CMS Shares State Reporting Requirements on PHE Unwinding, but Will the Agency Share State Reports with the Public?

We’ve been expecting CMS to release a template for states to report key baseline and monthly data that is needed to monitor the unwinding of the Medicaid continuous coverage protection, but we got more than that with today’s release.

CMS will also require states to complete and submit a form that summarizes the state’s approach as it resumes routine Medicaid operations, including how they will distribute renewals and protect against inappropriate coverage loss during the unwinding. States will be expected to submit the report 45 days before the end of the month in which the PHE ends. The following information must be included in the state reports:

  • the number and percentage of renewals that the state intends to initiate each month during the 12-months that states have to initiate all renewals;
  • how work will be prioritized, including identifying populations that will be renewed first and specific strategies such as aligning renewals for all members of the household, aligning renewals with SNAP recertifications, and coordinating changes in circumstances with a full renewal;
  • how the state will ensure that eligible individuals retain coverage and limit coverage losses for procedural reasons;
  • the steps the state is taking to strengthen the renewal process, update mailing addresses, improve consumer outreach and assistance, improve retention and promote seamless coverage transitions, and enhance oversight of eligibility and enrollment operations, and
  • strategies the state will take to ensure the fair hearing process is timely and accessible.

I was both excited and disappointed to see the specifications for data reporting. States will be required to report baseline data for the month prior to when the state initiates renewals. After that, states must submit monthly data by the 8th of the month for the prior month.

The baseline report will include information on the number of days in the state’s renewal processing period and the following data which will also be required on a monthly basis going forward:

  • the overall number of pending applications, grouped by disability-related applications and MAGI groups with any other non-disability applications,
  • total enrollment for both full and limited benefit enrollees, and
  • the number of fair hearings pending more than 90 days.

On a monthly basis, states will also be required to report these monthly (reporting period) metrics:

  • applications completed broken down by MAGI and disability-related applications,
  • total renewals initiated for the month,
  • total enrollees due for a renewal,
  • total successfully renewed and retaining coverage, with a breakdown for the number renewed on an ex parte basis or by using a pre-populated renewal form,
  • renewal determination outcomes, with a breakdown for the number determined ineligible and those terminated for procedural reasons,
  • number of renewals outstanding and month renewal was initiated, and
  • number of fair hearings pending more than 90 days.

I was really disappointed that call center statistics were not among the required data. These statistics are an early warning sign that the system is overwhelmed with consumer questions and the need for personalized assistance. If individuals fail to get clear information on what they need to do to retain Medicaid or transition to other sources, they are more vulnerable to a disruption in coverage due to procedural reasons.

I recognize the challenges states face in reporting disaggregated data (although much work needs to be done to address that need, particularly for race/ethnicity data). But couldn’t key data be reported at least by eligibility group? It would give us a sense of which groups — children, pregnant people, parents, expansion adult, people dually eligible for Medicaid/Medicare, or people with disabilities – are affected. Data on other demographics – income, geography, age, in addition to race/ethnicity – would also be immensely helpful for targeting outreach and assistance.

On a positive note, I was pleased to see that CMS is gathering basic information on the state’s unwinding plan. The quantitative data is all useful with key breakdowns for details like the share of procedural disenrollments. Timely reporting by the 8th of the month for the preceding month sets a strong standard.

But what happens if states don’t report or say the data is not available?

It’s also unclear to what extent state plans or data will be publicly available. A diverse group of stakeholders — health care providers, managed care plans, policy and advocacy organizations, child and family service organizations, the education and early childhood communities, disability groups, and more — want to assist with outreach and communications in advance of the unwinding and help individuals understand what they need to do or how to get assistance. Knowing a state’s plan and getting timely monitoring data is essential if we are to maximize these resources to smooth out the unwinding and promote continuity of coverage.