Many individuals and families experience numerous changes in health insurance program eligibility over the course of their lives, qualifying for Medicaid or the Children’s Health Insurance Program (CHIP) during some periods and qualified health plans (QHPs) with advanced premium tax credits (APTCs) or cost-saving reductions (CSRs) during others. In addition to changes in individual circumstances, public health events like the COVID-19 pandemic and updates to federal and state policy can lead to millions of people experiencing eligibility changes all at once.  

Providing an easy path between Medicaid/CHIP and QHP enrollments is one of the keys to keeping these individuals and families covered, and account transfers are at the heart of that process. Account transfers (ATs) securely share beneficiary information between Medicaid and marketplace platforms, creating an easier coverage transition process with fewer steps and less chance for error. As health care systems continue to change and evolve, further integrating Medicaid and marketplace data through account transfers becomes more critical than ever. 

Why Integration Between Medicaid and Marketplace Matters 

The size of the U.S. population moving between Medicaid/CHIP and QHP eligibility is considerable and has been especially large over the last five years. With the Continuous Enrollment Provision enacted near the beginning of the COVID-19 pandemic in 2020, Medicaid/CHIP enrollments grew by over 20 million people (reaching a record high of 94 million people by April 2023). Since Medicaid unwinding ended this provision in 2023, more than 25 million people have been disenrolled in Medicaid and CHIP (and over 56 million people had their coverage renewed).  

For these millions of individuals, integration between Medicaid/CHIP and marketplace programs is crucial and allows eligibility to be determined through a single application rather than requiring individuals to fill out multiple forms. This reduces the amount of work required of the applicant, the time it takes to collect data and determine eligibility, and the risk of user-input errors and, in turn, reduces the risk of delays or lapses in coverage.  

Challenges of Traditional Account Transfers 

While the traditional Medicaid/CHIP-marketplace account transfer system used by CMS and the FFM has been an important development, it also presents several well-known challenges and shortcomings, primarily related to the reliability and accuracy of data. One of the main weaknesses of the traditional AT system is its use of an inflexible data model with limited measures to control data quality (known as Extensible Markup Language or XML) – which introduces the risk of incomplete and incorrect data sharing – as opposed to more flexible and reliable models, such as the JavaScript Object Notation (JSON)-based data model GetInsured currently offers. Faulty data sharing can lead to errors in application processing, and resolving these errors often requires beneficiaries to fill out entirely new applications. The legacy AT system also features inconsistencies from state to state in how and when ATs are sent and how verification information is processed, which can lead to unnecessary reverifications and makes comparing outcomes across state systems difficult.  

The inaccuracies and inconsistencies of the legacy AT system have placed additional demands on beneficiaries as well as state and county agencies and workers, causing unnecessary rework, questions and confusion, and delays or lapses in coverage. It is for all these reasons that, in October 2024, CMS announced the development a new AT system: Account Transfer 2.0. 

Introducing Account Transfer 2.0 

Account Transfer 2.0 is a modernized AT system being developed by the Centers for Medicare & Medicaid Services (CMS) with input from a handful of volunteer states, intended to facilitate a more streamlined and automated transition between Medicaid and marketplace plans. AT 2.0 features planned improvements in terms of the following: 

  • Data Format and Transfer: AT 2.0 employs a JavaScript Object Notation (JSON)-based data model, which is more flexible and adaptable than the previous XLM-based model and aligns with the data format commonly used by marketplace eligibility systems. More consistent data elements and comprehensive quality controls are also incorporated, and automation makes real-time or near real-time data sharing possible, thereby improving the accuracy and re-usability of data and reducing the occurrence of unnecessary reverifications. 
  • Eligibility Process Automation: With more accurate and reliable data readily available, AT 2.0 yields a more automated and streamlined eligibility process than the legacy system, reducing the amount of information consumers need to fill out while simplifying and speeding up the coverage transition process and providing more holistic eligibility results. 

