State-Based Marketplace Transition Data During the Unwinding
Elizabeth Lukanen and Emily Zylla, SHADAC
The unwinding of the Medicaid continuous coverage requirement is currently underway in all states and the District of Columbia. While state Medicaid agencies are responsible for processing the eligibility redeterminations of the more than 94 million enrollees in the program as of April 2023, State-Based Marketplaces (SBMs) are also playing a significant role. SBMs are coordinating with Medicaid agencies using a number of different strategies to ensure a smooth transition for people who no longer qualify for Medicaid, but might be eligible for a qualified health plan (QHP) offered through the Marketplace. This work is critically important to keeping people insured, as estimates suggest that of those individuals moving off Medicaid, 2.7 million likely qualify for premium tax credits through the Marketplace and of these, 60% or 1.7 million are eligible for zero-premium plans.
Given the potential to reduce coverage losses, there is intense interest in data that monitors transitions between Medicaid and Marketplace coverage and, more importantly, the outcomes of those transitions. In an effort to promote transparency, the Centers for Medicare & Medicaid Services (CMS) requires states to report related metrics. CMS released the first batch of this data on July 28, 2023 and additional data on August 31, but information related to transitions was very limited and included many caveats. Later in September, CMS plans to release more comprehensive data on transitions from Medicaid and Children’s Health Insurance Program (CHIP) to Marketplace coverage in states that operate on HealthCare.gov, along with more recent transition data for SBMs that use their own eligibility platform. Given data concerns and cautions regarding state comparisons, SBMs that use their own eligibility platform should consider releasing their own data on Marketplace transitions and the outcomes of those transitions. This will allow the state to present the most current data available in the context of their broader unwinding efforts. Key considerations for presenting outcomes data include:
- Draw on existing reporting requirements. Because timeliness of this data is so important, SBMs should start by releasing the CMS-required Marketplace indicators—the number of individuals determined eligible for a QHP and the number who selected a plan. Beyond that, SBMs could release additional data related to process—such as whether the enrollment was active or passive—and outcomes—such as whether people qualified for financial assistance or whether they qualified for a zero-dollar plan.
- Present Marketplace and Medicaid data together. The best data dashboards present Medicaid and Marketplace data side-by-side, offering a wholistic view of the impact of unwinding. Several of the states who are currently reporting do this well, including Pennsylvania, featured below.
- Publish disaggregated data. 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
- Geography (ZIP code is best, but by county or any other level lower than statewide is helpful)
- Eligibility for or receipt of financial assistance (e.g., advance premium tax credit or cost-sharing reduction payments)
- Provide context and transparency. There are many reasons that Marketplace transition outcome data reported by different states might be difficult to compare. CMS has outlined these data limitations and specifically cautioned against comparing data from HealthCare.gov to data from SBMs. States should address this in their reporting by clearly labeling data time periods and documenting data revisions, providing clear data labels and definitions, and including both proportions and counts so it easy to understand the group being reported on.
- Make the data easy to find. Many SBMs release information and data via materials such as board meeting minutes (e.g. California, Colorado and Minnesota). Unless you know where to look, these materials can be hard to find and often do not appear in a cursory Google search. If a state does plan to release unwinding data in this way, consider cross-posting in order to increase visibility. For example, data could also be released as a blog post, highlighted in an SBM newsletter, or put out as a press release. Alternatively, the state could post links to the materials on a highly trafficked part of the SBM or Medicaid website for more permanency.
Outside of the required federal reporting, many states are releasing their own data related to unwinding, including a handful of states who are reporting the number of individuals deemed ineligible for Medicaid and were sent to the Marketplace. Given their important role in facilitating these coverage transitions, SBMs that use their own eligibility platform are well positioned to share crucial and coveted data on Marketplace transitions and outcomes in a timely manner. Below is detailed information on which of the 18 SBM states are reporting data on Marketplace transition outcomes.
SHADAC will continue to update this expert perspective as more states publish their unwinding data.
SBMs Reporting Marketplace Transition Outcome Data
Note: In some cases, SBMs publish Marketplace transition outcome data in a more ad-hoc way (e.g., in a legislative report) or in administrative documents that are hard to access (e.g., board meeting minutes—examples include California, Colorado and Minnesota). Because these data are not being systematically reported and are more difficult to access, they are not represented in the map above.
Variation in State Reporting
To date, seven of the 18 SBMs that use their own eligibility platform are reporting outcomes for individuals who exited Medicaid and were transitioned to the Marketplace. (California has indicated that they will start reporting transition data in October 2023.)
- Three states are reporting whether individuals were eligible for a QHP.
- Seven states are reporting whether individuals selected a plan.
- Three states are reporting enrollment and/or eligibility broken down by whether the individual received financial assistance (e.g., advance premium tax credit or cost-sharing reduction payments).
Select Data Highlights
In addition to general information on transition outcomes, most of the states reporting outcome measures are providing additional information of interest, though this detail differs by state. Select data highlights are provided below.
Massachusetts Health Connector Membership During MassHealth Redeterminations
Massachusetts presents a variety of data on the eligible but not enrolled population (those eligible for a QHP but have not selected a plan or effectuated their premium), including data showing the 10 communities with the largest concentration of eligible but not enrolled individuals. Massachusetts also provides an informative dashboard glossary that defines key terms and provides data definitions.
New York State Public Health Emergency Unwind Dashboard
New York provides information on transitions to the Marketplace based on which program an individual was previously enrolled in (e.g., did they transition to the Marketplace from CHIP or Medicaid).
Pennsylvania Unwinding Renewals Progress Tracker
Pennsylvania presents side-by-side renewal outcome metrics for Medicaid and the Marketplace, providing a holistic view of coverage transitions across the state. In addition, the state provides information on the outcomes of transitions to Pennie, the state’s official health insurance Marketplace, by county and ZIP code.
Health Source RI (HSRI) Return to Normal Eligibility and Enrollment Summary
Rhode Island provides information on whether individuals transitioning from Medicaid to Marketplace coverage were auto enrolled and whether their transition was based on a change in eligibility status (e.g., determined ineligible for Medicaid) or a procedural denial for not returning a renewal.