10 Things to Know About the Unwinding of the Medicaid Continuous Enrollment Provision


  1. Medicaid enrollment increased since the start of the pandemic, primarily due to the continuous enrollment provision.
  2. KFF estimates that between 8 million and 24 million people will lose Medicaid coverage during the unwinding of the continuous enrollment provision.
  3. The Medicaid continuous enrollment provision stopped “churn” among Medicaid enrollees.
  4. States approaches to unwinding the continuous enrollment provision vary.
  5. Maximizing streamlined renewal processes can promote continuity of coverage as states unwind the continuous enrollment provision.
  6. States have obtained temporary waivers to pursue strategies to support their unwinding plans.
  7. Certain groups may be at greater risk of losing Medicaid coverage during the unwinding period.
  8. States can partner with MCOs, community health centers, and other partners to conduct outreach.
  9. Timely data on disenrollments and other metrics will be useful for monitoring how the unwinding is proceeding.
  10. The number of people without health insurance could increase if people who lose Medicaid coverage are unable to transition to other coverage.

Initially of the pandemic, Congress enacted the Households First Coronavirus Reaction Act (FFCRA), which integrated a requirement that Medicaid systems stay other folks ceaselessly enrolled throughout the finish of the COVID-19 public well being emergency (PHE), in alternate for enhanced federal investment. As a part of the Consolidated Appropriations Act, 2023, signed into legislation on December 29, 2022, Congress delinked the continual enrollment provision from the PHE, finishing steady enrollment on March 31, 2023.  The CAA additionally levels down the improved federal Medicaid matching finances via December 2023. Essentially because of the continual enrollment provision, Medicaid enrollment has grown considerably in comparison to ahead of the pandemic and the uninsured rate has dropped. All through the unwinding of the continual enrollment provision, hundreds of thousands of persons are anticipated to lose Medicaid and that might opposite contemporary good points in protection, even though no longer everybody who loses Medicaid will change into uninsured. States may start disenrolling other folks beginning in April, however many didn’t resume disenrollments till Might, June, or July. To be eligible for enhanced federal investment all through the unwinding, states will have to meet positive necessities. So far, as reported within the KFF Medicaid Enrollment and Unwinding Tracker, there’s vast variation within the quantity of people that were disenrolled and in disenrollment charges throughout states with publicly to be had information.

This transient describes 10 key issues in regards to the unwinding of the Medicaid steady enrollment provision, highlighting information and analyses that may tell the unwinding procedure in addition to law and steerage issued by means of the Facilities for Medicare and Medicaid Products and services (CMS) that lay out the principles states will have to observe all through the unwinding duration and the flexibilities to be had to them.

1. Medicaid enrollment greater for the reason that get started of the pandemic, basically because of the continual enrollment provision.

KFF estimates that enrollment in Medicaid/CHIP enrollment can have grown by means of 23.3 million to just about 95 million from February 2020 to the top of March 2023, when the continual enrollment provision ended (Determine 1). General enrollment will increase mirror financial prerequisites associated with the pandemic, the adoption of the Medicaid enlargement underneath the Inexpensive Care Act in different states (NE, MO, OK), in addition to the continual enrollment provision integrated within the FFCRA. This provision calls for states to supply steady protection for Medicaid enrollees with a purpose to obtain enhanced federal investment. Via fighting states from disenrolling other folks from protection, the continual enrollment provision has helped to maintain protection all through the pandemic. It additionally greater state spending for Medicaid, even though KFF has estimated that the improved federal investment from a 6.2 share level building up within the federal fit fee (FMAP) exceeded the upper state prices via 2022.

The Consolidated Appropriations Act, 2023 decoupled the Medicaid steady enrollment provision from the PHE and terminated this provision on March 31, 2023. Beginning April 1, 2023, states may resume Medicaid disenrollments. States shall be eligible for the phase-down of the improved FMAP (6.2 share issues via March 2023; 5 share issues via June 2023; 2.5 share issues via September 2023 and 1.5 share issues via December 2023) if they agree to positive laws. They can not limit eligibility requirements, methodologies, and procedures and can not building up premiums as required in FFCRA. Additional, states will have to additionally conform to federal laws about accomplishing renewals. Finally, states are required to deal with up to the moment touch data and try to touch enrollees previous to disenrollment when mail is returned.

