States are racing to update their ‘ex parte’ Medicaid systems. Should new technologies play a role?

As states race to update their Medicaid eligibility systems to meet new federal requirements taking effect next year, some are focusing on scaling up their “ex parte” systems, automated processes that use state records, such as income databases or tax records, to renew enrollment without requiring any additional action or paperwork from recipients.

H.R. 1, last year’s budget reconciliation act, includes an upcoming mandate that most adults enrolled in Medicaid must have their eligibility redetermined every six months, instead of annually. With less than a year to prepare for the coming changes, a balance between compliance, automation and user experience may determine whether states’ Medicaid systems can handle the added pressure, while keeping eligible residents covered.

Danny Mintz, director of safety net policy at the civic tech nonprofit Code for America, said the shift is forcing states to rethink how their eligibility systems operate at a technical level, as agencies brace for an increase in renewal volume and administrative complexity.

While ex parte renewals have been required under the Affordable Care Act for more than a decade, states’ success at completing those renewals has varied widely across states — from less than 25% to more than 75%. Mintz said that variability often comes down to how well states have integrated data and designed their eligibility workflows.

In 2023, Code for America analyzed the benefits systems of five states as part of its Safety Net Innovation Lab, an initiative to improve access to services in states where large numbers of residents are eligible for government assistance programs but have not claimed them. In recent years, particularly during the unwinding of pandemic-era continuous coverage, Mintz said, states have worked to improve those systems by analyzing where automated renewals break down.

‘Working through the data’

In Minnesota, for instance, Code For America estimated that caseworkers were spending an average of 70 minutes on each Medicaid renewal case. But through the use of semi-automated case selection and automated renewal notices, as well as other changes, the time was cut to 11 minutes.

“We looked really in detail at the nuts and bolts of their ex parte processes … to see what was causing a case to fail out,” Mintz said, referencing “failure codes” that push cases into manual review. “A lot of those factors have to do with how is the data integrated into their system [and] what are the specific worker processes for working through the data that’s available.”

As H.R. 1 introduces more frequent eligibility checks and new requirements, including work reporting rules for able-bodied adults without dependents, the changes are expected to increase workloads while introducing new data sources, such as employment records and health indicators like medical frailty, that must be integrated into state systems. That work often requires coordination across agencies and roles, from IT personnel to policy experts to frontline caseworkers.

Minnesota’s human services department is working with other state departments — Children, Youth and Families, and Employment and Economic Development — to finalize data-sharing agreements so it can receive the necessary information for ex parte determinations, said Jen Amundson, a department spokesperson.

Amundson said the state is also planning to implement additional rules for processing Medicaid applications, such as setting new limits to retroactive coverage and increasing funding to the Human Services Response Contingency Account, a special revenue fund that addresses the department’s urgent funding needs. In an email, she said the agency will also conduct a statewide outreach campaign to identifying enrollees most at risk of losing coverage ahead of the 2027 renewal cycle: “This outreach effort will help us maintain our ex parte rates as the new eligibility information will be available for the system.”

Arizona, which reported an 82% ex parte renewal rate in 2024, among the highest in the nation, is taking a similar approach. The state’s Health Care Cost Containment System, responsible for Medicaid renewals, is working with the state’s Department of Economic Security on screening tools and how it can better use its existing data for the Supplemental Nutrition Assistance Program and Temporary Assistance for Needy Families, benefits programs that have significant recipient overlap, to obtain ex parte renewal data.

“We are also exploring consent-based income verifications, Federal and State data sources, and an enhanced member centric that supports automation of community engagement activities and reporting,” an agency spokesperson wrote in an email.

‘Liabilities’

The Center for Health Care Strategies, a nonprofit that works to improve outcomes for people enrolled in Medicaid, projects that millions of people could lose coverage by 2028, due to strict work requirements, increased eligibility checks and reduced federal funding for the benefits program.

Though states are working hard to meet the aggressive timelines laid out in the federal law, Mintz said, he warned that quickly adopting new IT tools like artificial intelligence, with the aim of increasing efficiency, could create longer-term issues: “What’s conceptually easiest is just build something new and layer it on top, but it comes with a lot of liabilities from a worker and system perspective.”

Mintz said that states should instead improve their systems by reviewing how work gets done, ensuring data matches and mapping how information moves between agencies and people to cut down on duplicative work.

Other policy experts have argued that emerging technologies, like artificial intelligence tools, could help states more expediently make changes to benefits systems. In a recent editorial for this publication, Jennifer Pahlka and Cassandra Madison, the heads of two civic tech nonprofits, argued that AI can “put state governments in the driver’s seat, making them better informed buyers, more capable builders and better stewards of outcomes.”

Amundson said Minnesota is not planning to use any new IT tools to support operations.

“We plan to leverage existing tools, many of which were developed during the recent efforts during the unwinding of the public health emergency,” Amundson said. “This includes the online Renewal Date Lookup Tool, informational notices, text messaging, dedicated websites and partner toolkits.”

Neither is Arizona.

“Rather than launching isolated pilots, [the Arizona Health Care Cost Containment System] is leveraging its broader Medicaid Enterprise System modernization to support eligibility and ex parte operations,” an agency spokesperson explained in an email. “We are also exploring consent-based income verifications, Federal and State data sources, and an enhanced member centric [system] that supports automation of community engagement activities and reporting. This includes the use of secure, cloud‑based platforms and enhanced system integrations.”

Code for America’s Mintz stressed the importance of reducing enrollee paperwork and streamlining communications to avoid overwhelming applicants with the new changes. If ex parte systems fail to scale effectively, he said, more enrollees could be pushed into manual renewal processes, increasing the risk of coverage loss due to paperwork barriers.

California’s implementation plan for Medicaid compliance under H.R.1, released in January, maximizes data-sharing to reduce paperwork and minimizes the need for county caseworker intervention. It also introduces new verification checks, like quarterly reviews of federal death records. These efforts are all designed to make ex parte renewals more accurate and reduce cases of eligible residents losing coverage because of missing paperwork.

“The thing that’s so great about an ex parte process,” Mintz said, “is that it takes a 50-page packet away from a person, and instead it replaces it with a letter saying: Good news. You don’t have to do any” paperwork.