Unwinding Wednesday #5: Application Processing Times Provide Insight into State Capacity to Manage the Medicaid Workload

In last month’s Unwinding Webinar Part 9, we covered the performance indicator and supplemental unwinding data that will be helpful in monitoring the impact of unwinding the Medicaid continuous coverage protection at the end of the public health emergency (PHE). I often talk about call center statistics being the canary in the coal mine. But there’s another indicator that can give us insight into state capacity – application processing times. If states are struggling to meet the application timeliness standards now, you can anticipate that things will only get worse when they begin to return to routine operations at the end of the PHE.

So, what do we know about application processing times? First, by regulation, states have 45 days to process MAGI applications (children, pregnant people, families and adults) and 90 days to process non-MAGI applications (people with disabilities and seniors dually eligible for Medicaid and Medicare). States are required to report the timeliness of MAGI application processing based on these timeframes: less than 24 hours, 1 to 7 days, 8 to 30 days, 31 to 45 days, and over 45 days. Reporting on non-MAGI applications falls into four buckets: less than 30 days, 31 to 60 days, 61 to 90 days, and over. These data are part of the Medicaid and CHIP performance indicators, covering more than 80 data points in 11 topic areas that states have been required to report since 2014. They provide insights into state workloads, including data on applications, account transfers, renewals due, and pending applications or determinations.

In 2018, CMS published the first annual three-month snapshot of state-level MAGI application timeliness. The first five annual reports covered application processing times in February through April. The most recent report (2022) switched to January through March reporting, and indicated that CMS will begin to report these data on a quarterly basis. Yet, as we know with other application and enrollment data, there is generally a lag before data is posted. The report for January through March 2022 was released on September 1, 2022. As of yet, data on non-MAGI application processing times have not been publicly reported.

Despite the data reporting lag, application processing times provide a sense of how well states are staying on top of their workload. In the first quarter of 2022, 15 states (AK, AR, CA, DC, FL, HI, MS, MO, MT, ND, OH, SC, TX, VA and WY) had at least one month where at least 15 percent of MAGI applications did not meet the 45-day timeliness standard. At the top of that list are Arkansas and Missouri, states where delays in processing Medicaid applications have garnered media attention. Arkansas data reflected a three-month average during which 78 percent of MAGI applications were beyond 45 days. Likewise, in Missouri, which adopted the Medicaid expansion in July 2021, a three-month average of 82 percent of applications took longer than 45 days to process. Conversely, nearly half of the states had low three-month average processing times over 45 days – less than 5 percent –  including seven states (CT, DE, MD, MN, NY, OK and OR) with 100 percent of applications processed in a timely manner.

The MAGI processing time report also provides insight into how well states use data sources to verify eligibility at application, which can also be an indicator of state success in processing ex parte or automated renewals. The report shows that nine states (AL, CT, DC, MD, MA, NY, OK, OR and WA) were processing at least 75 percent of applications, on average, in less than 24 hours.

Given that CMS reports limited performance indicator data, often with a lag, and has indicated that it does not plan to publicly report the supplemental data states are required to report for the unwinding, stakeholders need to use all of the data and intel from the field and in the media to monitor the unwinding. Knowing where your state stands on application processing times is just one more piece of the puzzle in assessing your state’s readiness for the unwinding.

[Editor’s Note: For more information, visit our PHE Unwinding resource page where you’ll find other blogs in this series, reports, and the 50-state tracker.]