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2. KFF estimates that between 8 million and 24 million other folks will lose Medicaid protection all through the unwinding of the continual enrollment provision.

Whilst the collection of Medicaid enrollees who is also disenrolled all through the unwinding duration is very unsure, KFF estimates that between 7.8 million and 24.4 million other folks may lose Medicaid protection all through the 12-month unwinding duration reflecting an 8% and 28% decline in enrollment (Determine 2). If Medicaid enrollment lowered by means of 18%, the midpoint of the variability, 17 million other folks would lose Medicaid protection. Those projected protection losses are in step with estimates from the Division of Well being and Human Products and services (HHS) suggesting that as many as 15 million other folks shall be disenrolled, together with 6.8 million who will most likely nonetheless be eligible. Findings from a survey of Medicaid enrollees fielded simply previous to the beginning of the unwinding duration counsel that many of us who shall be disenrolled within the coming months might proceed to be eligible. Whilst maximum enrollees have been unaware that states are authorized to renew disenrollments suggesting they won’t know that they are going to want to renew their protection within the coming months, just about two-thirds of enrollees mentioned they’ve no longer had a metamorphosis in revenue or circumstance that will cause them to ineligible for Medicaid.

Whilst the percentage of people disenrolled throughout states will range because of variations in how states prioritize renewals, it’s anticipated that the teams that skilled essentially the most enlargement because of the continual enrollment provision—ACA enlargement adults, different adults, and youngsters—will enjoy the most important enrollment declines. Efforts to behavior outreach, training and supply enrollment help can assist make sure that those that stay eligible for Medicaid are in a position to retain protection and those that are not eligible can transition to different assets of protection.

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3. The Medicaid steady enrollment provision  stopped “churn” amongst Medicaid enrollees.

The brief lack of Medicaid protection by which enrollees disenroll after which re-enroll inside of a brief time frame, ceaselessly known as “churn,” happens for a a number of causes. Enrollees might enjoy non permanent adjustments in revenue or instances that cause them to quickly ineligible. However, some individuals who stay eligible might face limitations to keeping up protection because of renewal processes and periodic eligibility exams. Eligible people are in danger for shedding protection if they don’t obtain or perceive notices or paperwork soliciting for more information to ensure eligibility or don’t reply to requests inside of required timeframes. Churn may end up in access barriers in addition to further administrative prices. Estimates point out that amongst full-benefit beneficiaries enrolled at any level in 2018, 10.3% had a gap in coverage of lower than a 12 months (Determine 3). About 4.2% have been disenrolled after which re-enrolled inside of 3 months and six.9% inside of six months. Every other analysis inspecting a cohort of kids newly enrolled in Medicaid in July 2017 discovered that churn charges greater than doubled following annual renewal, signaling that many eligible kids lose protection at renewal. Via halting disenrollment all through the PHE, the continual enrollment provision has additionally halted this churning amongst Medicaid enrollees. Seven states have waivers approved (6) or pending (1) to permit for assured steady enrollment past what is authorized underneath present legislation, together with approvals in Washington and Oregon to ensure Medicaid protection for kids via age six.

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4. State approaches to unwinding the continual enrollment provision range.

States are taking other approaches to unwinding the continual enrollment provision. CMS requires states to publish renewal redistribution plans that describe how the state will prioritize renewals, how lengthy the state plans to take to finish the renewals in addition to the processes and techniques the state is thinking about or has followed to scale back irrelevant protection loss all through the unwinding duration. As of Might 9, 2023, 30 states had posted their renewal redistribution plan, which needed to be submitted to CMS by means of February 15, 2023 for many states. Variations in state renewal and other policies and in how they enforce the ones insurance policies are more likely to result in variations throughout states within the extent of Medicaid enrollment declines all through the unwinding duration.

In keeping with a KFF survey carried out in January 2023, states have taken quite a lot of steps to organize for the top of the continual enrollment provision (Determine 4). Beneath CMS steerage, states had the approach to get started the unwinding duration by means of beginning the primary batch of renewals in February, March, or April. Eight states began the method in February, every other 15 began in March, and 28 states started in April. Maximum states (43) mentioned they plan to take 12-14 months to finish all renewals (the rest 8 states mentioned they deliberate to take lower than twelve months to finish renewals). All states indicated they’d taken steps to replace enrollee touch data all through the previous 12 months and nearly three-quarters of states (38) have been making plans to observe up with enrollees who don’t reply to a renewal request ahead of terminating protection.

