Unwinding Wednesday #19: What Can Application Processing Times Tell Us About State Readiness for the Unwinding?




In the past, I’ve blogged a lot about the Medicaid and CHIP performance indicators that states have been required to report since 2014. Among those indicators, states must report the share of MAGI-based (i.e., non-disabled, non-elderly Medicaid groups) applications completed in five buckets: less than 24 hours (also known as real-time determination), 1 – 7 days; 8 – 30 days; 31 – 45 days; and over 45 days. These data can provide insight into how well state systems are performing when accessing data to automatically determine eligibility at application, as well as pinpoint states that are struggling to complete applications within the 45-day timeliness standard.

As background, CMS reported state-level application processing times for one 3-month period each year (February – April) from 2018 through 2021. In 2022, CMS switched the period to the first quarter (January – March) and indicated the agency’s intent to publish these data on a quarterly basis going forward. So far, CMS has released data for the first two quarters of 2022. From those data, we calculated the average processing times for three quarters: February – April 2021; January – March 2022; and April – June 2022. In this 50-state table, we show the quarterly average processing time.

All states show at least a small percentage of MAGI-based applications completed in real-time. But states with very low shares generally report that these occur when an individual applies in person and has all documentation needed to verify eligibility. In those cases, eligibility workers can confirm eligibility immediately. Higher shares of real-time completion rates reflect state systems that can efficiently and accurately verify eligibility by accessing multiple electronic data sources to automate the determination process.

Since the eligibility system makes determinations at application and at renewal, states that have high rates of real-time eligibility determinations also tend to have higher shares of ex parte renewals. In those states, it is likely we will see lower shares of enrollees losing coverage due to administrative barriers and paperwork snafus. For the second quarter of 2022, 13 states report completing renewals for at least half of MAGI-based applications in less than 24 hours, including Alabama, Connecticut, District of Columbia, Kentucky, Maryland, Massachusetts, Minnesota, New York, Oklahoma, Oregon, Rhode Island, and Washington.


On the other end of the spectrum, higher shares of MAGI-based applications that take more than 45 days to complete are an indication of states where staff capacity is not sufficient to process applications on a timely basis. If states are already backlogged with application processing, it doesn’t bode well for what will happen when these states start processing renewals during the unwinding.

Thirteen states reported in the second quarter of 2022 that 10 percent or more of MAGI-based applications are completed beyond the standard 45-day processing window, including Alaska, Arkansas, California, Maine, Mississippi, Missouri, Montana, North Dakota, Ohio, South Carolina, Texas, Virginia, and Wyoming. Generally, these states have lower shares of applications processed in real time.

In the 2022 50-State Survey on Medicaid and CHIP Eligibility and Enrollment Policies (table 10) that the Kaiser Family Foundation conducts in partnership with CCF, states reported the share of ex parte renewals. Since then, we know that a number of states have taken steps to increase the share of renewals conducted automatically via ex parte, including expanding data sources and enhancing the system’s data matching rules. Stay tuned for updated information from states when the 2023 Survey Report is released in March.

As we approach the unwinding of the Medicaid continuous enrollment requirement, we know that outcomes will vary dramatically from state to state depending on state systems, policies, and practices. While CMS has stretched to provide states with an abundance of guidance, best practices, and flexibilities to smooth the unwinding, not all states have developed high-performing systems that rely on efficient and accurate data-driven determinations to streamline the application and renewal processes. But even in states that continue to rely on paper-driven processes, millions of eligible children and low-income families and adults don’t have to become uninsured if states take the time to get it right and are willing to hit the pause button to avoid inappropriate terminations of eligibility.

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

Tricia Brooks is a Research Professor at the Center for Children and Families (CCF), part of the McCourt School of Public Policy at Georgetown University.