The Marketplace has step-by-step instructions for individuals enrolling in Marketplace coverage without a referral during the unwinding.
In this new expert perspective series, State Health and Value Strategies will highlight examples of the work states are engaging in to prepare for and operationalize the unwinding of the continuous coverage requirement to minimize coverage losses. This new series aims to showcase strategies that other states may be interested in adopting and highlight how states are leveraging federal flexibilities.
The Tracking Medicaid Enrollment Growth During the COVID-19 Pandemic Databook provides a comprehensive, detailed look at Medicaid enrollment trends to-date. Using Medicaid enrollment data from over 40 states, the Databook provides a comprehensive, detailed look at Medicaid enrollment trends from the beginning of the COVID-19 pandemic through December 2022. The Databook provides enrollment detail by state across four eligibility categories: expansion adults, children (including those enrolled in CHIP), non-expansion adults, and aged, blind, and disabled individuals. It also compares enrollment trends across expansion and non-expansion states. While variations in states reporting mean that the enrollment numbers in this report are not necessarily comparable across states (and should not be summed across states), the data reported do allow states and others to track enrollment trends. As a companion to the Databook, Manatt Health authored an issue brief, The State of Medicaid Enrollment Approaching Continuous Coverage Unwinding, that summarizes key findings from an analysis of the Databook.
To maximize efforts to maintain coverage, state Medicaid agencies and Marketplaces can now leverage digital channels as part of their overall outreach and communications efforts. Rapidly evolving changes in consumer media consumption habits as well as shifts in digital channels, and the ability to leverage data sources, enables granular audience targeting and efficient use of resources. These can be incorporated into an overall integrated outreach and education campaign to maximize renewals and coverage retention.
The unwinding of the Medicaid continuous coverage requirement represents the largest nationwide coverage transition since the Affordable Care Act, with significant health equity implications. Given the intense focus on coverage transitions during the unwinding, some states have initiated plans to publish a data dashboard to monitor progress. To date, three states—Iowa, Minnesota and Utah—have a public data dashboard. SHADAC will update this expert perspective as additional dashboards go live.
The tool aims to help states qualify for the sustained enhanced Federal Medical Assistance Percentage, avoid corrective action imposed by CMS, promote continuity of coverage and care during unwinding, and make long-term improvements to eligibility and enrollment infrastructure.
The West Virginia Bureau for Medical Services created a webpage where it will post documents the state is required to submit to CMS, including the baseline and monthly unwinding data reports.
Now that the details and timing associated with the unwinding of the Medicaid continuous enrollment requirement have been established by the Consolidated Appropriations Act, 2023 (CAA), states can start refining and implementing long laid plans to restart eligibility redeterminations and return to routine eligibility and enrollment operations. This expert perspective outlines the relevant reporting requirements that were included in the CAA and the corresponding reporting guidance provided by CMS in its January 2023 State Health Official letter, and presents considerations for state officials as they fulfill their federal obligations and address calls from advocates and others for transparency.
On Wednesday, February 8, State Health and Value Strategies hosted a webinar during which experts from Manatt Health reviewed CMS’ recently released State Health Official (SHO) letter related to “unwinding” the Medicaid continuous coverage guarantee, based on provisions included in section 5131 of the Consolidated Appropriations Act, 2023 (CAA).The webinar reviewed the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter, and discussed key considerations for state policymakers. As a reminder, SHVS has created a single-stop resource page to support states as they plan for unwinding.
On January 27, 2023, the Centers for Medicare & Medicaid Services (CMS) released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” This SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible.
Building on existing CMS guidance, the State Health Official letter details the requirements that states must comply with in order to receive the enhanced federal medical assistance percentage; clarifies expectations for states to comply with the Medicaid, CHIP, and marketplace reporting elements required by the CAA; and reviews implications of the CAA on select COVID-19 public health emergency-related flexibilities and authorities.
New state reporting templates and guidance released by the Centers for Medicare & Medicaid Services (CMS) on March 22, 2022, build upon a State Health Official letter released on March 3. The resources specify both the data and the metrics that states will be required to submit to monitor enrollment and renewal efforts as they resume routine Medicaid and CHIP operations following the end of the COVID-19 PHE. This expert perspective summarizes the new reporting requirements and presents a set of considerations for states as they begin implementing new unwinding policies, procedures, and reporting.