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5. Maximizing streamlined renewal processes can advertise continuity of protection as states unwind the continual enrollment provision.

Beneath the ACA, states will have to search to finish administrative (or “ex parte”) renewals by means of verifying ongoing eligibility via to be had information assets, similar to state salary databases, ahead of sending a renewal shape or soliciting for documentation from an enrollee. Some states suspended renewals as they carried out the continual enrollment provision and made different COVID-related changes to operations. Finishing renewals by means of checking digital information assets to ensure ongoing eligibility reduces the load on enrollees to deal with protection. Whilst 31 states have taken motion prior to now 12 months to extend ex parte renewal charges, in lots of states, the percentage of renewals finished on an ex parte foundation is low. Even supposing states weren’t required to procedure ex parte renewals whilst the continual enrollment provision was once in position, of the 43 states that have been processing ex parte renewals for MAGI teams (other folks whose eligibility is in keeping with changed adjusted gross revenue) in January 2023, 18 states reported finishing 50% or extra of renewals the usage of ex parte processes. Twenty states finished lower than 50% of renewals on an ex parte foundation, together with 11 states the place lower than 25% of renewals have been finished the usage of ex parte processes (Determine 5). The collection of states reporting they whole greater than 50% of renewals the usage of ex parte processes for non-MAGI groups (other folks whose eligibility is in keeping with being over age 65 or having a incapacity) is even decrease at 6.

As states start to unwind the continual enrollment provision, there are alternatives to advertise continuity of protection amongst enrollees who stay eligible by means of expanding the percentage of renewals finished the usage of ex parte processes and taking different steps to streamline renewal processes (which will even have a tendency to extend enrollment and spending). CMS guidance notes that states can building up the percentage of ex parte renewals they whole with no need to observe up with the enrollee by means of increasing the knowledge assets they use to ensure ongoing eligibility. Alternatively, when states do want to observe up with enrollees to acquire more information to verify ongoing eligibility, they are able to facilitate receipt of that data by means of permitting enrollees to publish data by means of mail, in user, over the telephone, and on-line. Whilst just about all states settle for data in-person (51 states) and by means of mail (50 states), somewhat fewer supply options for people to publish data on-line (48 states) or over the telephone (46 states).

A proposed rule, launched on September 7, 2022, seeks to streamline enrollment and renewal processes one day by means of making use of the similar laws for MAGI and non-MAGI populations, together with proscribing renewals to as soon as in keeping with 12 months, prohibiting in-person interviews and requiring using prepopulated renewal paperwork. General, each and every state has taken a minimum of one motion to align renewal processes for non-MAGI populations with the ones for MAGI populations, together with 45 states that experience eradicated in-person interviews, 42 states that restrict renewals to as soon as in keeping with 12 months, and 33 states that ship pre-populated renewal paperwork.
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6. States have received brief waivers to pursue methods to fortify their unwinding plans.

As states get ready to finish redeterminations for all Medicaid enrollees, many might face important operational demanding situations associated with staffing shortages and old-fashioned methods. To cut back the executive burden on states, CMS announced the provision of brief waivers via Phase 1902(e)(14)(A) of the Social Safety Act. Those waivers shall be to be had on a time-limited foundation and can permit states to facilitate the renewal procedure for positive enrollees with the objective minimizing procedural terminations. As of February 24, 2023, CMS had approved a complete of 188 waivers for 47 states (Determine 6). Those waivers come with methods permitting states to: renew enrollee protection in keeping with SNAP and/or TANF eligibility; permit for ex parte renewals of people with 0 revenue verified throughout the previous twelve months; permit for renewals of people whose property can’t be verified throughout the asset verification gadget (AVS); spouse with controlled care organizations (MCOs), enrollment agents, or use the Nationwide Alternate of Cope with (NCOA) database or US postal carrier (USPS) returned mail to replace enrollee touch data; lengthen automated enrollment in MCO plans as much as 120 days; and lengthen the time frame for truthful listening to requests.

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7. Positive teams is also at higher possibility of shedding Medicaid protection all through the unwinding duration.

