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  • Writer's pictureSean Libby

Reimagining Dual Renewal Post-Continuous Coverage Requirement

Updated: Jan 31

On April 1st, the continuous coverage requirement associated with the COVID-19 pandemic finally ended. During the pandemic, Medicaid and CHIP enrollment grew by 20.2 million, representing a 28.5% increase from February 2020 to October 2022 (see Kaiser Family Foundation illustration below based on CMS published data). This growth was driven by an increase in the federal matching paid by CMS to state Medicaid agencies as a function of the joint state and federal funding of Medicaid. During the pandemic, CMS paid an increased amount but required that states not disenroll members, including members who no longer met the eligibility requirements with a few narrow exceptions.

Since the continuous coverage requirement ended earlier this month, now is a great time for DSNP, Medicare Advantage plans, and other service dual enrollees, to consider how renewal assistance can best be provided. There have been significant changes to Medicaid renewal processes that plans should incorporate into effective renewal assistance. I wanted to take this opportunity to share some of what BeneLynk has learned in providing renewal assistance to more than a million Medicaid members every year.

One of the biggest challenges is going to be the re-alignment of renewal dates at the state level. This is particularly challenging for dual members since communication about renewal changes has been communicated to managed Medicaid plans much more frequently than to managed Medicare plans. Historically, many managed Medicare plans have calculated a member’s renewal date by looking at the member’s start date on files such as the MCMD and assuming a renewal on the anniversary of the start. This methodology was always imprecise and is becoming significantly more so as we transition out of the continuous coverage requirement. To meet this challenge, plans need to adopt a multi-pronged solution.

  1. Solicit and input files from state agencies with updated information

  2. Use 834 files for any members who are also on an affiliated managed Medicaid plan

  3. Incorporate interview questions that ask about updated Medicaid renewal dates into existing member touchpoints most obviously in annual renewal calls

For all of this information, plans need a way to reason over possibly conflicting dates and determine which source should “win” in a given situation.

When offering renewal assistance, plans need to recognize the great work that Medicaid agencies have done in creating a wide range of renewal options. In most states, members have the option to renew by mail, by phone, in person, and through other innovative avenues. Education about Medicaid renewals needs to reflect all of these options. Also, plans have the opportunity to understand which avenue for renewal a member chooses and have that choice inform outreach in subsequent years.

Annual renewal assistance outreach is a great opportunity to tie into larger social care work. Dual-eligible members are significantly more likely to face SDoH barriers. A great way to start the conversation is to talk with the member about challenges that concern them and work together to build a plan to address those challenges (at BeneLynk we call this leading with help).

Finally, and most importantly, plans need to have a way to help members reapply for Medicaid benefits. Whether partial dual or full Medicaid, we know that as much as 9% of all Medicaid members are going to lose benefits due to failure to comply with administrative requirements. These members are going to lose needed benefits (most notably the state payment of the part B premium), and plans are going to lose the capitation associated with dual enrollment, as well as face the possibility of removing members from DSNP plans.

At BeneLynk we’re committed to helping our clients serve all members with an integrated and human, social care program. As the continuous coverage requirement comes to an end, we are working to engage all Medicaid recipients, both full and partial, and ensure that they keep the benefits they deserve. If you have questions, or if we might be of service, please reach out to us today at

About the Author

Sean Libby, BeneLynk’s President, has been an advocate for seniors, people with disabilities, veterans, and individuals with low income for over 20 years. At BeneLynk, we are committed to helping managed care plans deliver superior social care solutions to their members. We’re proud to develop and deliver our services in close partnership with our clients. Drop us a note at

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