Apr, 01, 2022

Public Health Emergency (PHE) Unwinding Reporting Requirements: Considerations for States

Emily Zylla and Elizabeth Lukanen, SHADAC

The Medicaid continuous enrollment requirement prescribed by the Families First Coronavirus Response Act (FFCRA) during the COVID-19 Public Health Emergency (PHE) continues to provide a vital source of stable health coverage for millions of people. When the PHE ends, however, states will resume eligibility redeterminations for Medicaid and Children’s Health Insurance Plan (CHIP) enrollees, which could have a significant effect on coverage for both adults and children.

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.

New Unwinding State Reporting Guidance

The new guidance specifies that states will be required to submit two new reports to CMS: a one-time Renewal Distribution Report as well as a baseline and ongoing Unwinding Eligibility and Enrollment Monthly Data Report. States will submit these new metrics through the same portal in which they enter Performance Indicator data.

  • Renewal Distribution Report: Forty-five days before the end of the month in which the PHE ends, states will have to submit a one-time, primarily narrative, form that describes how they intend to distribute renewals and indicate which processes and strategies they are considering or have adopted to mitigate against inappropriate coverage loss–among people who remain eligible for Medicaid or CHIP–during the 12-month unwinding period. CMS will use this information to identify states at greatest risk of inappropriate coverage losses and will follow up with states as needed to ensure that proper mitigations are in place to reduce risk of inappropriate terminations and that states’ plans will establish a sustainable workload in future years. (See Box 1 for further reporting details.)
  • Unwinding Data Report: States will also have to report on certain metrics in order to demonstrate their progress towards restoring timely application processing, initiating and completing renewals of eligibility, and processing fair hearings on an ongoing basis. First, states will need to submit a one-time baseline report (see Box 2 for further reporting details), followed by a monthly report submitted by the eighth calendar day of each month (see Box 3 for further reporting details).

Reflections on New Unwinding Reporting Requirements for States

As states prepare for the unwinding of the continuous coverage requirement and the implementation of new required reporting activities, they should consider ways to demonstrate and communicate progress with key partners. The following strategies will ensure transparency to stakeholders, who will be critical in supporting coverage retention for eligible people, while also keeping policymakers informed about the success of this transition. 

Sharing these reports publicly. The current guidance does not specify whether CMS will share the data in either of these reports publicly. As previously noted, a lack of publicly available data on Medicaid enrollment, renewal, and disenrollment makes it difficult to understand exactly who is losing Medicaid coverage/transitioning to other coverage and for what reasons. Many advocates and researchers have been calling for increased transparency around this data, and calls for this kind of data are likely to increase as people enrolled in Medicaid have their eligibility redetermined.

Some states, such as Utah, are considering publishing new Medicaid enrollment and retention dashboards that would track this type of data in more easily digestible, visually appealing ways, and we encourage states to explore that possibility. State Health and Value Strategies will continue to monitor state activities in this area and will update this resource with examples of that kind of reporting as it is available. (https://halcyonliving.co.uk)

Consider the guidelines a “floor”, and expand monitoring measures to get better insights into unwinding. The templates and resources from CMS sets the minimum amount of reporting that all 50 states should produce, but many states already collect and report other data that would also be useful to share. For example, states already submit monthly Performance Indicator data for 11 different topic areas, including information on call center statistics that could help serve as an early warning sign as to how applicants and enrollees are faring as renewals and redeterminations begin.

Consider reporting data that is disaggregated beyond what CMS requires. The CMS guidance does not require states to report data disaggregated any further than by modified adjusted gross income and non-disability applications versus disability applications. Data broken down by various population characteristics (e.g., age, race/ethnicity, income, gender, language, or program type) or geographic areas make it easier to understand the disproportionate impact enrollment and renewal policies have on groups that have been economically and socially marginalized. States can prioritize the monitoring and reporting of disaggregated data even though CMS has not required it. At a minimum, we recommend displaying data breakdowns by program type, age, race, ethnicity, and geography (ZIP code is best, but county, or region, is helpful). States should also consider additional breakdowns as the data is available, such as by language, income, and disability status. Data reported in this way would help improve the transparency, accountability, and equity of the Medicaid program.

