Kudos to CMS for prompt posting of key dates that states are initiating action as we approach the end of Medicaid continuous eligibility on March 31, 2023. Keep in mind that these dates are “anticipated,” and the document bears a specific date; as such, the list will likely be updated if timelines shift. So, what do these dates mean at the operational level?
Anticipated First Month State Unwinding-Related Renewals Are Initiated
There’s an important distinction in how CMS labeled the first month states will initiate the unwinding by describing renewals as “unwinding-related.” Generally, unwinding-related renewals would consist of renewals and changes in circumstances that have been pending for more than a year. Most states continued to process ex parte renewals during the public health emergency (PHE) which means some share of enrollees have been renewed over the past three years. As a refresher, ex parte renewal processes – also known as automated or administrative renewals – use reliable data sources to determine ongoing eligibility before requiring the enrollee to return a form or respond to a request for information.
Effective Date of First Anticipated Terminations for Procedural Disenrollments
States have renewal processing cycles ranging from 60 to 90 days, starting with initiating the ex parte process and sending notices for those who were renewed automatically. Next, states are required to send prepopulated renewal forms to enrollees that they are unable to renew on an ex parte basis and enrollees must be given at least 30 days to respond. Some states allow more than 30 days for a response and some states send reminders to individuals who must take action to retain coverage. Finally, for individuals who are determined ineligible or did not provide needed information, states must send a notice of termination at least 10 days in advance. This process accounts for the two- to three-month lag between when unwinding-related renewals are initiated and the first date of termination. Longer renewal cycles give enrollees more time to submit needed renewal information and states more time to process information received. And if you read between the lines, that first month of termination is specific to procedural disenrollments – meaning that ineligible individuals may lose coverage sooner (but not before April 1, 2023).
States with lower ex parte rates will have a larger volume of “unwinding-related” renewals. States with higher shares of ex parte renewals will have a lower volume of renewals that will require reviewing forms and manual processing of paper documentation. If the workload becomes unmanageable, there is a greater chance for lost paperwork and manual processing errors, leading to more inappropriate terminations.
States with higher staff vacancy rates will find it more difficult to manage the volume of “unwinding-related” renewals. States have acknowledged challenges in retaining, recruiting, and training eligibility and call center staffing. Those with more significant worker shortages and larger “unwinding-related” renewals will find it more difficult to manage the workload and may fall short of providing prompt assistance to enrollees who have questions or are confused about what they need to do to retain coverage.
There are other elements that impact state capacity to stay on top of the unwinding. Are notices and communications clear? Has the state engaged MCOs and other stakeholders? Is the state being transparent about its approach and timeline? Are call center wait times reasonable? Is the state already finding it difficult to process new applications on a timely basis?
State-level data transparency will be critical for stakeholders to monitor the impact of the unwinding. And although the Consolidated Appropriations Act requires CMS to post key unwinding data, it’s unclear how quickly those data will be posted. Let’s hope the public release of key monitoring data will be as timely as CMS’ release of state renewal timelines. But in the meantime, we continue to monitor state websites for posted data that we’ll add to the 50-state unwinding tracker. States that started unwinding-related renewals in February were required to submit their baseline data on February 8th and must submit monthly updates on the 8th of the month going forward. Hats off to Arkansas, Ohio, and West Virginia, three of the eight states that have already begun the unwinding process, for posting their baseline renewal data reports.
[Editor’s Note: For more information, visit our Medicaid continuous coverage unwinding resource page where you’ll find other blogs in this series, reports, webinars and the 50-state tracker.]