The Centers for Medicare & Medicaid Services (CMS) released additional templates and resources to support state reporting around enrollment and renewal efforts when the federal public health emergency (PHE) concludes. The resources include 1) a “Renewal Distribution Report” form in which states will be required to summarize their renewal plans, with a focus on mitigating inappropriate coverage loss during the unwinding period and 2) an “Unwinding Eligibility and Enrollment Data Reporting” Excel workbook and specifications document, which aims to support states in reporting on certain metrics around timely application processing, renewal initiation and completion, reason for termination, and fair hearings. CMS also previewed that states will eventually report on these metrics on a monthly basis.
When the Families First Coronavirus Response Act Medicaid “continuous coverage” requirement is discontinued states will restart eligibility redeterminations, and millions of Medicaid enrollees will be at risk of losing their coverage. A lack of publicly available data on Medicaid enrollment, renewal, and disenrollment makes it difficult to understand exactly who is losing Medicaid coverage and for what reasons. Publishing timely data in an easy-to-digest, visually appealing way would help improve the transparency, accountability, and equity of the Medicaid program. This expert perspective lays out a set of priority measures that states can incorporate over time into a data dashboard to track Medicaid enrollment following the end of the continuous coverage requirement. For a detailed discussion of the current status of Medicaid enrollment and retention data collection and best practices when developing a data dashboard to display this type of information, SHVS has published a companion issue brief.
The Families First Coronavirus Response Act (FFCRA) Medicaid “continuous coverage” requirement has allowed people to retain Medicaid coverage and get needed care during the COVID-19 pandemic. When continuous enrollment is discontinued, states will restart eligibility redeterminations, and millions of Medicaid enrollees will be at risk of losing their coverage. The current lack of publicly available and timely Medicaid enrollment, renewal, and disenrollment data will make it difficult to understand exactly who is losing coverage and for what reasons. One effective way to monitor this type of information is through the use of Medicaid enrollment and retention dashboards. This issue brief examines the current status of data collection to assess Medicaid enrollment and retention, summarizes potential forthcoming reporting requirements, and describes some of the best practices states should consider when developing a data dashboard to display this type of information. The issue brief lays out a phased set of priority measures and provides a model enrollment and retention dashboard template.
On November 24, CMS released a “punch list” of strategies states and the US territories can adopt to maintain coverage of eligible individuals as they return to normal operations after the end of the public health emergency. The strategies are organized around seven topics areas: (1) strengthening renewal processes; (2) updating mailing addresses; (3) improving consumer outreach, communication, and assistance; (4) promoting seamless coverage transitions; (5) improving coverage retention; (6) addressing strains on the eligibility and enrollment workforce; and (7) enhancing oversight of eligibility and enrollment operations. In this resource, CMS also flagged strategies they expect to have the biggest impact on mitigating coverage losses.
Following the expiration of the Public Health Emergency (PHE), states will resume normal eligibility and enrollment activities for all enrollees in Medicaid and the Children’s Health Insurance Program (CHIP). The volume of expected redetermination activity at the end of the PHE is unprecedented. This issue brief reviews state Medicaid/CHIP agency data and information technology (IT) system “table stakes”—strategies that will have the highest impact for states seeking to ensure that eligible enrollees are able to keep or transition to new affordable health coverage when the PHE continuous coverage requirements end. If adopted, these strategies will also enable states to dramatically improve Medicaid/CHIP enrollment and coverage retention in the longer-term for people eligible for government subsidized health coverage.
At the end of the public health emergency (PHE), people currently enrolled in Medicaid and the Children’s Health Insurance Program are at risk of losing their coverage unless state Medicaid/CHIP agencies take steps to update enrollee mailing addresses and other contact information. This expert perspective examines the information technology system, policy, and operational strategies states can consider to update key enrollee contact information to ensure eligible enrollees are able to keep or transition to new affordable health coverage at the end of the PHE.