Jun, 30, 2023

Best Practices for Publicly Reporting State Unwinding Data

Elizabeth Lukanen and Emily Zylla, SHADAC

The unwinding of the Medicaid continuous coverage requirement represents the largest nationwide coverage transition since the Affordable Care Act. With the restarting of eligibility redeterminations, millions of Medicaid enrollees are now at risk of losing their coverage and there is intense interest in monitoring the impact on coverage. To promote transparency, the Centers for Medicare & Medicaid Services (CMS) is requiring that states report the results of eligibility redeterminations and many states are making that data public. SHVS continues to monitor the states that are publicly reporting their unwinding data either in the form of data dashboards or static pdfs and the states posting copies of their required CMS Monthly Unwinding Data reports.

As advocates and researchers start to analyze unwinding data, it has become clear that it is difficult to compare different states for a variety of reasons. For example, states are initiating redeterminations and therefore disenrollments in different months and some states are staging redeterminations in a way that focuses on certain groups first, such as starting with people least likely to remain eligible. States are using a variety of different strategies to mitigate procedural terminations. States also use different terminology, definitions, population denominators, and timeframes on their reporting, which also makes it difficult to compare one state’s data to another.

In spite of data challenges, there are some best practices states can follow when reporting unwinding data.

  • Release CMS Monthly Reports. While we typically don’t recommend releasing competing sources of data on the same topic, in this case, we recommend releasing CMS Monthly Reports alongside any state-specific data reporting to help satisfy calls from advocates and the media for comparable data across states. However, we recommend that states provide context about why the information may differ on state dashboards from CMS monthly reports. Kansas, for example, explains that data on their monthly unwinding reports is different from data on their dashboard because members move between reported categories.
  • Timely release. Given the magnitude and scrutiny of unwinding coverage transitions, we recommend that states produce a data report that can be updated easily and frequently – at least monthly. We recommend prioritizing accuracy and timeliness over depth. And, if states are refreshing state unwinding data monthly, they should consider releasing it in tandem with the CMS Monthly Unwinding data reports.
  • Prioritize key measures. Because timeliness of this data is so important, the report or dashboard needs to have enough data points to convey key information, but be limited enough to update quickly. In this case, we recommend focusing on measures that are already being reported (CMS Performance Indicators and indicators from the CMS Monthly Unwinding Data report). Key measures include:
    • Renewals initiated
    • Successful renewals
    • Ex-parte/passive renewals
    • Coverage terminations
    • Procedural terminations
    • Medicaid cases sent to the Marketplace
    • Call center volume
    • Number of terminations who reenroll in a specific period of time (e.g. 90 days)
  • Publish disaggregated data. While required CMS data reporting includes very limited data disaggregation, there is a great interest in understanding who is being impacted by the unwinding. At a minimum, we recommend displaying data breakdowns by:
    • Program type
    • Age (children versus adults)
    • Race
    • Ethnicity
    • Language
    • Income
    • Geography (ZIP code is best, but by county or any other level lower than statewide is helpful)
  • Provide context and transparency. As noted above, there are many reasons that the data reported by different states might be difficult to compare. We strongly encourage states to use their reporting vehicle to contextualize and explain various measures. This includes:
    • Document data revisions. We anticipate that states may be asked by CMS to make various adjustments retroactively to their data. States do not need to wait until data is final to post it publicly. They can address this by including revision dates when new data are posted. And wherever possible, maintain an archive of older data for comparability.
    • Include both proportions and counts. Proportions are especially useful to help make comparisons across states on measures like procedural denials, but counts are critical for understanding the denominators being used and to get a sense for the magnitude of impacts within states.
    • Include data labels, definitions, and context. Provide clear data labels, establish defined date ranges for data being displayed, add data refresh dates (as needed), describe population numerators and denominators if relevant (including exclusions such as pending cases). If the format allows, link to information that can help contextualize the information. This might include the state’s unwinding timeline, information about how redeterminations are being staged or any analysis or reaction to the results to date. For example, California posts their plan for prioritizing and distributing renewals on the same page as their unwinding data. Kentucky also has a webpage dedicated to unwinding that includes the state’s unwinding dashboard (the Kentucky Medicaid Renewals Data Snapshot), their required CMS unwinding reports and materials from monthly stakeholder sessions that provide a summary of the federal requirements, state goals and activities and their progress to-date.