Jan, 11, 2024

State Reporting to Monitor the Unwinding of the Medicaid Continuous Coverage Requirement

Emily Zylla, Elizabeth Lukanen, and Lindsey Theis, SHADAC

States continue to refresh their reporting throughout the unwinding, but as of January 2024, no new measures have been added and no new states are reporting data.

As the unwinding of the Medicaid continuous coverage requirement continues, both states and the federal government are tracking and monitoring the impacts of the resumption of eligibility redeterminations and disenrollments. The Centers for Medicare & Medicaid Services (CMS) continues to release monthly batches of required state data reporting metrics. However, given the time-lags and caveats of the CMS data, many states have decided to also publish their own state data dashboards. On December 18, 2023 CMS released an informational bulletin that, for the first time, officially encouraged states to supplement their federal reporting with their own state-specific data analysis, as well as to follow best practices of reporting data broken down by eligibility group and other demographic characteristics (e.g., age, race, ethnicity, language). 

Releasing state-data via a dashboard or some other format allows states to follow other specific best practices, including the ability to provide additional detail about definitions, timeframes, and state context that are important for communicating the unique and specific circumstances that states are experiencing during unwinding. Colorado’s state dashboard, for example, highlights the state’s lower unemployment rate and provides context around the state’s reconsideration period in order to help users understand the CMS data reports. Several states are also using state dashboards to report how many individuals have been reinstated in Medicaid after a termination (see the SHVS expert perspective on States’ Reporting of Medicaid Unwinding Reinstatement Data), thus telling a more complete story about what happens to individuals after they are disenrolled.

States Publicly Posting Unwinding Data

To date, 47 states including the District of Columbia (D.C.) have publicly published their own unwinding data in some format (this does not include states with pre-existing enrollment dashboards that don’t specifically identify unwinding cohorts). In most cases, state Medicaid departments are releasing those data, although some State-Based Marketplaces (SBMs) are also publishing unwinding data (see the SHVS expert perspective on SBM Marketplace Transition Data During the Unwinding). Of the 47 states currently reporting data:

  • 24 release state unwinding data online in either an interactive dashboard or static pdf format.
  • Three states only release copies of their required CMS Monthly Unwinding Data
  • 20 states release both state data and their CMS Monthly Unwinding Data reports.

In some cases, states are publishing unwinding information in an ad-hoc way—such as by a press release. Because these data are not being systematically reported, they are not represented in the map above.

As unwinding has progressed, the number of new states reporting unwinding data has slowed significantly and states are updating their data less frequently. Fifteen states have not updated their state unwinding data reports since October. Arkansas and Idaho report to have completed all redeterminations and are no longer reporting through their unwinding dashboards. Iowa, which was one of the first states to publish a state unwinding dashboard, has removed renewal data from its “Medicaid and Covid Unwind Dashboard.” Both Arkansas and Iowa, however, do continue to make monthly reports to CMS publicly available. 

The public release of unwinding data has proven to be a valuable tool in understanding who is losing Medicaid coverage and why. States and advocates have successfully used the data to both monitor outcomes and adjust strategies. While CMS previously indicated it would  continue reporting unwinding data through June 2024, CMS’ December informational bulletin noted that states that are not meeting unwinding deadlines or experiencing other compliance issues may be required to provide additional data and/or report information more frequently. Therefore, we encourage all states to continue to make detailed disenrollment, renewal, and call center data (in addition to the enrollment data most states already report) available publicly on an ongoing basis.

SHADAC will continue to update this expert perspective as states update their unwinding data.

Variation in States’ Reporting of Indicators

There is a wide variation in the indicators that states are reporting on their state data dashboards and reports. Of the 47 states reporting publicly, most are now reporting renewal and termination data. Some states are also reporting other interesting indicators such as:

It’s important to note that states use different terminology, definitions, population denominators, and timeframes on their dashboards making it difficult to compare one state’s data to another. In some instances, the data displayed on state dashboards also varies from what states include in their monthly reports to CMS (see Georgetown’s State Unwinding Renewal Data Tracker for a summary of states’ monthly CMS reports).

Another cause of variation in the types of indicators reported across states is that states began disenrolling people from Medicaid in different months. For example, Arkansas resumed eligibility determinations in April 2023, and as of October 9th, the state indicated that it had fully completed its statutorily required six-month unwinding process. In contrast, Oregon started initiating procedural terminations in October and plans to take 10 months to complete eligibility redeterminations. Data reporting and interpretation across states is further complicated by the announcement from CMS on August 30, 2023 that 29 states and D.C. had been making ex parte renewal determinations on a household, rather than an individual level as regulations require. This caused some states to pause procedural terminations, reinstate coverage and/or implement temporary extensions for renewal. 

