Unwinding Wednesday #20: All States Must Submit Their Medicaid Continuous Coverage Unwinding Renewal Reports by Today!


Today’s the day! All states are required to submit their state renewal reports to CMS today. States that initiated their first batch of renewals in February were expected to submit their reports on February 1. And all other states are required to submit the reports today.

What are the state renewal reports?

To better understand states’ plans to process renewals during the unwinding period, “CMS is requiring states to describe how they intend to distribute renewals as well as the processes and strategies the state is considering or has adopted to mitigate against inappropriate coverage loss during the unwinding period. CMS will use this information to identify states at greatest risk of inappropriate coverage losses and will follow up with states as needed to ensure that proper mitigations are in place to reduce risk of inappropriate terminations and that states’ plans will establish a sustainable workload in future years.”

How does the state renewal report differ from its comprehensive unwinding plan?

Back in December of 2020, CMS released guidance on the need for states to develop a comprehensive plan for unwinding the continuous enrollment requirement and other public health emergency (PHE) related actions. CMS also provided states with two planning templates: a general transition planning tool for restoring routine operations and an eligibility and enrollment pending actions resolution tool (a fancy name for many of the elements required in the renewal report). Some states have posted their comprehensive plan, but most have shared summaries or presentations. In many states, those plans have not yet been updated to reflect the date certain for lifting the continuous enrollment requirement and other requirements enacted by the Consolidated Appropriations Act (CAA). For more information on publicly available information on state websites, check out our 50-state unwinding tracker.

 What information or data are required in the renewal report?

States must report the number and percent of renewals scheduled and a brief description of prioritization and how the state plans to distribute the work over 12 months. The plan must also describe the strategies the state will take to promote retention and prevent inappropriate terminations. This aspect of the report includes information on how the state will update contact information; conduct consumer outreach, communications, and assistance; improve coverage retention; promote seamless coverage transitions; and enhance oversight of eligibility and enrollment operations. States must also indicate which strategies are utilized to ensure the fair hearing process is timely and accessible.

Why is public sharing of state renewal reports essential?

Transparency is a fundamental government responsibility that promotes accountability. Congress recognized this when it added provisions to the CAA penalizing states that do not report required data. The law also requires CMS to make state unwinding data publicly available. All states should make their renewal plans publicly available, and CMS should post all state renewal reports because not all states will choose to do so. After all, health coverage for more than 15 million people is at risk and the unwinding could have significant financial impacts on safety net health care providers. And these are public programs and stakeholders have supporting roles to play in amplifying and supplementing state actions.

What can stakeholders do?

Work with your partners to urge state leaders, legislators, and the Medicaid agency to make the renewal plan publicly available. Posting at the state level will be timelier than what we might expect of CMS. And there’s always the fallback of requesting the reports and all unwinding data via the Freedom of Information Act (FOIA).

There’s a lot of talk about transparency and accountability in government, but all too often it’s more talk than action. This is an opportunity for states and CMS to demonstrate their commitment to transparency and accountability at a critical time when health coverage is at risk for the nation’s children and low-income families, people of color, and rural communities. Yes, the unwinding is going to be messy. And yes, people are going to lose coverage inappropriately. But let’s not hide the information that stakeholders need to monitor the unwinding and do their part to help eligible enrollees retain coverage and assist those who are no longer eligible transition to other sources of coverage.

[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.