Seek Technical Assistance from CMS or SHVS to improve reporting. States that are unable to submit data as defined are directed to check a box labeled “Unable to Report” and include an explanation of why the state cannot report the metric. Guidance goes on to say that CMS may follow up to discuss further. States that cannot report these baseline metrics can take advantage of any technical assistance that CMS offers in order to improve the reporting of this data. Without this minimum up-to-date data, states, policymakers, advocates, and other key stakeholders lose the opportunity to identify barriers that populations may be facing to enroll or renew their Medicaid coverage, as well as opportunities to identify effective solutions.

Box 2. The Unwinding Baseline Report Will Ask States to Submit Data on the Following Metrics:

Box 1. The Renewal Distribution Report Will Ask States to Use Both Qualitative and Quantitative Information to Summarize:

  • The approximate number and percent of Medicaid and CHIP renewals that the state intends to initiate each month during the 12-month unwinding period (table)
  • The state’s plan to prioritize and distribute work during the 12-month unwinding period (narrative)
  • How the state will ensure that eligible individuals retain coverage and limit coverage losses for procedural reasons (narrative)
  • Which strategies the state currently utilizes or is planning to adopt to ensure eligible individuals remain enrolled or are transferred to the appropriate program during the unwinding period (fixed-choice checklist)
  • Any other type of strategy the state intends to implement to ensure that the state will not inappropriately terminate coverage for enrollees who continue to be eligible for Medicaid and/or CHIP and will appropriately transition the appropriate ineligible individuals to other health insurance affordability programs (narrative)
  • Which strategies the state currently utilizes or is planning to adopt to ensure the fair hearing process is timely and accessible for any individuals who lose coverage due to redeterminations triggered by the end of the continuous enrollment period (fixed-choice checklist)


Important notes:

  • This report contains similar content, but is different than the Unwinding Operational Plan, which states are expected to develop, but are not required to submit to CMS for approval
  • States have reported difficulty opening the Renewal Distribution Report form. Options for viewing it include – opening the link in the Microsoft Internet Explorer Browser or saving as a PDF, by right clicking the window, clicking “save as” and saving as an Adobe Acrobat Document.


Box 2. The Unwinding Baseline Report Will Ask States to Submit Data on the Following Metrics:

  1. Total pending applications received between March 1, 2020, and the end of the month prior to the state’s unwinding period
  2. Total number of individuals enrolled as of the end of the month prior to the state’s unwinding period
  3. State’s timeline for the renewal process
  4. Total number of Medicaid fair hearings pending more than 90 days at the end of the month prior to the state’s unwinding period


Box 3. The Unwinding Monthly Report Will Ask States to Submit Data on the Following Metrics:


  1. Total pending applications received between March 1, 2020, and the end of the month prior to the state’s unwinding period
  2. The total number of applications completed
  3. The total number of applications that remain


  1. The total number of enrollees for whom a renewal was initiated in the reporting period
  2. Total enrollees due for renewal in the reporting period, including broken down by:
    1. The number renewed and retained in Medicaid or CHIP (those who remained enrolled)

      1. Number of enrollees renewed on an ex parte basis

      2. Number of enrollees renewed using a pre-populated renewal form

    2. The number determined ineligible for Medicaid or CHIP (and transferred to Marketplace)

    3. The number terminated for procedural reasons (i.e., failure to respond)

    4. The number whose renewal was not completed

  3. Month in which renewals due in the reporting month were initiated
  4. Number of enrollees due for a renewal since the beginning of the state’s unwinding period whose renewal has not yet been completed

 Fair Hearings

  1. Total number of Medicaid fair hearings pending more than 90 days at the end of the reporting period