Sneak Preview: HHS Extends Medicaid Reenrollment Data Collection

(The following is excerpted from a recent Thompson Grants Compliance Expert article.) In light of the complications that states have experienced during the post-COVID Medicaid reenrollment period, the Department of Health and Human Services (HHS) plans to continue collecting enrollee eligibility redetermination data from states “on an ongoing basis,” according to a recent Government Accountability Office (GAO) report.

States typically redetermine the eligibility of Medicaid enrollees annually and disenroll those who are no longer eligible. During the COVID-19 public health emergency, however, Congress required states to keep Medicaid enrollees continuously enrolled, which raised the number of enrollees from 63.8 million in February 2020 to 86.2 million in February 2023. Congress ended the continuous enrollment period in March 2023, requiring states to resume eligibility enrollment determinations, and if appropriate, disenroll ineligible individuals — a process known as “unwinding.”

States were required to submit monthly unwinding data (e.g., the number of redeterminations conducted and the number of individuals disenrolled) to HHS’ Centers for Medicare and Medicaid Services (CMS) from April 2023 through June 2024. Some states began disenrollments in April 2023, while the last state to begin conducting enrollments started in October 2023. When redetermining Medicaid eligibility, states generally assessed whether enrollees are included within specific categories (e.g., children, pregnant women, individuals with disabilities, and individuals over 65 years of age) and meet the applicable eligibility criteria.

“Given differing eligibility requirements for different Medicaid populations, determining eligibility is a complex process that is vulnerable to error,” GAO said. “Erroneous retention of ineligible individuals can increase program costs. Erroneous termination of eligible individuals can increase ‘churn’ (i.e., moving individuals out and then back into Medicaid coverage), resulting in worse health outcomes and higher program costs.”

Medicaid officials from several states that GAO reviewed explained that the Medicaid unwinding process was complex, adding that “the volume of redeterminations during unwinding was unprecedented.” One state official said the monthly redetermination caseload was double that of the caseload prior to the COVID-19 pandemic, while other state officials said their eligibility and enrollment systems needed significant updates, which sometimes forced them to conduct manual redeterminations. Other challenges state officials faced were a shortage of trained staff — many of whom had never performed Medicaid redeterminations — and enrollees who “may have stopped paying attention to their [responsibility for] renewal during the continuous enrollment period.”

(The full version of this story has now been made available to all for a limited time here.)

Join us for our following Thompson Grants events:
Federal Grants Forum State and Local Governments | Sept. 10-11, 2024 | Virtual Event
Nonprofit Legal, Finance, & Grants Conference | Oct. 1-2, 2024 | Arlington, Va.