State Reporting to Monitor the Unwinding of the Medicaid Continuous Coverage Requirement
Emily Zylla, Elizabeth Lukanen, and Lindsey Theis, SHADAC
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. Releasing data in this format allows states to follow some specific best practices, including providing 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, 46 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 46 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
- 19 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. Eleven states have not updated their state unwinding data reports since September. 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. Although CMS has indicated they only plan to continue reporting unwinding data through June 2024, we encourage 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 46 states reporting publicly, most are now reporting renewal and termination data. Some states are also reporting other interesting indicators such as:
- Reasons for procedural denials (see Colorado example below).
- Number of cases terminated that are re-enrolled or reinstated in Medicaid (see Massachusetts example below).
- Qualitative data from individuals about reasons why they did not renew Medicaid (see New Hampshire example below).
- Enrollment in CHIP (see Utah example below).
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 that 29 states and D.C. have been making ex parte renewal determinations on a household, rather than an individual level as regulations require. This has 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 program and geography (typically by county). Although CMS only asks 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 Arizona, Minnesota, Oregon and Washington’s dashboards below for additional examples of disaggregated data reporting).
State Unwinding Dashboards – Select Data Highlights
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.
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.
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.
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.
The dashboard provides the ability to disaggregate data in various ways such as by county, social vulnerability quartile, and member race/ethnicity.
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.
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.
Oregon also publishes call center data (shown below), including the daily average customer service score.
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).
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.