The lifting of the continuous enrollment requirement associated with the COVID-19 public health emergency (PHE) is inevitable, whether it be after the PHE ends or on April 1, 2022 as proposed in the Build Back Better (BBB) Act passed by the House. Regardless of what happens, millions of enrollees are likely to be disenrolled from Medicaid; but not all who lose coverage will be ineligible. While states have been required for many years to submit an extensive list of performance indicator data, very few of these data have been publicly reported by CMS.

To enable CMS and stakeholders to monitor the “unwinding” of the continuous enrollment requirement, a few key data points that states should already be collecting and reporting are essential.

Call center statistics are the canary in the coal mine and should be monitored weekly. Call center statistics provide an early warning system that consumers who need help to understand what they must do to retain coverage are having difficulty in getting that help. As call volume goes up, so do call wait times. And as call wait times increase, the abandonment rate increases. If phone systems encounter technical difficulties due to call volume or enrollees have limited cell minutes or need to return to work and can’t hold, the call is abandoned. Most phone systems that support call center operations have the ability to track these data embedded within the system.

Reporting the share of disenrollments for procedural reasons is needed to assess how many enrollees may be at risk for becoming uninsured. Historically, a significant share of Medicaid enrollees lose coverage for procedural reasons – that is – they never receive the notice and don’t respond; they don’t understand what they need to do to retain coverage; or they are unable to provide needed documentation within specific timelines.

Timely reporting of these data is critical in order to hit the pause button when large numbers of individuals cannot access consumer assistance or are being disenrolled for reasons other than eligibility. The importance of frequent and prompt reporting of these data cannot be overstated. If large numbers of individuals are unable to get the assistance they need or are losing coverage for reasons other than eligibility, states need to slow down the process and assess what additional steps they can and should take to ensure that eligible enrollees are able to maintain coverage. These steps vary by state, depending on state capacity, processes and systems. For example, if call centers and eligibility workers are overwhelmed, states can reduce the volume of renewals being processed until things settle down to a more manageable level. If large numbers of individuals are losing coverage for procedural reasons, the state can boost its efforts to remind enrollees of the need to take action and provide help in renewing coverage.

Even though BBB would reinforce the requirement for states to report these key monitoring data, the bill is currently written without standards for timely reporting or a requirement for public reporting of the data by CMS. Reporting of state-level application and enrollment data by CMS currently has a six-month lag. This is why it wasn’t until spring of 2019 that we discovered that nearly 1 million children were disenrolled from Medicaid and the child uninsured rate rose.

When states resume normal operations when the continuous enrollment requirement is lifted, we can’t wait six months to find out that millions of eligible children and low-income families have lost coverage. With no guarantee that monitoring data will be available at the federal level, stakeholders should be pressing their state to publicly report these data at the state level.