2.8M Americans potentially enrolled in more than one Medicaid/ACA plan, CMS says

A recent analysis of 2024 enrollment data identified 2.8 million Americans either enrolled in Medicaid or the Children’s Health Insurance Program in multiple states or simultaneously enrolled in both Medicaid/CHIP and a subsidized Affordable Care Act Exchange plan, according to the Centers for Medicare and Medicaid Services.

CMS is taking action to ensure individuals are only enrolled in one program and to stop the federal government from paying multiple times for these individuals to receive health coverage. In addition, as a result of the One Big Beautiful Bill Act, CMS now has new tools to prevent the federal government from paying twice for the same person’s care.

Over the past several months, software engineers collaborated with CMS to examine historical program enrollment data and found that in 2024 an average of 1.2 million Americans each month were enrolled in Medicaid/CHIP in two or more states and an average of 1.6 million Americans each month were enrolled in both Medicaid/CHIP and a subsidized Exchange plan.

Federal regulations require Exchanges to periodically examine data for dual enrollments in Medicaid to guard against improper enrollments in subsidized Exchange plans through a process called Medicaid Periodic Data Matching (PDM). These essential examinations were strengthened under the first Trump Administration and increased to at least twice a year. These examinations were paused under the Biden Administration to ensure that continuous coverage was maintained during the PHE, in alignment with the statutory requirement on states to maintain continuous enrollment in Medicaid or CHIP throughout the COVID public health emergency.

CMS will partner with states to reduce duplicate enrollment through three initiatives:

• Individuals Enrolled in Two or More Medicaid Programs: CMS will provide states with a list of individuals who are enrolled in Medicaid or CHIP in two or more states and ask states to recheck Medicaid or CHIP eligibility for these individuals. CMS will work with states to prevent individuals from losing coverage inappropriately.
• Individuals Enrolled in Medicaid or CHIP + a Subsidized Federally-facilitated Exchange (FFE) Plan: CMS notified individuals enrolled in both Medicaid or CHIP and an FFE plan with a subsidy. These individuals are asked to take one of the following actions:

1) Disenroll from Medicaid or CHIP, if no longer eligible;

2) End their subsidy (with the option to end their coverage); or

3) Notify the Exchange that the data match is incorrect and submit supporting documentation to show they are not enrolled in both Medicaid/CHIP and subsidized Exchange coverage.

After 30 days, the FFE will end the subsidy for individuals who still appear to be enrolled in both Medicaid or CHIP and an Exchange plan with a subsidy.

• Individuals Enrolled in Medicaid or CHIP + a Subsidized State-based Exchange (SBE) Plan: CMS will provide SBEs with a list of individuals who are potentially enrolled in the state’s Medicaid or CHIP and a subsidized Exchange plan and ask SBEs to determine whether these individuals are dually enrolled, and if so, to implement a process, similar to the federal Exchange, to recheck eligibility. CMS will work with states to prevent individuals from losing coverage inappropriately.

CMS will provide additional guidance to state Medicaid and CHIP agencies in early August with expectations for tackling concurrent enrollment. The agency will follow up with lists to each state of individuals concurrently enrolled in Medicaid or CHIP and ask states to make their best efforts to recheck eligibility by late fall. Going forward, CMS will continue to work with states to provide support for their existing Medicaid/CHIP and Exchange data matching processes and work to implement new requirements in the One Big Beautiful Bill Act designed to eliminate and prevent duplicate enrollment in Medicaid programs.