Terry Gerton States are facing some new requirements in determining Medicaid eligibility that go into effect at the end of December. Specifically, they have to verify recipient community engagement. Can you talk us through this change in new requirements? Where does it come from? What’s its purpose?

Rob Miller Yeah, as a result of the One Big, Beautiful Bill Act, we’re looking at implementing what we like to call community engagement for the Medicaid expansion population. So sometimes it’s commonly referred to as work requirements, but it’s really a little bit more comprehensive than that. So we’re looking at the Medicaid expansion population and essentially running them through what we like to call our five-tier verification structure at Citizen. As part of that, we are looking to essentially identify the folks that we actually need to reach out to. So you may look at different types of data sources — if we have existing records of people already working, if we have existing record of people hitting exemptions, whether that be pregnancy, a Native American, medically frail, whatever that might be — and essentially filtering down as far as we can through an automated fashion to identify the population that we actually need to reach out to that need to come back and either prove that they’re working 80 hours a month or find a job or help them do volunteer work and things like that. So this is really about trying to put some, I guess you can call it accountability on this particular population as a result of the legislation.

Terry Gerton That new requirement can be pretty challenging to validate. I mean, this is a very dispersed population. They may or may not have access to technology. They may or may not have the proof of verification. How do states respond to this kind of new federal mandate?

Rob Miller Yes, I mean, I think one of our biggest concerns and I think some of the states as well is this sort of member abrasion. And we’ve seen this in a couple of other implementations over the past let’s say 10 years or so where where these types of programs have resulted in members falling off the rosters that really shouldn’t have. So our approach is to ensure that sort of reducing member abrasions almost hopefully as much as to zero percent, if you will, is one of our core themes. So we, again, start with what can we do to automatically confirm these folks are good to stay in the program? And that is, when we’ve talked to [the Centers for Medicare and Medicaid Services (CMS)], their number one goal. So the last thing that we want to do is have to reach out to a member to actually perform this extra check,because like you said, it may be hard to get in touch with them. There may be technical concerns. There maybe a various number of reasons, and we need to make this as easy as possible. So another way to handle that, of course, is to reach to these consumers with that in mind. So there may be folks that have only cell phones. There may be folks going to the library to get to their computers. There may folks that are expecting to be able to do this over the phone, through paper as well. And so by having all of those sort of different channels available for some of them, maybe 20 years old versus some one that’s in their 60s, right? And having those different paths will hopefully make it so that we can reach those members in a clean way and ensure that the right people are staying covered at the right time.

Terry Gerton Many of these folks that are covered by Medicaid may also be receiving benefits through other programs. We’ve seen new work requirements go into place with the [Supplementary Nutrition Assistance Program (SNAP)], for example. So when we think about validating individual eligibility, are we looking across all of these different benefit programs to try to only have to validate them once, or do they have to validate themselves in every single eligibility program?

Rob Miller Yeah, I think, unfortunately, it’s going to be a state-by-state approach. I think we do see a lot of siloed states where some of their systems are in different places, which does require members, unfortunately, to have to do those different types of checks. We were just at a conference the other week and heard about a state talking about 80 different portals with 80 different logins for members, which is not a great user experience, let’s put it that way. I think one of the things that we can do from a technology perspective is help those different silos. And we did that in Mississippi, actually, where we took about 15 different state and federal data sources across different agencies and connected the Human Services [Department] and the Department of Medicaid together so that once somebody makes a request to apply for SNAP, and then maybe they also then apply for Medicaid at the same time, which happens often. Those transactions continue to funnel through us. And we’ll identify that so that one, they’re not getting double charged for those checks to the different credit bureaus and what have you for property and things like that. But more importantly, that data can come back to the state immediately as well if it’s available. So there’s technology solutions, if you will, to help bridge that gap. But that is certainly gonna be something that we might expect. Now, one other thing I think is important on your question specifically around SNAP is that we’ve already received, as part of that sort of five tier filter, if you will, that we’re going to try to go through when we get the Medicaid expansion population is if you’re on SNAP or [Temporary Assistance for Needy Families (TANF)], there’s already additional checks being done on those other programs that will already put you basically into good compliance for this program. So that is actually one of the automated checks we’re going to have. If somebody’s already on one of those other programs, but particularly SNAP and TANF, that’s an all-ready elimination for you for us to have to reach out. We’re already going to basically check off to say that you’re good to stay on the program without us doing any additional verifications.

