CMS paused Medicaid coverage redeterminations in six states due to procedural issues causing improper disenrollments. States were found violating federal requirements. Delays vary by state, and CMS worked with stakeholders to raise awareness among beneficiaries. The pauses reinstated those wrongly disenrolled but increased states’ burden to reprocess cases. Projections suggest they could prevent between 8 to 24 million beneficiaries from losing coverage. Improved oversight and strategies like automated renewals and outreach can help avoid future improper disenrollments.
In several states, the redetermination process for Medicaid coverage has led to unjust disenrollments due to procedural issues. To address this concern, CMS has taken action by putting a halt on coverage redeterminations in at least six states, nearly four months after the Medicaid continuous enrollment provision expired.
During a press call on July 19, CMS Administrator Chiquita Brooks-LaSure and Deputy Administrator Dan Tsai from the Center for Medicaid and CHIP Services explained the rationale behind the pauses. The decision to pause redeterminations was driven by the fact that most coverage losses among Medicaid beneficiaries were occurring due to procedural reasons. These situations arose when states were unable to determine an individual’s eligibility because the renewal process had not been completed, often resulting from a lack of awareness, incorrect addresses, or beneficiaries not receiving a Medicaid renewal form.
To address the issues, CMS identified violations of federal requirements in approximately six states. For beneficiaries affected by procedural terminations resulting from difficulties in following the regulatory process, CMS suspended further terminations. Furthermore, the agency instructed states to reinstate individuals who had been disenrolled, leading to tens of thousands of people being reinstated in some states.
Another concern raised by CMS was the presence of system glitches in some states, preventing the use of electronic data matching for automatic renewals. Ideally, income data should have been matched with recent data to verify if an individual’s income remained unchanged, allowing states to renew their coverage and notify eligible beneficiaries accordingly.
The length of the redetermination pauses varied by state, with termination delays ranging from 30 to 90 days to allow sufficient time for corrections in their systems. The duration depended on how quickly states could address the issues identified by CMS.
If states fail to rectify their errors and resume proper redeterminations, they risk losing their enhanced federal funding for Medicaid programs. To mitigate these issues, CMS has engaged with stakeholders in the private sector, including health plans and providers, to raise awareness among Medicaid beneficiaries about the renewal process.
The surge in Medicaid enrollment during the COVID-19 pandemic, which grew by 28 percent due to the introduction of the continuous enrollment provision by Congress, has added to the challenges of ensuring ongoing coverage. Despite this, CMS remains committed to reinstating eligible beneficiaries who lost coverage over the next 12 months.
Various strategies have been suggested to prevent wrongful terminations during the pause. For states facing administrative challenges, increasing automated renewals, conducting additional outreach, and improving customer service are recommended to avoid improper disenrollments. For states found in violation of federal requirements, enhanced oversight is deemed necessary, and having more personnel on the ground to observe and report violations can help facilitate prompt resolution by CMS.
The impact of the procedural termination pauses differs for beneficiaries and states. The pauses allowed improperly disenrolled beneficiaries to be reinstated and provided an opportunity for them to complete the renewal process. Additionally, the delays may indicate improvements in addressing disenrollment issues for future beneficiaries. However, these pauses may increase the burden on state Medicaid programs, which are already facing staffing challenges, as they now have to revisit and reprocess cases, leading to further backlogs.
Projections by KFF researchers suggest that between 8 million and 24 million Medicaid beneficiaries could have lost coverage through the redetermination process. However, procedural termination pauses have the potential to reduce these coverage losses by avoiding improper disenrollments.