The Centers for Medicare & Medicaid Services (CMS) recently revealed that millions of individuals were dually enrolled in taxpayer-funded health programs in 2024, raising new concerns about overlapping coverage and underscoring the urgent need for improved data and technology to support Medicaid cost avoidance.
Medicaid duplicate enrollment is costing the program valuable resources. According to CMS, 1.2 million people were enrolled in Medicaid or the Children’s Health Insurance Program (CHIP) in more than one state simultaneously during the past year. In addition, 1.6 million individuals were enrolled in both Medicaid and a subsidized Marketplace plan under the Affordable Care Act. These figures were uncovered through collaboration between CMS and a team of software engineers who reviewed national enrollment data.
For managed care organizations (MCOs) across the country, these findings are both familiar and frustrating. TPL and COB departments work diligently to ensure members have the right coverage and that taxpayer funds are used efficiently. These teams are doing everything in their power with the resources available to them. But despite their best efforts, systemic gaps in data access and verification tools make it extremely difficult to prevent enrollment overlaps before they occur.
Duplicate enrollments across states or between Medicaid and other subsidized programs can result in significant financial waste, disrupt care coordination, and create confusion for both providers and beneficiaries. In many cases, MCOs discover these issues only after claims have been paid, forcing plans to pursue costly and often unsuccessful recovery efforts, instead of avoiding improper payments upfront.
“Plans aren’t failing to do the work. They’re being asked to manage a national-scale eligibility challenge without the modern tools required to solve it,” noted one industry expert.
The current system often relies on outdated and incomplete data, as well as lagging eligibility feeds and fragmented interagency communication. Managed care plans have implemented numerous internal measures to flag suspected dual coverage. Still, without real-time, standardized access to enrollment and eligibility data across states and programs, true cost avoidance remains out of reach.
CMS’s report reinforces a message Medicaid plans have been delivering for years: Improving the integrity of public health programs doesn’t start with blame—it starts with better infrastructure. The professionals behind Medicaid COB and TPL functions are among the most resource-conscious in healthcare, and their work consistently saves public programs billions of dollars. But they cannot succeed alone.
If the Medicaid program is to sustain its promise as a safety net for those who need it most, the federal and state governments must invest in interoperable systems, more innovative data-sharing practices, and new technology that empowers plans to act before dollars are spent.
As attention turns to addressing the estimated 2.8 million cases of overlapping enrollment, the path forward is clear: Medicaid managed care plans are already leading the charge to protect program resources and improve outcomes for their members. With better access to timely, accurate, and integrated data, these plans can move from reactive recovery to true, proactive cost avoidance, further strengthening their ability to ensure that Medicaid dollars are spent appropriately and effectively.
