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The Connecting to Coverage Coalition (CCC) has published a new policy paper detailing key lessons learned during the unwinding, including what tactics worked especially well, how to address historic disenrollments in the immediate aftermath, and which enrollment flexibilities provided by CMS should continue beyond this period. Executive Summary
The Connecting to Coverage Coalition (CCC) is comprised of national organizations representing a diverse collection of stakeholders committed to being a single source of trusted information about the Medicaid redetermination process. The CCC convenes stakeholders to support information sharing, share and build on best practices, and develop solutions to ensure Americans can enroll in the coverage option that is right for themselves and their families. By working together, the CCC helps support a smooth transition back to normal Medicaid eligibility during this unprecedented redetermination process by connecting Americans to resources and helping them either maintain Medicaid eligibility or transition to other health insurance coverage, such as Medicare, Marketplace coverage, or employer-sponsored insurance (ESI). The member organizations of the CCC are committed to working with federal and state partners and protecting against individuals becoming uninsured as a result of the “unwinding” process, especially among children and at-risk adults. During the COVID-19 public health emergency, Congress ensured that Medicaid beneficiaries would have continuous health coverage during the pandemic.[1] As a result of the continuous coverage requirement, total Medicaid enrollment grew from 71 million (as of December 2019) to approximately 94 million individuals enrolled in Medicaid and CHIP in March 2023.[2] When the COVID-19 pandemic was winding down, Congress passed the Consolidated Appropriations Act, 2023 to require states, to begin on April 1, 2023, the process over a 12-month period to return the Medicaid program to normal operations. As part of the unwinding process, state Medicaid programs have resumed verification of over 94 million individual’s continuing eligibility for Medicaid. To mitigate procedural disenrollment for eligible individuals and support state Medicaid agencies’ compliance with federal renewal requirements as they resume Medicaid redeterminations, the Centers for Medicare & Medicaid Services (CMS) offered states a range of strategies and flexibilities, including making available waivers of certain federal Medicaid requirements under the authorities provided through 1902(e)(14)(A) of the Social Security Act (SSA). To date, nearly all states have adopted at least one 1902(e)(14)(A) waiver, which include strategies to: (1) increase ex parte renewal rates; (2) support enrollees with renewal form completion and automated submission; (3) update contact information; and (4) facilitate reinstatement of coverage for eligible individuals who were disenrolled for procedural reasons.[3] The CCC appreciates the historic and unprecedented nature of Medicaid unwinding and applauds the leadership that CMS has provided to address the ongoing challenges many states face during this time. We also acknowledge and are grateful for the immense work that states and advocates have done thus far to improve the Medicaid and CHIP redetermination process. At the same time, we recognize the logistical challenges that remain which often result in loss of coverage for those who are still eligible for these programs in many areas of the country. We acknowledge that the unwinding period has caused a substantial number of disenrollments across the Medicaid population at rates worse than many expected, particularly in certain areas of the country. The Biden administration anticipated around 15 million individuals losing coverage during this period, with nearly half losing coverage despite continued eligibility.[4] However, as of June 4, 2024, reported data reveals that more than 22.8 million people have been disenrolled, with a notable 69 percent disenrolled due to procedural reasons.[5] To date, nearly 35 million Medicaid beneficiaries still have not had their redeterminations completed or reported. This high procedural disenrollment rate is concerning, especially considering that many of these individuals may still be eligible for Medicaid coverage and that it disproportionately impacts individuals from vulnerable patient populations, including communities of color, children, elderly adults, and individuals living with disabilities. We also know that maintaining continuous coverage is important to maintaining better health outcomes and reducing administrative costs for both patients and states. As state Medicaid agencies, CMS, Congress, and other stakeholders look ahead to the immediate post-Unwinding period, the coalition believes this is an apt time to evaluate lessons learned during the Unwinding, including what tactics worked especially well, how to address historic disenrollments in the immediate aftermath, and which enrollment flexibilities provided by CMS should continue beyond this period. The CCC believes that extending flexibilities to maximize ex parte renewals, continuing and expanding data collection efforts, and reducing churn by improving outreach and facilitating alignment across programs are crucial and effective strategies that should continue to be employed by states to reduce coverage gaps for eligible individuals during and beyond the unwinding period. We offer the following recommendations: Recommendation #1
[1] Families First Coronavirus Response Act (Pub. L. 116-127); CARES Act (Pub. L. 116-136) [2] https://www.medicaid.gov/sites/default/files/2023-06/march-2023-medicaid-chip-enrollment-trend-snapshot_1.pdf [3]https://www.medicaid.gov/resources-for-states/coronavirus-disease-2019-covid-19/unwinding-and-returning-regular-operations-after-covid-19/covid-19-phe-unwinding-section-1902e14a-waiver-approvals/index.html [4] https://aspe.hhs.gov/sites/default/files/documents/dc73e82abf7fc26b6a8e5cc52ae42d48/aspe-end-mcaid-continuous-coverage.pdf [5] https://www.kff.org/report-section/medicaid-enrollment-and-unwinding-tracker-overview/ Comments are closed.
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