Next week, the continuous enrollment will expire and as a result, some families may lose coverage as soon as April 1. As states undergo final preparations for the unwinding to officially begin, state renewal reports are an important resource for stakeholders to prepare and help monitor the unwinding process.
We covered the basics of the state renewal reports last month when states were required to submit them to the Centers for Medicare and Medicaid Services (CMS). At the time, Tricia Brooks noted the importance of the renewal plans being released publicly, especially for transparency and accountability. Now, just over a month later, half of states’ renewal reports (26) have been published by the state or accessed through public records pathways, all of which are available on our 50-state unwinding tracker.
In reviewing available renewal reports, there are some common themes across states’ plans.
States are taking three main approaches to prioritizing renewals. The first approach is the most straightforward – keeping current renewal dates for all enrollees. This ensures a balanced distribution of renewals over the unwinding period as well as for future years. Second, some states are targeting particular groups of individuals for renewals first, like those identified as potentially ineligible as the state processed renewals while the continuous enrollment protection was in place. The states using this strategy to prioritize renewals mostly indicate a larger percentage of renewals being initiated in some months than others. For example, South Carolina and Montana, both of which plan to focus first on individuals previously determined to be likely no longer eligible, estimate between 12 to 15 percent of total renewals will be initiated within the first few months while 7 percent or less of renewals will be initiated in later months. Finally, about a third of the states with a renewal report available are doing a mixed approach where they are mostly keeping existing renewal dates, but they may be prioritizing (or deprioritizing) certain populations. In West Virginia, pregnant people or those in a postpartum coverage period will be among the last to have their eligibility redetermined.
A variety of approaches are being taken to manage workloads and address staff capacity. The recently published KFF/CCF 50-state survey showed that states are facing significant vacancy rates for both eligibility and call center staff. In their renewal reports, several states (9) identified specific actions being taken to address staff shortages like increasing call center capacity, providing worker trainings for new and existing staff, and using vendors or contracts to provide workforce support. Missouri is using a vendor to assist in data entry for prepopulated forms and returned mail as well as has plans to utilize software to translate completed documents (including handwritten ones) into the eligibility system. States have also taken steps to improve ex parte, or passive, renewal rates which can help reduce the administrative burden on staff in addition to enrollees. The state renewal report template identifies two strategies for improving ex parte rates, expanding data sources used or renewal and creating a data source hierarchy, but some states have also detailed additional actions to increase successful ex parte renewals.
While the majority of states have adopted (or plan to adopt) mechanisms to identify when large numbers of procedural disenrollments occur, few indicate they will put a “circuit breaker” in place when this problem is identified. In the renewal report template, states can select whether they are adopting or planning/considering adopting mechanisms to enhance oversight of unwinding-related operations. These include developing monitoring dashboards, implementing “early warning” or system triggers that identify when large numbers of procedural disenrollment have or will occur, and creating a “circuit breaker” flag for states to pause and consider mitigation strategies for inappropriate coverage losses. Of the 26 states with available renewal reports, only eight states noted they have or plan to adopt both “early warning” and “circuit breaker” system flags. Another twelve states are considering or have adopted one or the other (11 of the 12 plan to implement an early warning, but no circuit breaker), while five states and the District of Columbia indicated no plans to do either. The more strategies states have in place before the unwinding to identify when things start to go wrong, the greater ability they will have to rapidly respond and make mid-course corrections when issues arise.
Some states have developed innovative policies and practices to prepare for a smooth unwinding process. Kansas, for example, uses barcodes on renewal forms to help maintain coverage when a renewal form is received until the eligibility determination is completed. In California, where renewals are processed by county workers, the state requires county offices (58!) to complete an unwinding readiness plan which includes information about staff workload and training. Providers in Tennessee will have access to patients’ renewal dates so they can alert enrollees during visits about upcoming renewals. And Ohio and Montana are using vendors to help maximize renewal rates and improve staff capacity.
We are encouraged to see so many states make their renewal reports publicly available, which provide great insight into what states are planning and can help stakeholders identify areas where problems may arise. If your state has already posted a renewal report, make sure to read through it to gain a better understanding of your state’s plans and where you may be able to provide support. And if your state hasn’t posted its report yet, there is still time!