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Updates from the Medicaid Food Security Network

Dear MFSN Members,

Through the summer holidays and June organizational changes mentioned in our July Digest, the Medicaid Food Security Network (MFSN) Co-Design Team has stayed engaged, leaning into existing and new opportunities to support the Network with resources and to provide support to its Medicaid Food Security Partners and other states to take concrete steps toward policy change that will improve partnership with Medicaid systems to address food and nutrition security for children and families. In addition to our four official state partners in GA, MI, OK and VA, the MFSN has provided hands-on support to groups in CO, IL, and has engaged NV in advance of its Medicaid procurement schedule. Representatives of the work in GA and CO will be sharing how they have used the MFSN Policy Dashboard and benefited from the technical assistance provided by MFSN Co-Designer, HealthBegins, at the National Produce Prescription Collaborative Summit later this month. Network Members can also find lots of up-to-date resources on the website furnished by Steering Committee organizations, including links to survey results and a new toolkit, all incredibly vital to making our work more targeted and informed.

As we head into fall, we’re delighted to share new additions to our broader team: Craig Moscetti, MPH, Senior Manager, Policy at Share Our Strength’s Center for Best Practices, is now dedicating time to the MFSN Policy Dashboard and has highlighted some valuable policy updates for this digest. We are also delighted to welcome Alexandra Ashbrook, Director of WIC and Root Causes at FRAC to the MFSN Steering Committee. And last but not least, we are very excited to welcome Elevance Health as a sponsoring partner to the work of the MFSN. Elevance’s valuable investment in food is medicine is well established in the field. Join us on September 12th to learn more about their engagement during our upcoming convening.

Signed, Co-Designers

Highlights and New Resources

Feature Story

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

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

^[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

Other Updates from the MFSN

As organizations in healthcare and various social sectors consider more comprehensive, upstream approaches, such as how to address food insecurity for families, they encounter various challenges. To identify the needed reforms, Convergence brought together nearly 40 organizations, including Share Our Strength, and experts from multiple sectors to find consensus on a Blueprint for Action: https://convergencepolicy.org/our-work/health-and-wellbeing/convergence-collaborative-on-social-factors-of-health/

Upcoming Events and Opportunities

Mark Your Calendars! Join us for the Medicaid Food Security Network Quarterly Convening on September 12th from 1:00 PM to 2:30 PM Eastern Time. This engaging webinar will provide valuable insights and resources to support your collaboration with Medicaid in addressing food and nutrition security. Hear from industry experts Food is Medicine Coalition, Association for Community Affiliated Plans, Food Research & Action Center, Children’s HealthWatch and the National Association of Community Health Workers to learn about actionable policy tools, SDoH survey findings, strategies for tackling food insecurity, and methods for enhancing community health worker roles in Medicaid. Don’t miss this opportunity to advance your efforts in food security! Register here.

We are excited to have two representatives from the MFSN at NPPC’s National Summit in Washington, DC on September 18th, where they will participate in the state policy panel and workshop titled “Blueprints for Success: Adapting and Implementing State Policies Across New Jurisdictions.” This session will explore how policymakers and program implementers across the country have adapted existing policies—such as legislation and waiver proposals—to their state’s unique circumstances in order to tackle nutrition and diet-related chronic diseases. The MFSN representatives, Sandra Hoyt Stenmark, M.D., FAAP, Clinical Professor of Pediatrics at the University of Colorado Anschutz Medical Campus, and Kelcie Silvio, LMSW, M.P.H., Senior Policy Analyst at Voices for Georgia’s Children, will provide valuable insights into how they have used MFSN resources to make policy gains in their states.

Policy Updates

New York State Announces New Investments in Social Care Network

As part of its recently approved Medicaid Section 1115 Demonstration Waiver, New York committed $500 million over the next three years to support nine organizations in facilitating the delivery of services to address health-related social needs, including nutrition, housing supports, transportation, and case management for eligible Medicaid members.

Connecticut Enacts Law to Streamline Cross-Enrollment in Child Nutrition Programs

Signed on May 30, 2024, the legislation (H.B.5003) requires the Department of Public Health, in collaboration with the Departments of Social Services and Agriculture, to develop a plan by January 1, 2025, to streamline the cross-enrollment of children receiving Medicaid into SNAP, WIC, and the Connecticut Farmers’ Market/WIC Nutrition Program.

CMS Approves Delaware 1115 Waiver Extension with Expanded Nutrition Supports Initiative

On May 17, 2024, CMS approved a five-year extension of Delaware’s Diamond State Health Plan (DSHP) section 1115 waiver, which expands a Postpartum Nutrition Supports Initiative (also known as the Food Box Initiative) to provide Medicaid coverage for two meals per day, diapers, and baby wipes for postpartum beneficiaries experiencing food insecurity and adverse maternal and birth outcomes for the first 12 weeks postpartum.

New Comparison of Presidential Candidates’ Positions on Medicaid Policy

The Kaiser Family Foundation recently released a side-by-side comparison of health policy positions, including Medicaid, of the two presidential candidates, Donald Trump and Kamala Harris.

News Digest: September 6, 2024