DATE: April 10, 2025
TO: Assembly Committee on Public Benefit Reform
FR: William Parke-Sutherland, Government Affairs Director
RE: Opposition to AB 163 – redeterminations of eligibility for the Medical Assistance program and database confirmation for public assistance program eligibility.

Chairperson Knodl and committee members,

Kids Forward strongly opposes Assembly Bill 163. It will create harmful barriers to Medicaid participation, reduce access to health care among Medicaid-eligible children, parents, people with disabilities, and would worsen racial disparities in access to care and coverage. 

Kids Forward aspires to make Wisconsin a place where every child thrives. We advocate for effective, long-lasting solutions that break down barriers to success for children and families of color and rural families. Using research and a community-informed approach, Kids Forward works to help every kid, every family, and every community thrive.

AB 163 would prohibit DHS from automatically renewing coverage for Medicaid enrollees, would require eligibility to be verified every six months (instead of annually), and disallow the use of pre-populated forms. It would also require that people lose their coverage for six months if they fail to report, within 10 days, any change that may impact their eligibility. The bill also appears to require DHS to disenroll people who are found ineligible through data matching efforts. 

Doubling renewals, prohibiting automatic renewals, disallowing DHS from using best practices for renewals, such as pre-populating forms, would all significantly increase administrative burdens. More people would become uninsured, and it would exacerbate health disparities. A report from the Office of Management Budget found that barriers making it harder for people to access public benefits worsen health disparities. AB 163 would require someone enrolled in one of the state’s many Medicaid programs (like BadgerCare Plus or Family Care) to fill out more paperwork, answer more notices and phone calls, submit more verification and documentation, and have more interactions with income maintenance workers. All this additional work would fall hardest on those who have the least amount of time and resources. 

Because of long-term employment and economic discrimination, Black, Brown, and Indigenous people are more likely to have lower-paying jobs, less access to insurance, and more likely to face transportation and connectivity barriers and financial instability. The report notes that during the great recession Black and Hispanic workers were less likely to receive unemployment insurance benefits than White workers. Increasing administrative burdens by implementing this proposal would likely disproportionately harm Black and Brown people in Wisconsin. 

Automatic renewals help states ensure those who are eligible for coverage remain covered without adding costly administrative burdens and red tape like over-verification and redundant renewal forms. Forms can get lost in the mail, processed incorrectly, sent to the wrong address, not returned in a timely manner, poorly translated into languages other than English, and be misunderstood by beneficiaries (regardless of what language the form is in). All of these can lead to people losing their coverage despite being eligible and can result in increased health costs and worse health outcomes for people who need regular access to health care services.

Renewals help the state ensure that people who are enrolled are Medicaid eligible, but they are also when people are most likely to lose coverage, even if they are eligible. AB 163, which would make state staff process twice as many renewals as they do currently, would cause more Medicaid-eligible children, families, and people with disabilities to fall through the cracks and become uninsured. Further, it is unclear how many people could be required to renew coverage semi-annually. Federal regulations state that renewals for individuals whose Medicaid eligibility is based on modified adjusted gross income (MAGI) methods may not be done more frequently than every 12 months.¹ For most children, parents, adults without dependent children and pregnant people covered by BadgerCare Plus this section of the bill would likely not apply.

According to a report by the Medicaid and CHIP Payment and Access Commission (MACPAC), Wisconsin already has some of the highest rates of churn in the country. More than 12 percent of enrollees were disenrolled and then re-enrolled within 12 months. According to that same report, Black enrollees are more likely to be impacted by churn needlessly losing coverage more often than their white counterparts. Increasing administrative burdens could have a disproportionate impact. Further, language barriers for websites, communications, and interacting with income maintenance workers make it likely that people who speak a language other than English would be disproportionately impacted needlessly losing coverage despite being eligible. 

Doubling the number of renewals would also mean tremendous increases in state costs and staffing needs, which this bill doesn’t acknowledge or allocate funding for. An HHS study estimated the cost of processing a single instance of disenrollment and re-enrollment at between $400 and $600.²

Federal Medicaid rules require that states attempt to renew members’ coverage using other available data sources³ because this is one of the most efficient and cost-effective ways to keep people insured. States are required to use data sources the state determines useful. By requiring data checks for ineligibility and creating six-month sanctions, the bill is trying to have it both ways. If the data is good enough to prove someone is ineligible, then it is good enough to confirm that person’s eligibility. For these reasons, it is likely that the proposed prohibition is inconsistent with federal law. 

Please oppose this bill because it would prohibit one of the best ways of keeping eligible Wisconsinites covered, increase rates of churn where people are needlessly losing care and coverage, and exacerbate health disparities. It would also needlessly create substantial administrative burdens for staff and balloon administrative costs. 

Please feel free to contact me at wparkesutherland@kidsforward.org with questions, follow up, or requests for more information. Thank you. 

1. § 435.916 Periodic renewal of Medicaid eligibility. ↩︎
2. https://aspe.hhs.gov/sites/default/files/migrated_legacy_files/199881/medicaid-churning-ib.pdf ↩︎
3. 435.916(a)(2) Renewal on basis of information available to agency. The agency must make a redetermination of eligibility without requiring information from the individual if able to do so based on reliable information contained in the individual’s account or other more current information available to the agency, including but not limited to information accessed through any data bases accessed by the agency under §§ 435.948, 435.949 and 435.956. ↩︎