When a Medicaid enrollee moves out of state, they are required to report their change of residence to the Medicaid agency. However, many fail to do so, whether because they are unaware of this requirement or unsure of how to update their information, or their higher priority is enrolling in Medicaid in their new state of residence. This can result in Medicaid enrollment in more than one state (duplicate enrollment), which has been a persistent challenge for state Medicaid agencies. One result of this challenge is that if one or both states in which an individual is "duplicate enrolled" operate their Medicaid program through a Medicaid managed care delivery system, monthly capitation payments could be issued to a state health plan even though the person no longer resides in or seeks care in that state.1 This is an administrative problem that leads to unintentional waste of state and federal funds.
To mitigate duplicate Medicaid enrollment and payment, Medicaid statute and regulation require states to conduct data matching through the Public Assistance Reporting Information System (PARIS)2 which is administered by the U.S. Department of Health and Human Services (HHS) Administration for Children and Families (ACF) and is the only data resource available to states for this purpose. As part of the mandatory Medicaid Modified Adjusted Gross Income Verification Plan, all states must inform the Centers for Medicare & Medicaid Services (CMS), in detail, of how they use PARIS data to identify and avoid duplication of coverage.3
This expert perspective lays out the current challenges with using PARIS data matching and provides recommendations on how to improve identification of concurrent Medicaid enrollment.
Challenges with PARIS
PARIS data matching has significant timeliness and automation limitations. First, PARIS does not provide a real-time data source for states to check at the point of application whether an individual is currently enrolled in another state's Medicaid program. It provides static and retrospective data based on quarterly enrollment data submissions from states. As a result of this data lag, many duplicate enrollments go undetected until after duplicate enrollments have occurred and payments have been made.
The PARIS data match process begins with states submitting enrollment data to the ACF's contractor, the Defense Manpower Data Center (DMDC).4 The DMDC performs data matching against other participating state and federal files and, on a quarterly basis, returns matched results to each state via email with flags on individuals who may be receiving benefits in one or more states. States download the response files received from DMDC and must manually review and act on the information received.
Because the data is dated, it may not reflect accurate information on where the individual is residing. As a result, eligibility workers must conduct an eligibility review, which includes (1) sending notices to recipients to confirm whether they still reside in the state; (2) acting on the information received after sending the notice (e.g., maintaining coverage if the individual provides proof of state residence or terminating coverage if returned mail is received); (3) reaching out to the "other state" if the individual confirms residency to reconcile the duplicate enrollment; and (4) initiating recovery payments, as appropriate. This manual process is resource intensive and time consuming. Further, there is no federal guidance on the expected protocols and processes when a duplicate PARIS match is identified. As such, states often lack clarity on which state should follow up, end enrollment, and recover funds.
Nevertheless, states do take on, as they are required to do, the process of acting on "PARIS matches." However, swift action is impeded not only by the crude data and manual processing required, but also by workforce limitations and competing eligibility and enrollment priorities (often driven by federal partners). There are delays in processing PARIS matches that may indicate multi-state enrollment in most states as a result. This issue was particularly acute when states were working through renewal backlogs as part of the unwinding period following the COVID-19 public health emergency and will likely be further exacerbated if states are obligated to implement new eligibility and enrollment processes that are being considered by Congress, such as six-month renewals and verification of compliance with or exemptions from work requirements.
In a 2022 report, the HHS Office of Inspector General (OIG) documented these significant limitations with using PARIS data matching, highlighting the delay in the data that states received and the intensive manual process that is involved with processing the eligibility information.5 Because of these limitations, the HHS OIG recommended CMS provide states with matched Transformed Medicaid Statistical Information System (T-MSIS) enrollment data that identified Medicaid enrollees who were concurrently enrolled in Medicaid managed care in two states. Per the report, CMS did not concur with the recommendation on the basis that T-MSIS data would be duplicative to states and stated that CMS would provide "guidance and technical assistance to states as needed."6
Improving Identification of Concurrent Enrollments
There are a number of improvements to identify and act on multi-state Medicaid enrollments that would help states better address duplicate enrollment:
- Timely National Database. HHS should improve upon the timeliness, quality, and automation of the PARIS data or establish a new national data service hub that provides more timely multi-state enrollment information. Congress is currently considering a legislative proposal that directs HHS to establish a new national federal database by October 1, 2029, that would identify individuals simultaneously enrolled in Medicaid in more than one state on a monthly basis.7 If this proposal is adopted, the new system should also include functionality to provide real-time access at the point of application to: (1) the state that is processing the application; and (2) the state where the individual is already enrolled.
- IT System Upgrades. If a national database is established, federal funds should be allocated to support state system development to implement automated processes for acting on the multi-state information received automatically rather than relying on labor-intensive and error-prone manual processes. This would mean automatically ingesting the information into the eligibility system and issuing notices to enrollees based on receipt of concurrent enrollment rather than case workers having to manually research data accuracy.
- Standardized Processes. While a national solution is under development, CMS should develop clear guidance to states that outlines the expected processes when receiving PARIS data. Such federal guidance must be developed in close partnership with states.
- Monitoring and Oversight. States that have not already done so should consider establishing oversight and monitoring processes to ensure that county, regional, and statewide offices are acting to address duplicate enrollments and implementing corrective actions if they are not.
Conclusion
PARIS is the only tool in place today to inform dual-state Medicaid enrollment; its data quality issues and high-administrative workforce burden limit its usefulness. States are eager to work in partnership with CMS to discuss current challenges, inform federal development of a new national database, inform federal guidance on standardized processes, and work across states to share peer-to-peer best practices and develop additional mitigation strategies.
Footnotes
1. Office of Inspector General, Nearly All States Made Capitation Payments for Beneficiaries Who Were Concurrently Enrolled in a Medicaid Managed Care Program in Two States; and the U.S. Government Accountability Office, Additional Actions Needed to Help Improve Provider and Beneficiary Fraud Controls.
2. 42 U.S.C. § 1396r(c)(3); 42 C.F.R. § 435.945(d).
3. CMS, Verification Plan Template – Guidance and Instructions.
4. ACF, Operational Partnership Initiative Electronic File Transmission Instructions for PARIS; and Defense Manpower Data Center.
5. HHS OIG, Nearly All States Made Capitation Payments for Beneficiaries Who Were Concurrently Enrolled In a Medicaid Managed Care Program In Two States. See also: HHS OIG, Ohio Made Capitation Payments to Managed Care Organizations for Medicaid Beneficiaries With Concurrent Eligibility in Another State; HHS OIG, Illinois Made Capitation Payments to Managed Care Organizations for Medicaid Beneficiaries With Concurrent Eligibility in Another State; HHS OIG, Minnesota Made Capitation Payments to Managed Care Organizations for Medicaid Beneficiaries With Concurrent Eligibility in Another State.
6. Id.
7. 119th Congress (2025-2026), H.R.1.
Originally published by State Health and Value Strategies.
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