As states resume redeterminations and disenrollments, positive folks, together with individuals who have moved, immigrants and other folks with restricted English skillability (LEP), other folks with disabilities, and older adults, shall be at greater possibility of shedding Medicaid protection or experiencing an opening in protection because of limitations finishing the renewal procedure, even though they continue to be eligible for protection. Enrollees who’ve moved won’t obtain vital renewal and different notices, particularly if they’ve no longer up to date their touch data with the state Medicaid company. In 2020, one in ten Medicaid enrollees moved in-state and whilst stocks of Medicaid enrollees shifting inside of a state has trended downward in recent times, the ones tendencies may have modified in 2021 and 2022.

An analysis of churn charges amongst kids discovered that whilst churn charges greater amongst kids of all racial and ethnic teams, the rise was once greatest for Hispanic kids, suggesting they face higher limitations to keeping up protection. Moreover, other folks with LEP and other folks with disabilities are much more likely to stumble upon demanding situations because of language and different limitations having access to data in wanted codecs. An analysis of state Medicaid web pages discovered that whilst a majority of states translate their on-line utility touchdown web page or PDF utility into different languages, maximum handiest supply Spanish translations (Determine 7). That very same research printed {that a} majority of states supply normal details about cheap changes and teletypewriter (TTY) numbers on or inside of one click on in their homepage or on-line utility touchdown web page, however fewer states supply data on find out how to get entry to packages in massive print or Braille or find out how to get entry to American Signal Language interpreters.

Older adults can also be at upper possibility of shedding protection all through the unwinding duration. Early findings from a survey of medical insurance shoppers discovered that two-thirds of older Medicaid enrollees reported they’d no longer in the past participated in a renewal in their Medicaid protection (Determine 8). Enrollees who should not have enjoy actively renewing Medicaid protection is also much less ready for what to anticipate when their eligibility is redetermined within the coming months, lessening their skill to navigate and whole the renewal procedure. Moreover, just about part of older Medicaid enrollees supplied up to date touch data to the state Medicaid company in comparison to only a 3rd of Medicaid enrollees general.

CMS guidance in regards to the unwinding of the continual enrollment provision stresses the significance of accomplishing outreach to enrollees to replace touch data and offers methods for partnering with different organizations to extend the chance that enrollee addresses and get in touch with numbers are up to the moment. CMS guidance additionally outlines particular steps states can take, together with making sure accessibility of paperwork and notices for other folks with LEP and other folks with disabilities and reviewing communications methods to make sure accessibility of data. Making sure accessibility of data, paperwork, and help shall be key for fighting protection losses and gaps amongst those folks.
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8. States can spouse with MCOs, network well being facilities, and different companions to behavior outreach.

States can collaborate with well being plans and network organizations to behavior outreach to enrollees in regards to the want to whole their annual renewal all through the unwinding duration. CMS has issued particular guidance permitting states to allow MCOs to replace enrollee touch data and facilitate persevered enrollment. In keeping with a survey of non-profit, protection internet well being plans that take part in Medicaid, a majority of responding MCOs reported that they’re sending up to date member touch data to their state. Moreover, nearly two-thirds of states (33) are making plans to ship MCOs advance lists of contributors for whom the state is beginning the renewal procedure and about part will ship lists of contributors who’ve no longer submitted renewal paperwork and are prone to shedding protection or who’ve been disenrolled indicating whether or not the member was once made up our minds not eligible or disenrolled for forms causes (Determine 9).

States too can paintings with network well being facilities, navigators and different assister systems, and community-based organizations to supply data to enrollees and lend a hand them with updating touch data, finishing the Medicaid renewal procedure, and transitioning to different protection if they’re not eligible. A survey of health centers carried out in overdue 2021 discovered that almost 50% of responding well being facilities reported they’ve or plan to succeed in out to their Medicaid sufferers with reminders to resume their protection and to agenda appointments to lend a hand them with renewing protection. In a similar fashion, a survey of Marketplace assister programs discovered that assister systems have been making plans quite a lot of outreach efforts, similar to public training occasions and focused outreach in low-income communities, to boost shopper consciousness in regards to the finish of the continual enrollment provision. Moreover, just about six in ten assister systems mentioned they’d proactively reached out to their state to discover techniques to assist shoppers; supported the state sharing touch data with them on people who want to renew their Medicaid protection; and have been making plans to recontact Medicaid purchasers to replace their touch data. Connecting Medicaid enrollees with assister systems may assist other folks navigate the renewal procedure; a big majority of Medicaid enrollees say having a state skilled assist them with the method of renewing their Medicaid protection and searching for different protection, if wanted, could be helpful.
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9. Well timed information on disenrollments and different metrics shall be helpful for tracking how the unwinding is continuing.

