As we prepare for the eventual end of the Medicaid continuous coverage protection, a key focus here at CCF has been on monitoring the unwinding process. In last week’s Unwinding Wednesday, my colleague Tricia Brooks highlighted data such as the Medicaid and CHIP performance indicator (PI) data that can be useful in monitoring the unwinding. Another source that will be essential in monitoring the impact of the end of Medicaid continuous coverage protection is the supplemental unwinding data, which states are required to submit to CMS. (Well, that is, if the data is publicly released.)
CMS announced specific supplemental data reporting requirements for states during their unwinding process as part of its March 2022 guidance, where states must submit data reports on pending applications trends, renewal outcomes, and several other key metrics, beyond the required performance indicators. These reports – one baseline report and subsequent monthly reports – are intended to help CMS monitor states progress in resuming routine operations after the public health emergency ends as well as potential problems like high numbers of procedural disenrollments.
States must complete two types of reports: 1) an initial report with baseline data submitted at the end of the month prior to the month the state’s unwinding period begins; and 2) a monthly report submitted on the 8th of each month, for a minimum of 18 months. As a reminder, states can initiate renewals to begin their unwinding period by initiating renewals up to two months prior to the end of the PHE, but no one can be disenrolled until the first day of the month after the PHE ends.
A state’s baseline report must detail the number of days in a state’s renewal process and include the following data:
- Total number of pending applications, broken out by disability-related applications and MAGI and other non-disability applications
- Total enrollment including those receiving both full or limited benefits
- Total number of fair hearings overdue (pending more than 90 days)
The data points included in the baseline report are also required in the monthly reports. Additionally, the monthly reports must contain:
- Of the total pending applications at the beginning of the unwinding, the number of applications completed during the reporting period and the number of applications still pending
- Number of enrollees successfully renewed during reporting period, broken down by renewals completed on an ex parte basis and renewals completed using a renewal form
- Renewal outcomes, broken down by the number of enrollees determined ineligible and those disenrolled for procedural reasons
- Number of renewals initiated during reporting period and number still pending
The data in the baseline report is intended to give CMS a picture of a state’s “starting place” which can help identify where the state may be falling behind or where issues are arising based on the data provided in the monthly reports. I was pleased when the guidance and separate, detailed specifications guidelines were released by the data elements that CMS was requiring for states. Many of the metrics are those we see as key to monitoring the unwinding, such as total pending applications, which can indicate when staff is getting overwhelmed, and the number of procedural disenrollments, where an individual is not determined ineligible but is terminated for administrative reasons.
But the usefulness of these supplemental data reports for monitoring purposes will depend on two things. The first is whether or not the state actually reports all of the required data to CMS. You might ask: if the data is required how could a state not report it? Well, states will have the option to indicate “unable to report” for any of the required metrics. And while states must provide an explanation as to why they cannot submit a particular data element, this creates a potential out for any state that simply indicates it’s too difficult to report the data. Without all of the reports’ data points, we may not be able to assess the impact of the unwinding in time to recommend mid-course corrections if large numbers of eligible children and others are losing coverage for procedural reasons.
Even if states report the data, there remains the question as to whether the supplemental data will be publicly available. Since first expressing our concerns about public reporting, CMS has indicated, on more than one occasion, that the agency will NOT be posting the state-reported data. As a result, we will have to rely on states to release their own reports to be able to monitor the unwinding.
We have not heard yet of any state that plans to publish all of the key performance indicators and the supplemental unwinding data, so it will be up to advocates and other stakeholders to urge their states to share all of its data. The supplemental unwinding reports, combined with key performance indicators, contain metrics that will be critical to understanding the scope of states’ progress, or problems, in their unwinding process and help identify where corrective action may be needed to mitigate unnecessary coverage loss.
[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.]