The Unwinding: It’s Not Over Until It’s Over

Recently, the Centers for Medicare & Medicaid Services (CMS) put out a list of the estimated month in which states will finish processing renewals for individuals who were covered when the pandemic-era Medicaid continuous enrollment requirement was lifted and had not been renewed in the past year. While originally it was expected that all states would be done by June 2024, that timeline has been pushed out for 11 states. Five of those states (IL, KY, MI, NJ, WI) are expected to be done in July; HI and SC in August; NC in November; and AK and DC in 2025; (NY is TBD). The extended timelines help to offset pauses for system fixes or to provide more time for targeted outreach to improve renewal response.

In the meantime, CMS announced that states are expected to continue to report renewal outcomes even if they are done with the unwinding. These data have been critically important for CMS and stakeholders to monitor state performance, and we commend the agency for not only taking steps to continue data reporting but also for their plan to continue posting these data nationally.

CMS is also now posting data from state “updated” renewal reports. One of the data points is the number of renewals due that month that were pending at the end of the month. This means no determination was made on that renewal even though it was due that month. There are a couple of primary reasons so many renewals would be pended. It could be that the renewal had been received but not processed or that the state is giving the enrollee more time to respond. The updated reports show the same information as the original, but there should be a considerable drop in the number of renewals pending and an increase in one or more outcomes: determined ineligible, renewed based on return of the renewal form, or procedurally disenrolled. Generally, we would not expect to see a change in the number of renewals conducted via ex parte unless the state went back to re-run data after a system change or due to resolve a deficiency in the system.

CCF is working on updating our unwinding data tracker so stakeholders can compare how their state’s outcomes have changed and have a better sense of the final disposition of most renewals. In the past two months, CMS released two groups of updated reports with data through October 2023. Going forward, CMS will post the updated reports for four months prior to the current report. For example, when CMS releases March 2024 renewal data next week, they will post updated data for November 2023. Stay tuned next week after we return from our conference for updates!

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.