New Unwinding Data and Resources Released by CMS
Kaylee O’Connor and Patti Boozang, Manatt Health
This week, the Centers for Medicare & Medicaid Services (CMS) released new data related to the unwinding of the federal Medicaid continuous coverage requirement, along with additional unwinding resources. This expert perspective reviews newly available Medicaid, Children’s Health Insurance Program (CHIP), and Marketplace data, and summarizes key findings pertaining to Medicaid and CHIP enrollment, applications, and renewals, as well as Marketplace transitions.
New and Updated Unwinding Data and Resources
Medicaid and CHIP Enrollment and Applications
As of July 2023, more than 91.5 million individuals were enrolled in Medicaid and CHIP coverage, as compared to 70.9 million individuals in February 2020 (the month prior to the start of continuous enrollment) and 93.9 million in March 2023 (the final month that the continuous coverage requirement was in effect). CMS’ snapshot report provides a more granular breakdown of national enrollment data and finds that the number of children enrolled in Medicaid and CHIP has increased by about 17% since February 2020 and decreased by 2.7% since March 2023. (CMS also reports a slight increase in separate CHIP enrollment nationally from April to May 2023.) Enrollment among Medicaid adults has increased by about 42% since February 2020 and decreased by 2.1% since March 2023. (For information on changes in Medicaid and CHIP enrollment by state, see CMS’ Medicaid and CHIP Unwinding Operations Snapshot for July 2023.) While the effect of unwinding on rates of coverage loss in Medicaid and CHIP generally appears less dire than projections, projections did not account for recent unwinding developments, such as CMS’ directive for 29 states and Washington D.C. to reinstate coverage and put in place mitigation strategies for at least 500,000 individuals whose coverage was terminated inappropriately. State actions to pause procedural disenrollments (e.g., due to failure to return required paperwork) or to negotiate extensions of the unwinding period beyond the allotted 12 months may be minimizing the effect of unwinding now, but could lead to a higher number of terminations in the months ahead.
The number of Medicaid and CHIP applications that enrollees have submitted to states since the start of unwinding continues to increase, and the number of applications in July 2023 has far surpassed that of July 2020, 2021, and 2022. This increase in applications could be—at least in part—attributable to reinstatements of Medicaid and CHIP coverage that are counted as new applications in the data (either during the 90-day reconsideration period or at the direction of CMS as areas of non-compliance are identified). Despite the increased volume of applications, state Medicaid and CHIP application processing times improved when comparing April to June 2023 data to that of the same period in 2022. For the months of April to June 2023, Alabama, Connecticut, Maryland, Massachusetts, New York, Oklahoma and Washington were exceptionally high performers, processing on average 80% to 100% of determinations within 24 hours. [Also see CMS’ Medicaid and CHIP Unwinding Operations Snapshot for the most recent (July 2023) application processing data, as well as call center wait time and abandonment rate data.]
Medicaid and CHIP Renewal Outcomes and Marketplace Transitions
CMS reports that, of the 7.1 million redeterminations due in July 2023, 52% of enrollees had coverage renewed, 23% were terminated from Medicaid or CHIP, and a quarter of cases are still pending. Ex parte renewals accounted for nearly 60% of successful renewals, and procedural closures accounted for 71% of terminations. CMS reports that 14 states—Arkansas, California, Delaware, Illinois, Kansas, Kentucky, Maine, Michigan, Minnesota, New Jersey, New York, Oklahoma, Washington D.C., and Wyoming—paused all or some procedural terminations for their July cohort of renewals, resulting in higher rates of pending renewals in some of these states.
With respect to cumulative renewal outcomes from March to July 2023, four states (Connecticut, Massachusetts, North Carolina, and Oregon) reported that 70% or more of enrollees who were due for renewal had their Medicaid or CHIP coverage successfully renewed. States including Idaho, Massachusetts, Nevada, South Dakota, Texas, and Utah had termination rates exceeding 50%. Nevada, Texas, and Utah also experienced the highest rates of procedural terminations: 53%, 47%, and 51%, respectively.
While it’s still early to draw conclusions, CMS data suggests that transitions from Medicaid and CHIP to Marketplace coverage during the unwinding period may be exceeding historical trends. According to Medicaid and CHIP Payment and Access Commission findings, only about 3% of people terminated from Medicaid and CHIP enroll in Marketplace coverage within a year after disenrolling. CMS’ cumulative data on Marketplace transitions suggests that:
- For HealthCare.gov between April and May 2023: Of the 914,000 individuals whose Medicaid or CHIP was terminated, approximately 120,000 individuals (or 13%) were determined eligible and made a qualified health plan (QHP) selection.
- For State-Based Marketplaces between April and July 2023: Of the nearly 1.2 million individuals whose Medicaid or CHIP coverage was denied or terminated following renewal, nearly 20% of individuals enrolled in QHP or Basic Health Program coverage (124,000 individuals or 11%, and 88,000 people or 8%, respectively).
CMS plans to continue releasing unwinding data on a monthly basis until all data are reported for the months through June 2024; each month’s data will be released as part of multiple releases given differences in availability of different data sources. The full picture regarding application, enrollment and renewal outcomes during unwinding is incomplete, and there are still myriad stories of Medicaid and CHIP enrollees confronting serious challenges in their attempts to remain covered. But CMS’ October data release may be a sign that efforts on the part of states, the federal government, and community partners to collaborate to improve unwinding results are positively impacting the trajectory of unwinding. In the months ahead, it will be critical for healthcare stakeholders to build on progress to date to ensure that individuals retain access to affordable healthcare through a coverage program for which they are eligible—whether it be Medicaid or CHIP, the Marketplace, Medicare, or Employer-Sponsored Insurance.
 For more information on CMS’ guidance instructing states to assess whether they are in compliance with the federal requirement that all Medicaid and CHIP eligibility renewal processes be conducted at the individual level, see this State Health and Value Strategies analysis.
 States are required by 42 CFR § 435.916 to reconsider eligibility without requiring the individual to fill out a full new application if the renewal form/documentation is returned within 90 days after the date of termination, or a longer period elected by the state.
 CMS notes: Massachusetts reports the dispositions of renewals completed in the reporting period. Therefore, the state is unable to report the number of pending renewals to CMS. Massachusetts’ data is excluded from the national totals.
 HealthCare.gov is unable to report on whether a HealthCare.gov Marketplace consumer lost Medicaid or CHIP until a few months following the coverage loss date, so data on individuals transitioning from Medicaid or CHIP to HealthCare.gov is available later than data on renewals or early Marketplace data.