March 31 marks the one-year anniversary of the end of the COVID-related Medicaid continuous enrollment requirement. While it was expected that renewing nearly 90 million Medicaid enrollees would be a heavy lift for states, it’s taking some states longer to complete renewals due to system changes and efforts to improve ex parte renewal rates or give enrollees additional time to respond when eligibility cannot be redetermined automatically. Today, CMS announced additional actions and posted new resources to help eligible people stay covered.
Special Enrollment Period (SEP) for Marketplace Transitions
A special enrollment period for people who are no longer eligible for Medicaid or CHIP to transition to the Marketplace has been extended through November 2024. As a general rule, individuals losing Medicaid must transition within 60 days of their disenrollment or wait until open enrollment to secure coverage through the Marketplace.
New Unwinding Guidance and Tools for States
The agency press release noted the recent guidance that CMS released in an informational bulletin (CIB) on March 15 outlining 10 “Do Nots” in processing renewals that have been reported as issues in multiple states. As outlined in this blog, the CIB and accompanying slide deck outline some of the top errors states are making in conducting renewals.
The agency pointed out that it has updated its prior guidance on how managed care organizations (MCO) may assist in submitting telephonic or electronic signatures on behalf of enrollees they assist with renewal (see slide 13). MCOs may: 1) record telephonic signatures and forward to the state, 2) coordinate a three-way call with the Medicaid agency so the enrollee can provide a telephonic signature directly to the state, and 3) collect an electronic signature that is forwarded to the state.
During the unwinding, there have been numerous reports of call centers not advising disenrollees of their fair hearing rights and directing them to file a new application. To help educate partners, CMS also released a fact sheet on Medicaid fair hearings outlining the federal rules. It reminds partners that states are required to tell people about their fair hearing rights and that anyone who disagrees with certain decisions made by the Medicaid agency has the right to request a fair hearing.
US Digital Service Assists States with Ex Parte Improvements
CMCS teamed up the US Digital Service (USDS) to conduct interviews in 20 states to assess Medicaid agencies’ implementation needs, capacity, and renewal policies. Here’s an update on their work which highlighted that ex parte renewals were inefficiently implemented across dozes of states and states wanting help to make improvements. California was one of the states that benefited from the technical assistance provided through this effort in doubling their ex parte rates as we blogged about here!
Final Eligibility and Enrollment Rule Builds on Lessons Learned During the Unwinding
And no rest for the weary! Earlier this week CMS finalized new set of eligibility and renewals regulations proposed in September 2022. As my colleague Joan Alker blogged about earlier, many of the changes will make substantial improvements to CHIP coverage by addressing outdated actions that are not allowed in Medicaid and are not common in private insurance either. But there’s a lot more to unpack in that rule. We’re working on an explainer brief that will be released soon. So, keep an eye on Say Ahhh! for that posting.
And speaking of no rest for the weary, we should acknowledge the enormous effort that CMS and HHS have undertaken to assist states and hold them accountable in ensuring that eligible kids and families stay covered during the unwinding. But we’re not done yet. Based on CMS and state reported data, about two-thirds of renewals have been completed. So, we still have a ways to go!