Unwinding Indicators & Disaggregated Data Reported by States

 

 

Few states are reporting disaggregated data on their dashboards. The most common breakdowns that states are providing are by age and geography (typically by county). Although CMS only requires states to report data by modified adjusted gross income (MAGI) and non-disability applications versus disability applications, additional data breakdowns by age, race, ethnicity, and program type can elucidate important trends about the disproportionate impact of unwinding on groups that have been economically or socially marginalized. (See the state dashboards below for examples of disaggregated data reporting). 

State Unwinding Dashboards – Select Data Highlights

Arizona Health Care Cost Containment System – Eligibility Dashboard

Unwinding data is presented as a static document (pdf). The dashboard provides the number of renewals in process, closed, and approved for regular Medicaid members and “COVID override” members (individuals who did not complete a renewal or failed to supply needed documentation during the public health emergency, or those who were found to be factually ineligible during that time). The dashboard also provides counts of the number of COVID override individuals enrolled by health plan and detailed race and ethnicity information for individuals enrolled, renewed, and terminated. In December 2023, Arizona added a new zip code heat map to their dashboard, highlighting areas where individuals are at highest risk of losing coverage. Arizona also announced that they have completed renewals for all members of the COVID override group.

Screenshot: 1/10/2024

 

Colorado Department of Health Care Policy & Financing – Continuous Coverage Unwind Reports

Monthly unwinding data, as well as terminology definitions and context are summarized in the reports. Historical data is also compared to current renewal data. For example, Colorado notes that during the two years prior to the pandemic an average of 41% of Medicaid members lost coverage annually–with 12% of those losing eligibility for procedural reasons. Detailed breakdowns of the number and percent of individuals who are no longer eligible for specific reasons are provided.

Screenshot: 10/11/2023

 

Indiana Family and Social Services Administration – Medicaid Renewals and Outcomes Dashboard

Indiana’s dashboard provides a highly visual, interactive interface for the user. Renewal outcome data is filterable by geography, demographic, program data and managed care entity. Both total counts and percentages are displayed. 

Screenshot: 9/19/2023

 

MassHealth Eligibility Redetermination Dashboard

MassHealth publishes a monthly dashboard that provides data on member renewals and departures, filterable by age, program type, disability status and whether the member resides in a “priority community” (i.e., one of the top 15 towns or cities where the most MassHealth members are at risk of losing coverage). Massachusetts is also one of nine states (see indicator table above) that report the number of terminated members who re-enroll in Medicaid after a specific period of time.

Screenshot: 10/11/2023

 

Minnesota Department of Human Services – Renewal Dashboard

The dashboard provides the ability to disaggregate data in various ways such as by county, social vulnerability quartile, and member race/ethnicity.

Screenshot: 10/11/2023

New Hampshire Department of Health and Human Services Medicaid Continuous Enrollment Unwinding Report

New Hampshire’s dashboard is a static report (pdf) summarizing multiple metrics including renewal status, renewal outcomes, reasons for closure, number of closed cases referred to the Federally Facilitated Marketplace, and the number of cases that have reopened. The report also displays results of a call campaign the state undertook to reach households with vulnerable individuals using Medicaid whose cases were closed for failure to renew. State staff asked respondents about the reasons they did not renew their Medicaid. 

Screenshot: 9/6/2023

 

Oregon Department of Human Services – Medical Redeterminations Dashboard

The dashboard provides statistics showing the number of renewals due each month as well as the number not started, initiated, and completed. The dashboard also presents data disaggregated by written language, gender identity, race and ethnicity, disability status, housing status and reason for closure. 

Screenshot: 10/11/2023

Oregon also publishes call center data (shown below), including the daily average customer service score.

Screenshot: 5/3/2023

 

Utah Department of Health & Human Services – Unwinding Eligibility Data Dashboard

The Utah dashboard provides detail on redetermination progress (e.g., average days to decision, fair hearing requests, reviews for non-Medical program) and outcomes (e.g., transfers to the Marketplace, transitions from Medicaid to CHIP).

Screenshot: 10/11/2023

Screenshot: 10/11/2023

 

Washington State Health Care Authority – Continuous Enrollment Unwind Data

Unwinding data is presented as a static document (pdf) which is updated monthly. Data are focused on the timing and characteristics of forthcoming renewals, including detail by month, managed care organization, and demographics (e.g., age, race, language, and geography). The tables also summarize the number of individuals terminated at the end of each month by several demographic categories including reasons for termination, managed care enrollment, race, ethnicity, and language.  

Screenshot: 10/11/2023