Howard cites the governance challenges posed by the massive requirements for integration and coordination of business process. "Effective governance is proving to be a major obstacle to service integration across agency boundaries," he says.
The need to address technical and organizational obstacles on a tight deadline may cause some agencies to scale back expectations. Wilbur believes the best-case scenario for a number of states will be going live on Jan. 1 as opposed to Oct. 1.
Some states, she adds, may temporarily give up on building their own expanded Medicaid eligibility systems. Those will leverage the Federally Facilitated Marketplaces, which will include a system for determining Medicaid and CHIP eligibility. States may also use the federal government's Data Services Hub, which connects to Internal Revenue Service and Social Security Administration data, to help verify an applicant's eligibility information.
Howard, however, says that those components-and many state exchanges - will still need work when day one arrives. "The confidence of federal and supportive state officials notwithstanding, it's highly unlikely that most state exchanges, the federal marketplace or the federal data hub will be thoroughly tested and fully operational by the first day of open enrollment."
Wilbur notes that it took two or three years to work the kinks out of Medicare Part D - and adds that Medicaid expansion is much more complicated.
"It's hard for people to understand how complex these system builds are and...the amount of integration that's needed to make this work," Wilbur says. "[States] are modernizing how eligibility and enrollment gets done, and it's not surprising people are running into issues and concerns."
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