Mobilizing Medicaid Managed Care Organizations to Support SNAP Enrollment: A Data Story Sharing

Feature Story

By Jamila McLean with support and guidance from Julian Xie

Published September 6 2024

Today, almost all states administer their Medicaid program through Managed Care Organizations (MCO), which are responsible for managing cost, utilization, and quality of healthcare access for Medicaid enrollees. Seventy-four percent of Medicaid enrollees are enrolled in MCOs. As awareness of social needs’ impact on health increases, so does the role of Medicaid MCOs in addressing those needs. Therefore, a central goal of MCO efforts should be to maximize enrollment in available state and federal benefits.

A core strategy to address food insecurity in Medicaid enrollees is maximizing enrollment in the Supplemental Nutrition Assistance Program (SNAP), the nation’s largest food program for low income families. SNAP not only has a demonstrated impact on reducing food insecurity but also improving health outcomes and reducing Medicaid spending. However, despite the potential benefits of SNAP, research by the U.S. Department of Health and Human Services (HHS) has found that only 40% of Medicaid beneficiaries also receive SNAP.

MCOs can be critical partners to increase enrollment in SNAP, if they have:

Adequate funding to account for outreach and enrollment activities
Accountability for addressing food insecurity or maximizing co-enrollment
Member-level data on SNAP enrollment to support outreach and quality improvement strategies

Leading states provide examples of how states could consider the role of MCOs in addressing SNAP. Three states—Texas, Rhode Island, and North Carolina—specifically mention facilitating enrollment in SNAP through referrals and/or direct application assistance in their managed care contracts. Pennsylvania shares SNAP data with MCOs to facilitate their ability to support SNAP enrollment, described in greater detail below.

SNAP Enrollment Background

Medicaid and SNAP have similar eligibility requirements, however, administrative barriers complicate the enrollment process making it difficult for eligible individuals to access the benefits for which they are eligible. For example, SNAP applicants are required to complete an interview, which can be done by phone or in-person as part of the application process. SNAP interviews have been shown to be a common reason many applications are denied. A 2019 review of SNAP denial data in LA County found that one-in-three applications were denied for a missed interview. Additionally, the study found that approximately 40% of students and working families, and 34% of applicants experiencing homelessness were denied because of a missed interview. There is much work to be done at the federal and state level to align eligibility criteria with Medicaid and streamline verification processes. At the same time, Medicaid MCOs can be instrumental in providing application and enrollment assistance with support from the state agencies administering Medicaid and SNAP.

How Pennsylvania is Leveraging Data Sharing and Medicaid MCOs to Close The Enrollment Gap

The Pennsylvania Department of Human Services (DHS) is the state agency responsible for administering both Pennsylvania’s SNAP and Medicaid (known as Medical Assistance (MA)) programs. Individuals can apply for Medicaid, SNAP, and additional benefits through a single application on the state’s online portal, COMPASS. Like most states, Pennsylvania delivers Medicaid through a managed care program called HealthChoices. The state operates three managed care programs:

Physical HealthChoices
Behavioral HealthChoices – Mental health and drug and alcohol services
Community HealthChoices (CHC) – Health care coverage for individuals dually enrolled in Medicaid and Medicare

In 2021, the Pennsylvania DHS began providing individual-level SNAP participation data to all MCOs in the state via an enhanced ASC X12 benefit enrollment and maintenance file. Also known as a “834 transaction,” this file is the standard process by which Medicaid agencies share daily enrollment data with their MCOs—data that can range from the enrollment of a new member to the termination of coverage to changes in a beneficiary’s name, address, or preferred language. In addition to the data specific to the beneficiary’s enrollment in Medicaid, the enhanced 834 file now includes four additional data points specific to the status of that individual’s enrollment in SNAP:

Start Date
End Date
Renewal Date
Semiannual Reporting (SAR) Date

This strategy offers Pennsylvania MCOs deeper insights into whether their members are utilizing this crucial public benefit, and potentially influencing how they incorporate benefit access support into their social drivers of health (SDOH) strategies. It also improves the ability for the Pennsylvania MCOs to collaborate with non-profits, allowing both the plans and their community partners to target outreach efforts towards individuals who may be eligible for SNAP but are not currently enrolled.

Sharing SNAP Data with Medicaid Managed Care Organizations

Sharing SNAP enrollment data for the purpose of increasing co-enrollment in Medicaid and SNAP remains a novel approach, but there are several factors that may complicate uptake among state agencies and MCOs. Concerns about consent and the legal rationale for data sharing, or a lack of integrated infrastructure can hinder a state’s ability to maximize the power of data sharing. Fortunately for Pennsylvania, Medicaid and SNAP are administered by the same agency, DHS, allowing for a more seamless approach to data sharing. States where both programs are administered by separate agencies may need to consider establishing new data-sharing agreements between Medicaid, the MCOs, and the SNAP agency.

