible.