In last week’s Unwinding Wednesday blog, my colleague Allie Gardner noted that CMS is requiring states to provide supplemental data for monitoring the unwinding of the Medicaid continuous coverage protection. These data are in addition to the performance indicator data that states have been required to submit monthly since 2013. But … the supplemental data being reported are not unique to the unwinding; they go beyond the current performance indicators in understanding renewal outcomes and assessing how well the state is staying on top of the workload by tracking pending applications, renewals, and fair hearings. CMS should add the data required in the unwinding reports to the performance indicators now so that states continue to report them after they return to routine operations.
This isn’t the first time I’ve urged CMS to expand the performance indicator data. Back in 2013, the agency indicated that the initial set of indicators was just Phase I. What was clearly missing is data on transitions across Medicaid, CHIP and the Marketplace, as well as ineligibility and disenrollment “reason” codes that would get at the number of people denied or disenrolled for procedural (non-eligibility) reasons. Detailed denial and disenrollment codes would also be helpful in identifying strategies to avoid procedural disenrollments. For example, addressing coverage loss due to returned mail requires different strategies than disenrollment due to nonpayment of premium, and voluntary disenrollment requires no follow-up strategy at all.
I know how useful additional data can be. When I was the New Hampshire CHIP Director, my organization managed the consumer assistance hub for Medicaid and CHIP way back when mail-in applications were an advancement over applying in-person. We tracked which documents were missing (i.e., income, citizenship, etc.) to help better understand how we could assist families in completing the application process. We tracked how many applications were received incomplete and required follow-up and the average number of times we reached out to gather missing documents. We tracked transitions between Medicaid and CHIP, and more. Based on that experience, one of the first briefs I wrote after joining CCF in 2008 was entitled “Data Reporting to Assess Enrollment and Retention in Medicaid and CHIP.”
The initial set of performance indicators was a good start and, as noted above, CMS clearly intended to add additional metrics to the list. Yet, here we are nearly a decade later, without more robust data reporting requirements, not to mention that many of the performance indicators have never been publicly reported. This is why CMS needed to take the step to require states to report the supplemental data. Some of the performance indicators, including call center statistics and enrollment, are helpful but they are woefully inadequate in monitoring the unwinding of the Medicaid continuous coverage protection.
Bottom line: the supplemental data should not be limited to the unique circumstances of lifting the Medicaid continuous coverage protection. If the data are helpful in monitoring the impact of the unwinding and assessing state workloads and timeliness, they will certainly be useful in assessing enrollment and retention on an ongoing basis.
[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.]