A full draft of the new system isn’t planned for release for state review until 2025, with early adoption for states operating on the FFM planned to begin in 2027. However, many of the above features have already been implemented in state-based marketplaces (SBMs) on the GetInsured platform with great success for some time now, such as the JSON data model and enhanced AT tracking and reporting capabilities. Platforms like ours provide an excellent source of insight and inspiration through the development and implementation of AT 2.0 as well as a springboard for future AT developments, as GetInsured continues to lead the market in SBM technology and innovation. 

Benefits of Account Transfer 2.0 

Based on the successes we’ve seen, the advantages of AT 2.0’s improved data transfer, eligibility process, and tracking features are likely to be significant for consumers, state agencies, and administrators alike. Anticipated outcomes include the following: 

  • Improved Eligibility Accuracy: The real-time data sharing and more stringent data controls of AT 2.0 help to minimize data errors and improve overall program accuracy, ensuring consumers are provided with eligibility results and program options they can trust. Automation further enhances accuracy by reducing the risk of user errors and the need for reverifications. 
  • Easier Coverage Transitions with Fewer Gaps: With AT 2.0, consumers are able to see a more holistic view of their eligibility options with only one application, reducing the risk of individuals and families going without coverage due to a lack of information. Automation further simplifies the transition between Medicaid and marketplace programs – for the most part, consumers are able to easily verify their transferred application and eligibility information before proceeding to plan shopping.  
  • Reduced Inquiries and Administrative Demand: The enhancements of AT 2.0 are likely to not only improve the experience of the consumer and reduce consumer inquiries, but also improve the experience of agency staff, as increased accuracy, automated eligibility processes, and comprehensive eligibility information all reduce the need for manual interventions.  

The Role of SBMs in Medicaid and Marketplace Integration 

In terms of Medicaid-marketplace integration, GetInsured has also been leading the charge. To support the end of the Public Health Emergency (PHE), GetInsured introduced significant innovations to enhance integration across the two systems, including improvements in sharing verification data and additional data, such as Medicaid termination dates, reasons, and codes, and began offering automated eligibility determinations to streamline processes. These innovations demonstrate the potential of the advanced AT features and options already offered by GetInsured.  

The ongoing AT advancements enacted by SBMs combined with the rollout of AT 2.0 have the potential to facilitate widespread improvements to Medicaid/CHIP-marketplace integration, making changes to eligibility easier on consumers and agency staff, reducing unnecessary disenrollments and gaps in coverage, and ultimately lowering the average uninsured rates for individuals and families across the nation. 

While AT 2.0 will provide much-needed updates to the account transfer system used by CMS and the FFM, GetInsured has stayed ahead of the curve, offering SBMs continually more advanced and reliable options. For states already operating with advanced SBM AT features, AT 2.0 introduces a new base level from which to innovate and improve, but also a new base level from which to integrate with other agency systems.   

It is for these reasons that AT advancements are also a considerable step forward in realizing a No Wrong Door approach in health and human services. The improvements achieved by AT 2.0 – and the way they will act as a springboard for SBM account transfer innovation and improvement – will help chart a path for integration within and across other health and human services programs, such as Medicare, child care programs, and benefits programs including SNAP and TANF. Carefully measuring the lessons and outcomes of SBM AT advancements as well as the AT 2.0 implementation across SBM and FFM states will therefore play an important role in the future development of No Wrong Door functionality. 

The persistent innovation driven by competition across SBM vendors is one of the reasons SBMs are currently able to implement more advanced AT features and achieve more successful Medicaid integration than states operating on the FFM. As we look to the future of account transfers and program integration, it is important that we keep this lesson in mind and continue asking how we can improve our systems not only before, but also during and after the implementation of AT 2.0. With our flexibility, adaptability, and emphasis on continual innovations such as AI-driven automation and predictive analytics, GetInsured is well-positioned to be at the forefront of this advancement. 

Read more about how GetInsured infuses accountability in all our marketplace and Medicaid eligibility processes here, or request whitepapers with additional information on how the GetInsured solution supports a No Wrong Door Approach here.