Terry Gerton I’m speaking with Rob Miller. He’s general manager and senior vice president at CITIZ3N. We mentioned the Medicaid requirements up front. Really states are only getting months to not only receive these new mandates, but have them implemented, which is like lightning speed in terms of tech innovation, and every single state has to do it themselves. What are you seeing in terms of state compliance: Are they ready? Are they not? Are some states ahead of this game?

Rob Miller That’s a great question. I think everybody’s still waiting, to be honest with you, with the formal guidance from CMS. And there’s been some things that have come out already as well. I think one of the things that we talk about is not starting from home base, if you will. We’re starting from third base. And then at Softheon, we had done a lot of this work in Kentucky back in 2018 when they were looking to implement work requirements. So we had a pretty decent idea of what we might expect to see from a state, as well as the potential flexibility that we might see different states try to implement as well. And so I think a couple things we’re going to see. One, we’re not going to see likely a lot of RFPs coming out, requests for proposal, because of the timeline. It may take three or four months just to get all the approvals in place just to publish something, a couple months before you get responses, a couple of months after that before you’re able to evaluate that. And right then we’re already looking at we’re like in September of next year, and that’s going to be too late. We’re looking at probably having to have systems in place by June, certainly notifications and communications going out to members definitely by September, if not sooner than that as well. Because if we’re looking for members to comply with this in January 2027, they need to be notified, again, back to our chat a little bit earlier about this, they need to notified much sooner. So we do think states are probably a little bit behind just because of the timing and the lack of maybe full clarity on what’s expected from a detailed policy perspective. So what we’re seeing is we’re seeing a lot of states look towards their existing vendors. And so our strategy on the citizen side, we have a bunch of existing customers, but we’re also talking to the bigger system integrators as well to help them because they also tend to be slower to respond as well, as a bigger organization. I think the one biggest concern I think we have in general with that is that we don’t want them to use that as an opportunity to make another buck. And one of our biggest missions at CITIZ3N and Softheon is to make health care affordable, accessible and plentiful, and we really do believe that. In fact, we spoke about one of the previous conferences, about being able to split the cost of the implementation. That’s not something I think some of the bigger guys would talk about doing. They’ll use an opportunity to charge the same amount in each different state as they see it, customize it to crazy when maybe CMS comes out and makes a policy change, that’ll be a change order. That’s just not exactly how we operate. And so we want to make it easy and something where they can define their budget ahead of time and not worry about having all these extra costs as we work towards the implementation date.

Terry Gerton You mentioned that you and CITIZ3N have worked through these kinds of programmatic changes in the past. What have you found with the beneficiary population? Do they understand the new requirements? Are they going to be prepared to meet them? And what happens to their coverage if they’re not?

Rob Miller Yeah, I mean, unfortunately, if they don’t hit it, they’re going to lose coverage. And that’s certainly the last thing, back to our mission, the last thing that we want. And so we want to make sure that the communications are clear, they’re easy to receive. But we can go through any channel, whether it be a text message, a letter in the mail, an email, a push from a mobile app or whatever it might be. All of those different potential channels to get to those members. I think there’s going to be a lot of educating that’s going to need to happen as part of this because it’s going to be new for some folks, and I can’t imagine everybody sitting there watching and reading through the One Big Beautiful Bill Act. So we’re going to need make sure that folks are communicated to properly, which is why that timeline is even more crunched, as we talked about, than it is because we don’t want to send that letter to them in December, expecting them the month after to just be ready for it. So that communication is going to really be key.

Terry Gerton And are states adequately funded to do both the modernization and the outreach that’s going to be required to bring folks across the spectrum into compliance with these new requirements?

Rob Miller Well, I think there’s definitely going to be some federal funding available to them in the typical 90-10 rules, but it is going to be a challenge. And I think we’ve already talked to a few states on the CITIZ3N side where they’ve reached out to their existing vendors and again they’re seeing major dollar signs just to analyze the requirements and so that’s something where we come in hopefully and could be a little bit more nimble and agile than than they can and and help these states out because again our mission here is to is to help sustain the program and ensure nobody gets dropped off the rails, not to make a quick buck off of some impending legislation, if you will.

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