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CMS Steps In On Disenrollments Due to Medicaid Redeterminations

Since April 1, 2023, over 3 million people have been disenrolled from Medicaid coverage.  It is not surprising that this number is large and will continue to grow.  The Kaiser Family Foundation (KFF) states that Medicaid/CHIP enrollment grew from 23.3 million in February 2020 to nearly 94 million as of information from March 2023.  As states move along the redetermination process, estimates of how many people will lose their coverage vary, with KFF projecting 17 million and a Department of Health and Human Services analysis from last summer projecting 15 million enrollees.

However, what is surprising is that approximately three-quarters of current disenrollments are for procedural reasons: meaning that recipients did not complete the renewal process, possibly due to not receiving forms or not understanding instructions, among other reasons.

Due to concerns that many of these individuals may still be eligible for coverage, Centers for Medicare and Medicaid Services (CMS) have stopped eligibility checks to 12 states to address concerns about procedural disenrollments.  These dozen states are now working with CMS to temporarily halt terminations and address compliance issues with renewal requirements for some or all of their enrollees.  While CMS is not publicly naming the states at this time, they have made it clear that if any state fails to comply in the future, that information will be made public.  CMS administrator Chiquita Brooks-LaSure emphasized the importance of collaboration with states and the potential consequences if they do not adhere to federal requirements—including the risk of losing their federal Medicaid matching funds.

CMS says it will be closely tracking state data and fielding complaints. The agency will issue corrective actions, including pausing terminations, reinstating coverage and addressing “systems glitches”.  Congress has given CMS the discretion to impose financial penalties and withhold extra federal funding from states that do not comply with renewal rules. The agency is also providing extensive technical assistance to states and encouraging them to spread renewals over 12 months as well as increasing auto-renewals based on available data to minimize unnecessary paperwork.

Also, check out our blog from January 2023 – Don’t Let Your Consumers’ Medicaid Fall Thru The Cracks.


Sources:  Articles from ANCOR, Noah Block (7/25/23) and CNN, Tami Luhby (7/20/23)