Three Lessons: How Kentucky Turned a Federal Requirement into a Meaningful Voice for Medicaid Beneficiaries

November 11, 2026

Beneficiary voices are integral to continuous quality improvement and increasing access to services across state Medicaid programs. 

In 2024, the Centers for Medicare & Medicaid Services (CMS) finalized the Ensuring Access to Medicaid Services Final Rule (42 CFR 431.12), which required states to establish Beneficiary Advisory Councils (BACs) to give Medicaid beneficiaries a direct voice in program oversight and policy development.

Kentucky's Department for Medicaid Services (DMS), which serves 1.45 million beneficiaries, approached the mandate as an opportunity to strengthen the connection between Medicaid beneficiaries and state leadership to shape improvements across their programs and services. To accomplish this, DMS partnered with Altarum to effectively launch its first BAC and help ensure members had the support they needed to participate fully. In just 11 months, the project established new ways for beneficiary feedback to reach state leaders and inform broader Medicaid discussions. 

Kentucky's experience provides practical insights for other states implementing BACs.

Lesson 1: Meaningful Participation Requires High-Touch Support

Many beneficiaries have never served in an advisory role to a state agency. Kentucky DMS wanted to ensure that beneficiaries had the support needed to engage fully and share their perspectives. To help members participate confidently and effectively, Altarum liaisons maintained regular one-on-one contact with participants throughout the project. These liaisons answered questions, identified individual needs, gathered feedback, and helped members navigate discussions about complex Medicaid policies and programs.

Behind the scenes, Altarum helped to coordinate accessibility accommodations, member reimbursement, and other activities that kept participation from being a burden.

Lesson 2: Close the Feedback Loop

Closing the feedback loop with beneficiaries demonstrates that their input is taken seriously and can help shape programs and decisions. Sharing how their perspectives were considered shows respect for the time and effort they invested, and it reinforces the value of continued engagement. 

Altarum worked with DMS to establish documentation and tracking procedures for BAC member comments, questions, and recommendations and created a process for DMS to respond. The team tracked BAC member input from when it was raised through DMS’s response. 

Throughout the project, BAC members provided feedback on various topics from when waiver participants could lose access to services to electronic verification procedures. BAC members also had the opportunity to review and comment on a letter that is sent to individuals placed on the Supports for Community Living waiting list. The feedback loop was transparent, and beneficiaries knew their questions and recommendations were being taken seriously. Altarum’s process also gave DMS direct insight into how beneficiaries experience Medicaid programs in their daily lives.

BAC members could also weigh in on the BAC itself; they helped develop bylaws, suggested meeting topics, and shared ideas for improving the council. Altarum worked with BAC leadership to ensure members’ suggestions were considered and addressed. This second feedback loop helped members feel valued and more invested in the BAC.

Lesson 3: Sustainability Requires Infrastructure

Engagement alone isn’t enough to sustain a BAC. Clear governance procedures, consistent onboarding, defined communication workflows, and a process for tracking recommendations from submission through resolution keep the BAC running smoothly. They create accountability, preserve institutional knowledge, and ensure beneficiary input continues to inform decision-making. Without this infrastructure, processes can become dependent on individual staff members, responsibilities may be unclear, and beneficiaries may have limited visibility into what happens after they provide input.

Altarum worked with DMS to embed these structures into routine operations so the BAC could continue functioning effectively beyond the initial implementation period. The team documented processes, developed templates and operational guidance, created an operations manual, supported transition planning, and transferred knowledge and responsibilities to DMS staff. The resulting framework gave DMS the processes and resources needed to maintain consistent BAC operations, support beneficiary participation, and show how beneficiary recommendations are considered and resolved.

Looking Beyond the Requirement

With Altarum’s expertise and direct work with beneficiaries, Kentucky went beyond the letter of the rule. The state created stronger connections between Medicaid beneficiaries and state leadership and gave both a way to regularly engage with one another. 

The same council that helped clarify waiver protections and weighed in on a beneficiary letter can provide feedback on issues ranging from rural health initiatives to maternity care. It can inform policy changes, program redesigns, and beneficiary communications. DMS doesn't have to build a new focus group or outreach effort every time it needs beneficiary input.

Could your BAC play a larger role in your Medicaid programs? Altarum helps agencies support council members and manage the operational work—from onboarding to recommendation tracking—that keeps a BAC running.