CMS Asks States and Stakeholders to Lean In and Help Respond to Mounting Concerns About Eligible Children, New Moms and Others Losing Medicaid During Unwinding

As outcomes data has emerged from states getting an early start on resuming Medicaid renewals, there are mounting concerns about eligible children, new moms, and others losing coverage due to procedural disenrollments. In response, CMS released additional information on the unwinding, including a letter from HHS Secretary Becerra to governors urging them to adopt additional flexibilities available to states to minimize the number of Medicaid enrollees losing coverage inappropriately during the unwinding. “I am deeply concerned with the number of people unnecessarily losing coverage, especially those who appear to have lost coverage for avoidable reasons that state Medicaid offices have the power to prevent or mitigate,” Becerra wrote to governors.

The letter was sent in conjunction with the announcement of additional flexibilities available to states to engage partners and give states an extra month to conduct additional outreach to enrollees when information is needed to avoid a loss of coverage. CMS also released a summary of available state strategies to minimize terminations for procedural reasons. The new flexibilities include:

  • Allowing managed care plans to assist people with Medicaid with completing their renewal forms, including completing certain parts of the renewal forms on their behalf.
  • Allowing states to delay an administrative termination for one month while the state conducts additional targeted outreach. This will give people more time to be reminded to fill out and return their renewal forms.
  • Allowing pharmacies and community-based organizations to facilitate reinstatement of coverage for those who were recently disenrolled for procedural reasons based on presumptive eligibility criteria.

In a new fact sheet, CMS also provided background on the unwinding for potential partners who are not in the thick of it. In an accompanying call-to-action, CMS outlined ways that community partners can help keep kids and families connected to coverage.

The agency also has produced two postcards (here and here) focused on keeping kids covered. Each post card is available in English and Spanish and can be customized with organization logos. The focus on children is also evident in the Secretary’s communications to governors and we are happy to see messaging to parents that points out that children may be eligible even if the parent is not – we have been urging this message for some time. However, this is not the only reason children are going to lose coverage inappropriately; there are many children enrolled in Medicaid whose parents are uninsured or covered by other sources. Ultimately states must work hard with family facing systems and partners to insure that children remain covered, and the Secretary will have to use his enforcement authority where necessary if inappropriate terminations are happening. The Secretary’s letter states:

As you know, states must comply with federal rules regarding how they conduct Medicaid and CHIP renewals, and individuals must be afforded the due process to which they are entitled in order for states to continue to receive enhanced federal funding.  We take our oversight responsibilities extremely seriously, and while we know that states are working hard to meet the federal requirements, we will not hesitate to use the compliance authority provided by Congress, including requesting that states pause procedural terminations under conditions outlined by the Consolidated Appropriations Act, 2023, should it be needed[1].

The agency also promoted its 6, 15, and 30-second You Tube videos with the message “Don’t Wait! Update! Get Ready to Renew Your Medicaid or CHIP Coverage.” While these videos cannot be used for PSAs (not sure why), they are available for other public uses. Links to the videos can be found here.

We appreciate efforts by HHS and CMS to engage more partners, offer more flexibilities to states, and provide additional tools and resources. States must take them up, however, to avoid the worst outcomes. At the end of the unwinding, none of us wants to say “I wish I had done more.” Too much is at stake, including health coverage for more than half of the nation’s children.

[Editor’s Note: This is the 36th blog in the Unwinding Wednesday series. 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.