Oct, 06, 2023

CMS Releases Third Batch of State-Reported Unwinding Data, With New Data on CHIP and Transitions to Marketplace Coverage

Patti Boozang, Kinda Serafi, and Michelle Savuto, Manatt Health

Introduction

On September 29, the Centers and Medicare & Medicaid (CMS) published a new release of state-reported Medicaid unwinding data through its Unwinding and Returning to Regular Operations after COVID-19 landing page. This data release covers June and preliminary data for July and, like previous releases of data (see SHVS’ expert perspective on CMS’ initial data release), includes national and state-specific metrics pertaining to Medicaid and Children’s Health Insurance Program (CHIP) eligibility renewal outcomes and total enrollment.

This month, as part of its timeline of planned data releases (see Table 1 below), CMS newly shared more comprehensive data on Marketplace enrollment and transitions—including cumulative enrollment data between April and June for HealthCare.gov, State-Based Marketplaces (SBMs), and the Basic Health Programs—and separate CHIP enrollment in April 2023. As a reminder, CMS plans to continue releasing unwinding data on a monthly basis until all data are reported for the months through June 2024. 

Key Findings[1]

  • CMS reports that of the 6.6 million redeterminations in June, 51% of enrollees (approximately 3.3 million individuals) had their coverage renewed, 25% (approximately 1.6 million individuals) were terminated from Medicaid or CHIP, and 24% (approximately 1.5 million individuals) cases were still pending. CMS notes that Arkansas, the District of Columbia, Delaware, Iowa, Illinois, Kansas, Kentucky, Maine, Michigan, Minnesota, Missouri, New Jersey, New York, Oklahoma, South Carolina, West Virginia and Wyoming held terminations of individuals for procedural reasons (i.e., failure to return required paperwork) for renewals due in June. Further, Oregon and Texas did not complete renewals for the cohort due in June. The state with the highest rate of procedural disenrollment was Idaho (67% or around 18,000 individuals) and the state with the highest rate of ex parte renewal[2] was North Carolina (74% or around 102,000 individuals).
  • According to new HealthCare.gov data in this month’s release, of the over 267,000 individuals whose Medicaid or CHIP coverage was terminated in April and whose accounts were transferred to HealthCare.gov, 22% (approximately 59,000 individuals) were determined eligible for Qualified Health Plan (QHP) coverage, of which 51,000 were eligible for advance premium tax credits (APTCs s). Of those who were found eligible, approximately 46,000 individuals selected to enroll in a QHP.[3]
  • For SBM states, of the over 593,000 individuals who were previously enrolled in Medicaid/CHIP and submitted applications for Marketplace coverage between April and June, nearly 70% (approximately 415,000 individuals) were QHP-eligible, but only about 11% of the total (approximately 63,000 individuals) later enrolled in a QHP. Ten percent of total applicants (approximately 60,000 individuals) were BHP eligible, of which 56,000 enrolled.
  • CMS reports that over two million individuals were enrolled in a separate CHIP in April.

Conclusion

CMS’ expanded data set, which will continue to be released until June 2024, provides helpful feedback for states and continues to indicate areas where course correction and technical assistance support may be necessary. It remains to be seen whether CMS will re-issue compliance letters based on states’ May data. However, CMS is expected to issue an interim final rule; which may codify into regulation new penalties that Congress has authorized during the unwinding period for states that fail to comply with federal reporting and renewal requirements in the Consolidated Appropriations Act, 2023.

[1] As in prior data releases, CMS’ data does not provide a complete picture of unwinding and should be interpreted with caution.

[2] “Ex parte” refers to verifying eligibility based on a review of available data sources without needing to send a renewal form and request information/documentation from the enrollee.

[3] CMS reports that the cumulative number of individuals who had previous Medicaid or CHIP enrollment was over 436,000 between April and June, with approximately 77% (about 337,000 individuals) eligible for APTC and 67% (approximately 291,000 individuals) ultimately selected to enroll into a QHP.