Federal law permits Medicaid agencies to “use and disclose Medicaid applicant and participant data for purposes directly connected with the administration of the Medicaid plan” including with appropriate third parties. Medicaid MCOs are both HIPAA-covered entities and “business associates” directly involved in the administration of the Medicaid program. Additionally, it has been well established that appropriate nutrition through enrollment in programs like SNAP is connected to better outcomes. The undeniable link between nutrition and health provides a sound rationale for Medicaid agencies and MCOs to pursue data sharing agreements (DSAs) with the SNAP agency.

MCOs consistently express the need for improved data sharing between state agencies and MCOs specifically for the purpose of supporting Medicaid health plans’ SDOH Initiatives. The Annual Medicaid MCO survey by the Institute for Medicaid Innovation (IMI) found that Medicaid MCOs believed that state Medicaid agencies could further assist Medicaid health plans in addressing SDOH needs through:

Improved data sharing between government agencies (e.g., foster care system, criminal justice system) and MCOs (88%)
Improved data sharing between state and MCOs (79%)
Standardized 834 enrollment forms with social needs information (79%)

Despite the desire for additional data, few other states—like North Carolina and Michigan—have begun sharing SNAP enrollment data with Medicaid MCOs. Even fewer have a clear direction or standardized expectations for how that data should be utilized to facilitate SNAP enrollment. Clear federal guidance on SNAP data sharing with Medicaid MCOs, and even providers, could support Medicaid systems in taking a greater role in supporting co-enrollment.

Summary Recommendations

Food insecurity is one of the most common needs identified by low-income individuals and enrollment in the SNAP program affords individuals and families a path to sustainably meet their nutritional needs. Additionally, Medicaid MCOs possess the resources and connections to Medicaid beneficiaries, making them well suited to facilitate enrollment into the SNAP program. However, for MCOs to be successful they need access to data, accountability, and support. Interested states and advocates, could pursue one or all of the following steps to enable greater MCO support of SNAP enrollment:

If SNAP and Medicaid are housed in separate agencies, support agencies by clarifying the legal regulations that exist to promote data sharing and facilitating cross agency collaboration
Provide examples of existing data-sharing initiatives within your state or work in other states to initiate or advance discussions on what it would take to adopt a similar model in your state
Include clear requirements to support SNAP enrollment in Medicaid MCO contracts and allow MCOs to count those costs as “medical costs.”
Look for opportunities for data management modernization in your state to support the mechanics of data exchange
Request more aligned verification processes such as the same enrollment periods or opt-out systems for sharing eligibility data across platforms

Visit the MFSN website for resources to support implementation of these promising strategies, including the recently launched Medicaid Food Security Policy Dashboard and Medicaid and Food Security 101 learning series. You can also find the full “Promising Medicaid-Based Strategies to Address the Food Needs of Children and Families” resource on the MFSN website, which provides a deeper dive into each of the strategies outlined in this article.

^[1] Total Medicaid MCO Enrollment. (2020, August 21). KFF. https://www.kff.org/other/state-indicator/total-medicaid-mco-enrollment/?currentTimeframe=0&sortModel=%7B%22colId%22:%22Location%22

^[2] USDA ERS – Supplemental Nutrition Assistance Program (SNAP). (2017). Usda.gov. https://www.ers.usda.gov/topics/food-nutrition-assistance/supplemental-nutrition-assistance-program-snap/foodaps/#:~:text=The%20Supplemental%20Nutrition%20Assistance%20Program

^[3] Berkowitz, S. A., Palakshappa, D., Rigdon, J., Seligman, H. K., & Basu, S. (2021). Supplemental Nutrition Assistance Program Participation and Health Care Use in Older Adults : A Cohort Study. Annals of internal medicine, 174(12), 1674–1682. https://doi.org/10.7326/M21-1588

^[4] How Many People that Receive One Safety Net Benefit Also Receive Others? (n.d.). https://www.aspe.hhs.gov/sites/default/files/documents/340f9d2586febc3cdc1510f793403d0c/program-overlap-datapoint.pdf‌

^[5] Wolf, C. (2021, December 22). Think Big, Start Small: How Implementing Flexible Interviews Improves Benefit Delivery — Code for America. Code for America. https://codeforamerica.org/news/think-big-start-small-how-implementing-flexible-interviews-improves-benefit-delivery/

^[6] Federal Register :: Request Access. (n.d.). Unblock.federalregister.gov. https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.506

^[7] Social Determinants of Health (SDOH) Annual Medicaid MCO Survey How State Medicaid Agencies Could Further Assist Medicaid Health Plans in Addressing SDOH Needs 79%. (n.d.). Retrieved September 4, 2024, from https://medicaidinnovation.org/wp-content/uploads/2023/11/SDOH_MCO_Survey_Fact-Sheet_2023-Final-111423.pdf