As a part of a vast set of unwinding reporting necessities, states supplied baseline data at the beginning of the unwinding duration after which will publish per 30 days studies that shall be used to observe unwinding metrics via June 2024 (Determine 10). In the course of the per 30 days studies, states are reporting general renewals due within the reporting month, the collection of enrollees whose protection was once renewed, together with by way of ex parte processes, the collection of enrollees who have been made up our minds ineligible and disenrolled, the collection of enrollees disenrolled for procedural causes, and the collection of renewals that stay pending.

The  Consolidated Appropriations Act integrated further reporting necessities for states and calls for that CMS make the knowledge reported by means of states publicly to be had (Determine 10). The law additionally imposes consequences within the type of diminished federal matching bills for states that don’t conform to the reporting necessities. States that don’t record the desired information face a discount in federal scientific help share (FMAP) of as much as one share level for the quarter by which the necessities don’t seem to be met. If CMS determines a state is out of compliance with any appropriate redetermination and reporting necessities, it could require the state to publish a corrective motion plan and will require the state to droop all or some terminations for procedural causes till the state takes suitable corrective motion.

Jointly, those metrics are designed to exhibit states’ growth in opposition to restoring well timed utility processing and beginning and finishing renewals of eligibility for all Medicaid and CHIP enrollees and will lend a hand with tracking the unwinding procedure to spot issues as they happen. Alternatively, whilst the brand new information reporting necessities are helpful, they are going to no longer supply a whole image of ways the unwinding is continuing and whether or not positive teams face limitations to keeping up protection. To totally assess the affect of the unwinding would require broader consequence measures, similar to continuity of protection throughout Medicaid, CHIP, Market, and employer protection, gaps in protection through the years, and will increase within the collection of the uninsured, information that may not be to be had within the non permanent.

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10. The collection of other folks with out medical insurance may building up if individuals who lose Medicaid protection are not able to transition to different protection.

The proportion of people that lack medical insurance protection dropped to 8.6% in 2021, matching the ancient low in 2016, in large part on account of will increase in Medicaid protection, and to a lesser extent, will increase in Market protection. Alternatively, as states resume Medicaid disenrollments, those protection good points usually are reversed. The Congressional Finances Workplace (CBO) projects that 6.2 million people who find themselves disenrolled from Medicaid over the following 18 months will change into uninsured, and that the uninsured fee will building up to ten.1% by means of 2033. CMS steerage supplies a roadmap for states to streamline processes and enforce different methods to scale back the quantity of people that lose protection even if they continue to be eligible. Alternatively, there can also be present enrollees who’re made up our minds to be not be eligible for Medicaid, however who is also eligible for ACA market or different protection. A MACPAC analysis tested protection transitions for adults and youngsters who have been disenrolled from Medicaid or separate CHIP (S-CHIP) and located that only a few adults or kids transitioned to federal Market protection, handiest 21% of kids transitioned from Medicaid to S-CHIP, whilst 47% of kids transitioned from S-CHIP to Medicaid (Determine 11).

A KFF research printed that amongst other folks disenrolling from Medicaid, more or less two-thirds (65%) had a duration of uninsurance within the 12 months following disenrollment, and handiest 26% enrolled in every other supply of protection for the total 12 months following disenrollment (Determine 12). In combination, those findings counsel that folks face limitations shifting from Medicaid to different protection systems, together with S-CHIP. Simplifying the ones transitions to scale back the limitations other folks face may assist be sure people who find themselves not eligible for Medicaid don’t change into uninsured. Importantly, those findings additionally display that giant stocks of enrollees (41% within the KFF research) reenroll in Medicaid after a time frame, and plenty of after a duration of uninsurance. Lowering the quantity of people that lose protection for procedural causes even if they continue to be eligible too can assist to scale back the quantity of people that change into uninsured

The proposed eligibility and enrollment rule goals to clean transitions between Medicaid and CHIP by means of requiring the systems to simply accept eligibility determinations from the opposite program, to broaden procedures for electronically shifting account data, and to supply mixed notices. States too can imagine sharing data on shoppers shedding Medicaid who is also eligible for Market protection with Market assister systems; on the other hand, in a 2022 survey, few assister systems (29%) anticipated states to supply this data even though just about part have been undecided in their state’s plans.


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