Although ex parte was hardly a household term before the unwinding of the Medicaid continuous enrollment requirement, most stakeholders and observers are now aware of the critical role automating renewals using data available to the state can play in reducing churn and promoting continuity of coverage in Medicaid and CHIP. The policy not only removes red tape barriers to enrollment and reduces churn, but it is also an efficient, accurate, and administratively cost-effective process for states. Thanks to Congressionally-mandated public reporting requirements in the Consolidated Appropriations Act of 2022, we can see how states compare but also what progress, if any, they are making in improving ex parte renewal outcomes.
CCF has been tracking state renewal outcomes and Medicaid and CHIP enrollment data during the unwinding. For this analysis, we compared states’ ex parte rates from their first month of the unwinding to the most recent reported data to identify any progress being made, particularly considering the intensive technical assistance provided by CMS and its technical partners, as well as public pressure for states to step up their game. Here’s what we found.
Forty-two (42) states have experienced increased rates of successful ex parte renewals – ranging from 1 to 73 percentage points – since initiating their first month of unwinding renewals. Almost half of the states (23) have seen double-digit percentage point increases. In fact, nine states have improved their ex parte renewal rates by 30 percentage points or more. Keep in mind, an ex parte renewal is successful when the state agency can verify ongoing eligibility at renewal using reliable data available to the state without requiring the enrollee to complete a form or submit documentation. Sadly, nine states have not shown improvement; in fact, their ex parte rates have slipped. The ex parte rate could decline over time depending on how states sequence renewals and whether flaws are discovered in their ex parte processes. For example, if renewals for likely eligible people are prioritized (which is generally not the case), the state would have a better ex parte rate early on that might decline over time.
This map shows the percentage point change from the ex parte rate reported from each state’s first month of the unwinding to the most recent.
While the percentage point change map above shows the change in rates over time, the most current month’s results are even more encouraging. Nineteen states reported ex parte rates greater than 50%, compared to the national average of 37%. But there can be anomalies in the data. For example, South Carolina had an ex parte rate of 82% in November but that’s because they targeted a group of MAGI renewals for people that data indicated were still likely eligible for coverage. On the other hand, you can see notable gains when states implement improvements. For example, California’s ex parte rate jumped from 36% in November to 66% in December after automating several of the flexibilities CMS has offered states through the Section 1902(e)14(A) waiver process.
Ex parte had been a longstanding requirement in Medicaid requiring states to examine available data sources for evidence of eligibility, but only as a last step before terminating coverage. That all changed with implementation of the Affordable Care Act’s streamlining policies requiring states to conduct ex parte reviews as a first step in the renewal process. Still, over the past decade, many states made little progress in automatically redetermining eligibility at renewal using reliable data from sources such as the Social Security Administration, state quarterly wage reports, unemployment compensation databases, and other trusted sources of data.
There are a variety of actions states can take to improve ex parte rates. A key strategy for states is to increase the number and sources of data it uses to increase the share of automated renewals. States can and are doing more. While it takes considerable time and effort to pinpoint when and why data matches are unsuccessful, this effort is critical to identifying areas for system tweaks that can increase ex parte rates. Other actions include changing the order or hierarchy of which data sources are used, revising rules about the age of data used, and asking enrollees to update income information so reasonable compatibility can be applied. CMS has also provided a variety of flexibilities via Section 1902(e)(14)(A) waivers – including those California implemented – to boost ex parte rates.
Altogether, the improvement in ex parte rates is very good news, particularly if some of the flexibilities that have been offered to states during the unwinding can be made permanent options. CMS and states should take to heart the lessons learned during the unwinding and strive to continue to make improvements to ex parte rates by better harnessing technology to improve Medicaid operational effectiveness and efficiency.
