With the COVID-19 Public Health Emergency ended, nearly 3.8 million people have lost Medicaid coverage during the redetermination process, with an estimated 15 million at risk. Varying disenrollment rates across states and a high procedural termination rate pose concerns. Children are losing coverage, particularly in non-expansion states. State Medicaid agencies are proactively engaging in outreach efforts to retain coverage. CMS is monitoring and offering flexibilities. Clear communication and engagement are vital to assist Medicaid enrollees during this transition.
Since the conclusion of the COVID-19 Public Health Emergency (PHE), nearly 3.8 million individuals have seen their Medicaid coverage discontinued. During the PHE, the federal government had guaranteed continuous Medicaid coverage for enrollees. However, with the PHE officially ended, states have recommenced the process of periodically reevaluating Medicaid eligibility. The assessment of eligibility began as early as February in some states, with most states initiating disenrollments by June. By late July, the count of those who lost their coverage had reached nearly 3.8 million.
It is estimated that around 15 million people may lose their Medicaid coverage during the redetermination process. Some of these individuals may be eligible for low-cost premiums in the health insurance marketplace, while others may have transitioned to alternative health insurance plans during the pandemic. Some could still be eligible for Medicaid but might lose their coverage due to administrative reasons, such as outdated addresses, incomplete renewal applications, failure to apply for renewal, or late submissions. These are referred to as procedural or administrative terminations, and many of those who lose coverage in this manner may eventually regain Medicaid coverage after a period without insurance. Unfortunately, in states that have not expanded Medicaid eligibility under the Affordable Care Act, there are limited affordable coverage options.
Early observations and concerns suggest that the rate of disenrollment varies significantly from one state to another, ranging from 8% in Wyoming to 82% in Texas. The high rate of procedural terminations in some states may be attributed to their initial focus on individuals presumed to be ineligible for Medicaid, which could decrease as they move on to individuals still presumed eligible. However, not all states are providing consistent or publicly available information, making it challenging to draw conclusions about the differing disenrollment rates among states or specific populations.
The Center for Medicare and Medicaid Services (CMS) closely monitors states and issued data in July regarding terminations in the first month of disenrollments in a few states, along with call center wait times across all states. CMS has granted states various options and flexibilities to reduce procedural terminations and has been granted additional enforcement capabilities under the Consolidated Appropriations Act (CAA). If a state fails to meet the conditions outlined in the CAA, CMS can halt procedural terminations in that state, mandate a corrective action plan, and potentially reduce the state’s federal match rate for each quarter of non-compliance.
One pressing concern is the loss of Medicaid coverage among eligible children. Typically, children are eligible at higher income levels compared to other covered groups. Parents or caregivers, believing they are no longer eligible, may neglect to submit renewal materials, inadvertently impacting their children’s coverage. This issue is prevalent in both expansion and non-expansion states, but it’s of particular concern in non-expansion states where Medicaid eligibility levels for parents and caregivers are extremely low.
Several state Medicaid agencies are implementing proactive strategies to enhance outreach to enrollees, aiming to increase response rates for renewals and facilitate access to alternative sources of coverage. Examples include:
– Arizona offering a live chat feature for Medicaid enrollees to assist with renewal.
– Missouri and New Mexico providing videos explaining the renewal process and necessary steps to maintain coverage.
– Kentucky and the District of Columbia holding regular meetings with stakeholders to analyze data, devise outreach strategies, resolve issues, and clarify messages.
– Massachusetts creating an outreach toolkit with materials available in multiple languages and collaborating with the Massachusetts Health Connector and Health Care for All to target high Medicaid enrollment communities for outreach about renewals and affordable state marketplace options for those no longer eligible for Medicaid.
