CMS Highlights State Use Of Ex Parte As Key To Implementing Work Reqs

By Dorothy Mills-Gregg / September 12, 2025

KANSAS CITY -- CMS hopes states will be able to reuse their automated income verification process already in place for Medicaid renewals when implementing the new work requirements and more frequent eligibility renewals, a CMS official told Medicaid Health Plans of America conference attendees Thursday (Sept. 12).

States and Medicaid stakeholders are still frantically parsing through all the provisions of the One Big Beautiful Bill -- a reconciliation bill Congress passed in July that will cut an estimated $1 trillion in federal Medicaid funding over the next decade through reforms like a national work requirement, capping state directed payments and lowering the provider tax threshold, among many other changes.

But the Trump administration seems to be trying to calm stakeholders by saying states will be able to use existing technology to meet the new requirements.

CMS Senior Advisor Grant Thomas tried to reassure MHPA conference attendees Thursday that beneficiaries will be okay during this transition, telling them the OBBB reforms are meant to return Medicaid to helping only the “most vulnerable beneficiaries.”

A lot of states are using technology to help them process Medicaid renewals ex parte, Thomas said, referring to a practice where states use a third party to automatically confirm a beneficiary’s income or other eligibility information to determine on-going eligibility. Ex parte is promoted by advocates as one of the best ways to reduce inappropriate Medicaid coverage loss due to paperwork issues.

“[D]epending on the state, ex parte rates could be 40% to 60%, and so states already have a lot of experience utilizing that for income verification in Medicaid, and so we’re going to be working for it and trying to apply that to employment hours, which is very similar to the income verification, education, volunteer, [etc.],” Thomas said.

CMS’ focus on leveraging technology in work requirements was echoed at a recent virtual discussion hosted by KFF, where one panelist said CMS is planning to provide states with resources like an income verification application.

State ex parte rates will also be relevant when it comes to meeting the OBBB requirement that redeterminations are now done every six months rather than once a year, Thomas said.

“A lot of times . . . individuals are not even aware that they’re up for redetermination because it’s just automatically happening and going through the system at the state on the back end,” Thomas said. “So we want to really make sure that it’s as seamless of an implementation as possible, where we can promote and have program integrity, but also use technology to efficiently do so and minimize any burden on the Medicaid members.”

Thomas did not mention the guidance released in September 2024 under the Biden administration that gave states until Dec. 31, 2026 to meet federal requirements around ex parte rates and other eligibility requirements.

Illinois Association of Medicaid Health Plans CEO Jill Hayden said using the existing ex parte renewals process that her state recently invested in to implement the work requirements will likely play a part in their public education efforts around OBBB’s provisions.

Illinois is up to a 65% ex parte rate so “to the extent that you could build any proof of job somehow into that -- or education or volunteerism or whatever -- that might be an opportunity too,” Hayden said an MHPA conference session Friday (Sept. 12) when explaining her organization’s planned communications campaign around the OBBB provisions. Most of their communication campaign will likely be based on the post-COVID redetermination communications and connections with local leaders.

Thomas also tried to encourage Medicaid managed care organizations to explain to beneficiaries the new work requirements and increased renewals mandated by the OBBB. But, some experts say it’ll be up to the individual states on how much freedom MCOs will have to explain the new requirements as some states might develop a communications packet to prescribe MCO messaging on the work requirements or redeterminations.